Legal and Regulatory

Registered Office information

Cigna Insurance Services (Europe) Limited. Registered in England and Wales No. 04617110. Registered Office is: c/o Steptoe & Johnson UK LLP, 13th Floor, 5 Aldermanbury Square, London EC2V 7HR.

FirstAssist Insurance Services is a trading style of Cigna Insurance Services (Europe) Limited.

Financial Conduct Authority (FCA) information

Cigna Insurance Services (Europe) Limited is authorised and regulated by the Financial Conduct Authority. Our Financial Services Register number is 310671 and our details including our permitted activities can be checked by visiting the FCA’s website: http://www.fsa.gov.uk/register/home.do or by contacting the FCA on 0800 111 6768.

Insurance underwriters

Insurance products provided by Cigna Insurance Services (Europe) Limited are underwritten by:

Health, Accident, Protection and Travel

CIGNA Life Insurance Company of Europe S.A.-N.V. UK Branch c/o Steptoe & Johnson UK LLP, 13th Floor, 5 Aldermanbury Square, London EC2V 7HR. Registered in Belgium with limited liability (Brussels trade register no. 0421 437 284), Avenue de Cortenbergh 52, 1000 Brussels, Belgium, authorised by the National Bank of Belgium and subject to limited regulation by the Financial Conduct Authority and Prudential Regulation Authority.

CIGNA Europe Insurance Company S.A.-N.V., registered in Belgium with limited liability (Brussels trade register no. 0474624562), Avenue de Cortenbergh 52, 1000 Brussels, Belgium. Subject to the prudential supervision of the National Bank of Belgium, Boulevard de Berlaimont 14, 1000 Brussels (Belgium) and to the supervision of the Financial Services and Markets Authority (FSMA), rue du Congrès 12-14, 1000 Brussels (Belgium), in the field of consumer protection and subject to limited regulation by the Financial Conduct Authority.

Great Lakes Reinsurance (UK) PLC is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority. Financial Services Register number 202715.

Legal Protection

Cigna Legal Protection policies are underwritten by Cigna Europe Insurance Company S.A.-N.V.

CIGNA Europe Insurance Company S.A.-N.V., registered in Belgium with limited liability (Brussels trade register no. 0474624562), Avenue de Cortenbergh 52, 1000 Brussels, Belgium. Subject to the prudential supervision of the National Bank of Belgium, Boulevard de Berlaimont 14, 1000 Brussels (Belgium) and to the supervision of the Financial Services and Markets Authority (FSMA), rue du Congrès 12-14, 1000 Brussels (Belgium), in the field of consumer protection and subject to limited regulation by the Financial Conduct Authority.

With effect from 1st December 2017, underwriting and claims services in respect of all policies underwritten by Cigna Europe Insurance Company S.A.-N.V. will be provided by Abbey Legal Protection, on behalf of Cigna Legal Protection.

Abbey Legal Protection is a trading division of Abbey Protection Group Limited. Registered in England and Wales No. 4959808. VAT No. 245 7363 49. Registered Office: 20 Fenchurch Street, London EC3M 3AZ. Abbey Protection Group Limited is the corporate member of LHS Solicitors LLP. Markel Corporation is the ultimate holding company for Abbey Protection Group Limited.

Creditor

Groupama Insurance Company Limited. Registered in England and Wales No. 995253. Registered Office at Groupama House 6th Floor, One America Square, 17 Crosswall, London EC3N 2LB.

Groupama Insurance Company Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority. Financial Services Register number 202124.

You can check this information on the Financial Services Register by visiting the FCA's website http://www.fsa.gov.uk/register/home.do or by contacting the FCA on 0845 606 9966.

Cigna European Services (UK) Limited – United Kingdom Tax Strategy

Introduction and scope

This statement represents publication for the purposes of Schedule 19 of the United Kingdom Finance Act 2016 (the “Act”). This UK tax strategy has been approved by the Directors of Cigna Life Insurance Company of Europe SA-NV and Cigna Europe Insurance Company SA-NV (the “European Board”) to be published in satisfaction of these requirements, and applies to Cigna European Services (UK) Limited (“CESL”) and all entities listed at Appendix I, hereon referred to as “the Group”1.

This statement and strategy contained within applies from the date of publication until it is superseded.

Tax governance, compliance and risk management in relation to UK taxation

In relation to tax, the Group considers itself to have a low threshold for risk and accordingly places high importance on complying with all statutory obligations, be they tax or regulatory.

The Group manages tax risk as part of its wider internal risk management process, with a view to ensuring that tax returns and reporting are accurate, timely and in compliance with all applicable laws and requirements.

Ultimate responsibility for the Group’s tax strategy lies with the European Board, with executive management of tax delegated to our European Finance Director. Our European Head of Tax2 is responsible for the day-to-day oversight of our tax affairs in the UK and reports directly to the European Finance Director on all significant tax matters, such that tax developments and risks are considered at the European Board level on a case-by-case basis.

Tax risks and the operational effectiveness of controls around tax processes are periodically reviewed and considered by the Board. The European Audit Committee3 meets with the European Board on a quarterly basis, and discusses all significant risks, including tax risks, such that these are monitored on an ongoing basis.

The tax function comprises a team of professionals with the appropriate knowledge, experience and capabilities to manage the Group’s tax affairs and maintain oversight of the tax risks emanating across the group. Our in-house tax team keeps abreast of developments in tax law and practice through attendance at training seminars, and has access to major tax intelligence resources. They also receive regular mailings from professional advisers to ensure developments in the legislative environment are monitored.

From time to time there may be instances where we face uncertainty as to the interpretation and application of certain tax laws, and/or a transaction or activity which may have a material impact on our finance position. In such instances, we consult internally and may seek external advice to ensure our interpretation is appropriate, taking into account both the spirit and the letter of the law, and the underlying commercial position taken by the Group.

We have appropriate guidance in place to support the tax team and all Group tax returns undergo multiple levels of review, including review by the European Head of Tax prior to submission.

Reasonable care is applied in relation to all processes which could materially affect our compliance with our tax obligations. Tax risk is managed in a way such that it does not pose a threat or cause damage to the reputation of the business or impact our financial performance.

Acceptable level of tax risk

It is our desire to achieve certainty in our tax affairs. Effective risk management is paramount to the business and our appetite towards tax risk is aligned with our strategic business objectives. Our ongoing approach to tax risk is based on the principles of reasonable care and materiality. We assess risks on a case by case basis but do not seek to go beyond the spirit of the UK tax rules and seek certainty in our tax positions.

Our focus is on compliance with regulations and the detection and management of tax risks through our procedures and controls. The Group’s tax team is suitably qualified and experienced to make such judgement calls including the need to consult where significant levels of uncertainty are present, be this internally or with professional advisors. As a Group we consider ourselves to have a low threshold for tax risk.

Attitude to tax planning

We conduct our tax affairs in line with our code of ethics, maintaining our reputation as a good corporate citizen, by ensuring our tax analyses and considerations reflect the commercial reality of the business operations.

To maintain competitiveness, where there are opportunities for statutory tax reliefs, as laid out in the UK legislation, we would seek to pursue such tax reliefs in line with the law and the commercial reality. Where applicable, we take advice from professional advisers and HMRC to confirm our interpretation of the law.

This approach is driven by our desire for certainty in our tax affairs and is grounded in our values.

Relationship with HMRC

All dealings with the UK tax authorities are undertaken in a courteous, collaborative and timely manner. Our tax function represents the Group in its interaction with HMRC and their priority is always the integrity of our tax affairs and the maintenance of an open and honest relationship.

Our tax submissions are prepared on a full disclosure basis and while every effort is made to ensure all tax filings are accurate, where errors in submission are identified, we notify HMRC of these promptly and engage fully to rectify the position.

1The European Board has delegated authority for the Group and all other Cigna entities within Europe

2Employee of CESL but responsible for the Group and all other Cigna entities within Europe

3Audit Committee of CLICE/CEIC with delegated authority for the Group

Appendix 1 – Tax Strategy Applicable to following:

UK Limited Companies

Cigna Chestnut Holdings Ltd

Cigna European Services (UK) Ltd

Cigna Global Wellbeing Services Holdings Ltd

Cigna Insurance Services (Europe) Ltd

Cigna Legal Protection Ltd

Cigna Oak Holdings Ltd (dormant)

Cigna Walnut Holdings Ltd

Cigna Global Wellbeing Services Ltd

Cigna Willow Holdings Ltd (dormant)

UK Permanent Establishments of overseas group companies

Cigna Life Insurance Company of Europe SA-NV UK Branch

Cigna Europe Insurance Company SA-NV UK Branch