GLOBAL REPORTING INITIATIVE

The Global Reporting Initiative (GRI) provides a globally applicable framework in the form of guidelines that set out economic, social and environmental indicators for organisations to report against.

As with prior years, the GRI G3 Guidelines have been the basis for the preparation of our 2009 online reporting, together with the Business Sustainability content in IAG's 2009 Annual Review. It represents a balanced presentation of our organisation's economic, environmental and social performance and governance, and has been designed to provide our stakeholders with meaningful information about IAG.

We have also used the GRI Financial Services Sector Supplement: Social Performance and the GRI Financial Services Sector Supplement: Environmental Performance to develop the online reporting content. All G3 based reports must self declare the level to which they have applied the GRI reporting framework-their 'Application Level'.

Our reporting applies the GRI reporting framework to a B+ application level, which means that we have demonstrated robust sustainability reporting and well developed reporting systems based on the GRI G3. We have provided an explanation about any core indicators that we have not reported against. All GRI indicators are listed in the GRI index.

The data and information referred to in the GRI Index have been independently assured by Net Balance Management Group (NBMG) and the financial information has been independently audited by KPMG. Please refer to NBMG's assurance statement and to our 2009 Annual Report for the KPMG assurance statement.

Adherence to the GRI requirements are marked as a 'C' for Conformance;
'PC' for Partial Conformance; and a 'NR' for Not Reported.
'NA' is used when as issue is Not Applicable and 'GRI only' is used for indicators that are reported only in this index.

Standard disclosures
Performance indicators
Financial services sector supplement

Performance indicators

GRI indicator Status Comments
Economic performance indicators
EC1 Direct economic value generated and distributed. C Annual review (43kb .pdf);
5 year financial performance.
EC2 Financial implications and other risks and opportunities for the organisation's activities due to climate change. PC Key risks and opportunities;
IAG's Carbon Disclosure Project 2009.
EC3 Coverage of the organisation's defined benefit plan obligations. GRI
only
All new staff members enter accumulation style benefits. Historical defined benefit arrangements are closed to new members and are managed by the operators of the funds in their respective countries.
EC4 Significant financial assistance received from government. GRI
only
No significant financial assistance was received from government.
EC5 Range of ratios of standard entry level wage compared to local minimum wage at significant locations of operation. GRI
only
At a minimum, IAG offers wage levels that meet the legislative requirements of the jurisdictions in which we operate although our goal is to offer competitive wages for comparable roles in comparable companies in the relevant labour market.
EC6 Policy, practices, and proportion of spending on locally based suppliers at significant locations of operation. GRI
only
Interact with our suppliers is governed by our Supplier Selection Guidelines (19kb .pdf).
EC7 Procedures for local hiring and proportion of senior management hired from the local community at locations of significant operation. GRI
only
When recruiting for positions we advertise internally and externally as necessary. External advertising for roles in regional centres includes local papers and on regional job search websites. We have not reported the proportion of senior management hired from the local community;
Our performance.
EC8 Development and impact of infrastructure investments and services. NA IAG does not provide funds for these kinds of developments.
EC9 Understanding and describing significant indirect economic impacts, including the extent of impacts. PC The economic impacts of taxation on insurance;
Developing innovative products for customers;
Innovative ways of getting customers back on the road faster;
Addressing the issue of underinsurance and non-insurance.
Environmental performance indicators

Strategy and profile

EN1 Materials used by weight or volume. PC Our performance–environment.
EN2 Percentage of materials used that are recycled input materials. PC Our performance–environment.
EN3 Direct energy consumption by primary energy source. C Our performance–environment.
EN4 Indirect energy consumption by primary source. C Our performance–environment.
EN5 Energy saved due to conservation and efficiency improvements. PC Our performance–environment;
Our performance– Greening our property network through more efficient buildings
EN6 Initiatives to provide energy efficient or renewable energy based products and services, and reductions in energy requirements as a result of these initiatives. PC Our performance–Rewarding customers for sustainable activities
EN7 Initiatives to reduce indirect energy consumption and reductions achieved. C Our performance–environment.
EN8 Total water withdrawal by source. GRI
only
This indicator has been investigated in 2009 however difficulty has been experienced in obtaining the relevant data. We will continue to review this indicator in the current year.
EN9 Water sources significantly affected by withdrawal of water. GRI
only
This indicator has been investigated in 2009 however difficulty has been experienced in obtaining the relevant data. We will continue to review this indicator in the current year.
EN10 Percentage and total volume of water recycled and reused. GRI
only
This indicator has been investigated in 2009 however difficulty has been experienced in obtaining the relevant data. We will continue to review this indicator in the current year.
EN11 Location and size of land owned, leased, managed in, or adjacent to, protected areas and areas of high biodiversity value. NA IAG’s operations do not impact on areas of high biodiversity value.
EN12 Description of significant impacts of activities, products, and services on biodiversity in protected areas and areas of high biodiversity value outside protected areas. NA IAG’s activities, products and services do not impact on areas of high biodiversity value.
EN13 Habitats protected or restored. PC Our performance–community
EN14 Strategies, current actions, and future plans for managing impacts on biodiversity. PC Our approach.
EN15 Number of IUCN Red List species and national conservation list species with habitats in areas affected by operations, by level of extinction risk. NA IAG’s operations do not impact on habitats with IUCN Red List species and national conservation list species.
EN16 Total direct and indirect greenhouse gas emissions by weight. C Our performance–environment.
EN17 Other relevant indirect greenhouse gas emissions by weight. GRI
only
We have reported on all of our largest known emission sources. We are investigating other sources of our indirect emissions.
EN18 EInitiatives to reduce greenhouse gas emissions and reductions achieved. PC Our performance–environment.
EN19 Emissions of ozone depleting substances by weight. NR As a financial institution IAG does not directly produce significant amounts of ozone depleting substances or other significant emissions such as SOx and NOx.
EN20 NO, SO, and other significant air emissions by type and weight. NR See EN19 for more information.
EN21 Total water discharge by quality and destination. NA As a financial institution we do not have any significant discharges to water.
EN22 Total weight of waste by type and disposal method. C Our performance–environment.
EN23 Total number and volume of significant spills. NA As a financial institution we do not have significant spills.
EN24 Weight of transported, imported, exported, or treated waste deemed hazardous. NA We do not have any hazardous waste.
EN25 Identity, size, protected status, and biodiversity value of water bodies and related habitats significantly affected by discharges of water and runoff. NA As a financial institution we do not have any significant discharges to water.
EN26 Initiatives to mitigate environmental impacts of products and services, and extent of impact mitigation. PC

Our approach–environmental;
Our performance–environment.

EN27 Percentage of products sold and their packaging materials that are reclaimed by category. NR IAG does not produce physical products.
EN28 Monetary value of significant fines and total number of non monetary sanctions. GRI
only
There were no known sanctions for non compliance imposed on IAG in 2009.
EN29 Significant environmental impacts of transporting products and other goods and materials used for the organisations operations, and transporting members of the workforce. NR IAG does not generate significant environmental impacts through transportation of its products and services. IAG does not measure the environmental impacts of workforce transport.
EN30 Total environmental protection expenditures and investments by type. GRI
only
Our environmental protection expenditures have included the costs of disposing our waste, in kind expenditure through IAG’s volunteer day program and sponsorship and participation in environmental community groups.
Social performance indicators

Human rights

HR1 Percentage and total number of significant investment agreements that include human rights clauses or that have undergone human rights screening. PC Our performance–economic.
HR2 Percentage of significant suppliers and contractors that have undergone screening on human rights and actions taken. PC

Our supplier selection guidelines govern all interactions with our suppliers;
Supplier selection guidelines (19kb .pdf).

HR3 Total hours employee training on policies and procedures concerning human rights. PC Code of Ethics.
HR4 Total number of incidents of discrimination and actions taken. GRI
only
Aligned to IAG’s devolved operating model, each of our operating divisions has processes in place and is responsible for the management of incidents.
HR5 Operations identified in which the right to exercise freedom of association and collective bargaining may be at significant risk, and actions taken to support these rights. GRI
only
Freedom of association is protected by the Workplace Relations Act 1996 (in Australia) and the Employment Relations Act 2000 (in New Zealand) which mandate not only that employees are free to join a union but also that they should not suffer detriment because of their membership of a trade union.
IAG’s Code of Ethics specifically refers to the International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work, which includes freedom of association.
In addition, the IAG Enterprise Agreement also contains a number of clauses broadly relevant to the exercise of freedom of association.
HR6 Operations identified as having significant risk for incidents of child labour. NR
only
Over the reporting period IAG had no known incidents of child labour. We operate under the requirements of local legislation in this area.
HR7 Operations identified as having significant risk for incidents of forced or compulsory labour. NR Over the reporting period IAG had no known incidents of forced or compulsory labour. We operate under the requirements of local legislation in this area.

Labour practices and decent work

LA1 Total workforce by employment type, employment contract, and region. C Our performance–workforce.
LA2 Total number and rate of employee turnover by age group, gender, and region. PC Our performance–workforce.
LA3 Benefits provided to full time employees that are not provided to temporary or part time employees. PC Full time and part time employees receive and have access to the same benefits;
our approach–workforce.
LA4 Percentage of employees covered by collective bargaining agreements. GRI
only
In our Australian and New Zealand operations, all employees with the exception of senior management are covered by collective bargaining agreements. In our Asian and UK operations there are no collective bargaining agreements.
LA5 Minimum notice period(s) regarding operational changes, including whether it is specified in collective agreements. GRI
only

Notice periods in the instance of operational change are set out in the Insurance Australia Group Enterprise Agreement (EA) 2003. It provides that for employees with less than 25 years service will receive 8 weeks’ notice of retrenchment (or payment in lieu) while employees who are either over 45 years of age or have over 25 years service will receive 12 weeks’ notice (or payment in lieu).

The IAG EA also contains provisions regarding consultation with employees and/or the Finance Sector Union (FSU) regarding any change program which will impact on employees or on their working arrangements.
LA6 Percentage of total workforce represented in formal joint management worker health and safety committees that help monitor and advise on occupational health and safety programs. PC IAG Charter for Health, Safety and Security (150kb .pdf).
LA7 Rates of injury, occupational diseases, lost days, and absenteeism, and number of work related fatalities by region. C Our performance–workforce.
LA8 Education, training, counseling, prevention, and risk control programs in place to assist workforce members, their families, or community members regarding serious diseases. GRI
only
HIV and AIDS and other communicable diseases are not material risks in our areas of operation. However, we provide a range of services for our staff to mitigate eg RSI and stress. These include EAP, and OH&S training.
LA9 Health and Safety topics covered in formal agreements with trade unions. GRI
only
The IAG Enterprise Agreement (IAG EA) which the Finance Sector Union is a party, contains a specific commitment to a safe workplace (see clause 1.2.5). The IAG EA refers to IAG's Charter for Health, Safety and Security and additional occupational health and safety policies that apply at IAG.
LA10 Average hours of training per year per employee by employee category. GRI
only
We have a wide range of training available to all our employees, and are focused on providing high quality tailored training for our employees rather than a specific quantity of training. As part of the annual performance management processes, specific development plans are determined for each staff member and training requirements are identified at this time.
LA11 Programs for skills management and lifelong learning that support the continued employability of employees and assist them in managing career endings. GRI
only
    IAG offers its employees the following initiatives which are provided for in both the IAG Enterprise Agreement or through policy:
  • external study support;
  • internal training/learning and development programs;
  • career breaks;
  • create retirement seminars for those approaching retirement;
  • retrenchment outplacement services; and
  • severance pay.
LA12 Percentage of employees receiving regular performance and career development reviews. GRI
only
100%. Organisation policy requires all parts of the business and all categories of employees to follow a performance appraisal process.
LA13 Composition of governance bodies and breakdown of employees per category according to gender, age group, minority group membership, and other indicators of diversity. PC Our performance–workforce;
Our approach–workforce.
LA14 Ratio of basic salary of men to women by employee category. C

Our performance–workforce.

Society indicators

SO1 Nature, scope, and effectiveness of any programs and practices that assess and manage the impacts of operations on communities, including entering, operating, and exiting. GRI
only
    In assessing and selecting the location and positioning of our offices we have considered:
  • the location and concentration of IAG members and participating employers;
  • the age and business demographics of the areas being considered; and
  • growth forecasts for the areas.

To minimise the likelihood of exiting a community we have attempted to ensure that our offices have been established in regional cities, have taken long term leases and employed local people to operate the centres.

We do not have any structured programs in place for assessing and managing the impacts of operations on communities.

SO2 Percentage and total number of business units analysed for risks related to corruption. PC

Risk Management & Compliance Committee Charter;
Codes and policies–Code of Conduct;
Security Trading Policy;
Continuous Disclosure Policy.

SO3 Percentage of employees trained in organisation's anti corruption policies and procedures. PC Risk management;
Code of Ethics.
SO4 Actions taken in response to incidents of corruption. PC Code of Ethics.
SO5 Public policy positions and participation in public policy development and lobbying. C

Government submissions;
Stakeholder engagement.

SO6 Total value of financial and in kind contributions to political parties, politicians, and related institutions by country. C Zero. We do not make contributions to political parties or related institutions.
SO7 Total number of legal actions for anti competitive behaviour, anti trust, and monopoly practices and their outcomes. GRI
only
There were no known legal actions for anti competitive behaviour, anti trust, and monopoly practices.
SO8 Monetary value of significant fines and total number of non monetary sanctions for noncompliance with laws and regulations. GRI
only

Our UK operations incurred a fine of 735,000 GBP for a breach of the Financial Services Authority's Business Principles. This related to having loaded incorrect premium rates into the system and the subsequent impacts to customers.

Our Victorian Workers' Compensation operations were fined $1,000,000 for a breach of their agency agreement.

Product responsibility

PR1 Life cycle stages in which health and safety impacts of products and services are assessed. NA Our products do not have any significant direct health and safety issues. Staff involved in the development of products are addressed through our Charter for Health, Safety and Security (150kb .pdf).
PR2 Total number of incidents of non compliance with regulations and voluntary codes concerning health and safety impacts of products and services. GRI
only
There were no known incidents of non compliance with regulations and voluntary codes concerning health and safety impacts of products or services.
PR3 Type of product and service information required by procedures and percentage of significant products and services subject to such information requirements. GRI
only
We comply with the relevant government legislation per the Financial Services Act in all our product labeling. 
PR4 Total number of incidents of non compliance with regulations and voluntary codes concerning product and service information and labeling. GRI
only
Australia: Management reported a “significant breach” to ASIC in January 2009 relating to the failure to provide customers with policy documentation. This breach impacted the approximately 800 customers. All affected customers were contacted and advised that the company was extending the 21 day cooling off period. ASIC has since replied that no further action will be taken.
Australia: The Financial Ombudsman Service (FOS) raised a breach relating to claims denial letters not detailing the entire complaints handling process.
The Business Division involved updated the claims denial letters and processes. The new procedure has been communicated to staff and is operational. FOS was advised of the completion of these actions and has confirmed that this matter has been closed without any fines.
PR5 Practices related to customer satisfaction, including results of surveys measuring customer satisfaction. C Our performance–customer.
PR6 Programs for adherence to laws, standards, and voluntary codes related to marketing. GRI
only
We comply with the relevant government legislation in the countries in which we operate.
PR7 Total number of incidents of non compliance with regulations and voluntary codes concerning marketing communications, including advertising, promotion, and sponsorship. GRI
only
There were no known incidents of non compliance with regulations and voluntary codes concerning marketing communications, including advertising, promotion, and sponsorship.
PR8 Total number of substantiated complaints regarding breaches of customer privacy and losses of customer data. GRI
only
Refer to SO8.
PR9 Monetary value of significant fines for noncompliance with laws and regulations concerning the provision and use of products and services. GRI
only
There were no significant fines for non compliance with laws and regulations concerning the provision and use of products and services.