Questions & Answers
What are you proposing?
We’re proposing to transfer a number of policies provided by Aviva Life & Pensions UK Limited to Friends First Life Assurance Company Designated Activity Company (dac) on 29 March 2019. We’ll also rename Friends First Life Assurance Company dac as Aviva Life & Pensions Ireland dac on or about 29 March 2019 and we’ll also change its registered office address to One Park Place, Hatch Street, Dublin 2, Ireland.
The transferring policies are currently either written through the Irish, French or Belgian branches of Aviva Life & Pensions UK Limited or are policies underwritten by Aviva Life & Pensions UK Limited which were marketed to policyholders elsewhere in the EU/EEA.
You can find more information about this in the Scheme Summary and Scheme Document in our document library.
Why are you doing this?
We’re preparing for anticipated changes in the law which applies to Aviva as a result of the UK’s expected withdrawal from the European Union. Companies based in the UK, including Aviva Life & Pensions UK Limited, may lose the right to carry out business in other EU/EEA countries in the same ways as they do now. This means that we may be unable to administer your policy in the same way. Friends First Life Assurance Company dac is incorporated in the Republic of Ireland, a country within the European Union, and will be able to operate your policy. Friends First Life Assurance Company dac will be renamed Aviva Life & Pensions Ireland dac on or about 29 March 2019.
We want to provide certainty for customers who may be affected by these changes.
Which policies are transferring?
We’re proposing to transfer the following policies:
- all policies issued by Aviva Life & Pensions UK Limited’s branches in the Republic of Ireland, France and Belgium; and
- certain other policies issued by Aviva Life & Pensions UK Limited and which were marketed to policyholders outside the United Kingdom.
How many policies are transferring?
There will be about 440,000 policies transferring to Friends First Life Assurance Company dac.
Do I have a vote on the transfer?
The transfer is subject to the approval of the court. It is not open to a vote of policyholders, shareholders of Aviva plc or anyone else with an interest.
However, anyone who believes they may be negatively affected by the transfer can object or express their views to the court.
Does this mean you’re forming a new company?
No. The policies affected by the proposals will be transferred from Aviva Life & Pensions UK Limited to Friends First Life Assurance Company dac which is an existing company within the Aviva group of companies. More on this company.
Where can I find out more information about the new company my policy will be transferring to?
Aviva announced its proposal to acquire Friends First Life Assurance Company dac in November 2017 and the transaction was completed on 31 May 2018. Friends First Life Assurance Company dac will change its name to Aviva Life & Pensions Ireland dac on or about 29 March 2019. You can find out about Friends First Life Assurance Company dac here.
You recently transferred my policy from Aviva Life & Pensions Ireland Limited to Aviva Life & Pensions UK Limited. Are you now transferring it back to the same company?
We transferred your Aviva Life & Pensions Ireland Limited policy to Aviva Life & Pensions UK Limited in January 2015 as part of a restructure of our business. Because of anticipated changes in the law as a result of the UK’s expected withdrawal from the European Union, we now need to transfer some of our policies out of the UK company and into another Aviva company which is incorporated in the Republic of Ireland and able to continue to operate your policy.
Aviva announced its proposal to acquire Friends First Life Assurance Company dac in November 2017 and the transaction was completed on 31 May 2018. Friends First Life Assurance Company dac will be renamed as Aviva Life & Pensions Ireland dac on or about 29 March 2019. This is a different company to Aviva Life & Pensions Ireland Limited which previously provided your policy.
Where can I find more information about your proposal?
You can find all the information relating to our proposals in the document library. This includes copies of the documents that we’ll provide to the court which you can download. For any questions about your policy, please call your usual number.
How will my interests as a policyholder or claimant be protected under the transfer?
Your interests are being protected by a rigorous approval process which includes a detailed review by an Independent Expert, whose appointment has been approved by the Prudential Regulation Authority in consultation with the Financial Conduct Authority, to review the effect on policyholders.
The Prudential Regulatory Authority and the Financial Conduct Authority have also been consulted and have been given the opportunity to raise objections. In addition, we are writing to you to make you aware of our proposals and to give you the opportunity to object if you believe you may be negatively affected by them. This is because the Independent Expert will not be able to review the position of each policyholder, so if you have any questions or think you will be negatively affected by the scheme it is important that you contact us and consider whether you want to make an objection.
The court will consider the proposal and will only approve the changes if they’re satisfied they are appropriate, including whether policyholders may be negatively affected. The court will take into account the views of the policyholders, the Independent Expert, the Prudential Regulation Authority and the Financial Conduct Authority.
Who’s the Independent Expert and what makes him independent?
Tim Roff is a Fellow of the Institute and Faculty of Actuaries (IFoA) and has over 30 years' experience in the life insurance industry. He’s a Partner and Head of Actuarial and Risk Services at Grant Thornton UK LLP. Before this he held senior roles as Head of Global Actuarial Services at KPMG and Ernst & Young and Head of Financial Reporting at Tillinghast (now Willis Towers Watson).
We appointed Mr Roff after he was approved by the Prudential Regulation Authority in consultation with the Financial Conduct Authority. His role is to report to the court on the effect of the proposed transfer on policyholders. While we will pay him a fee, he has no duty to us and as a Fellow of the IFoA he has a professional obligation to stay fully independent.
Mr Roff formed his opinion using his experience and his duty is to the court.
Why are you telling me about this now?
To make sure you’re protected, we must follow a set process before the transfer can take effect and the process is quite lengthy. This process includes:
- giving you (as a policyholder or claimant) notice of the transfer;
- making you aware that you can object to the transfer and put your objection directly to the court if you believe you’ll be negatively affected by the transfer;
- a detailed review by an Independent Expert; consulting our industry regulators in the UK and Ireland; and
- approval by the court in London.
What happens if the UK decides not to withdraw from the EU?
The UK Government has indicated its intention to leave the EU and on that basis, we’ll proceed with the proposed transfer so that we’re not dependent on a political outcome.
I'm not a policyholder, why have you written to me?
We’re writing to all policyholders, as required by the court, to tell them about our proposal and to outline the process we are following. The definition of a ’policyholder‘ includes:
- policyholders, trustees, assignees, and attorneys under a power of attorney, of a policy; and
- claimants, such as an employee under an employer’s policy.
Why have you sent me several letters about the same thing?
You may receive more than one letter if you have more than one policy or claim with us. Aviva is also proposing a separate transfer of certain general insurance policies from another Aviva company in the UK to another Aviva company in Ireland, so you may receive a letter about this if you have a product with that company as well.
I’ve received more than one letter with different phone numbers. Why?
We have different customer teams for different types of policy. To make sure you speak to the right team, the phone number on each letter is the one which is right for that particular policy.
I have opted out of receiving marketing/direct mail. Why have you ignored my request?
Legally we have to contact you about our proposal so that you have an opportunity to ask questions or object.