Regulation
As a specialist insurer for companies within the international transport and logistics sector we set great store by equity between Members and probity when dealing on their behalf. In support of our commitment to maintaining the highest possible standards of business practice we hold a 'zero-tolerance' stance towards bribery. Bribery is illegal and as such has no place in our organisation.
TT Club Policy
In accordance with the UK Bribery Act 2010, TT Club prohibits absolutely:
- the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement, regardless of size;
- to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company;
- by any individual employee, agent or other person or body acting on behalf of TT Club;
- in order to gain any commercial, contractual or regulatory advantage for TT Club in a way which is illegal or unethical;
- or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.
Interpreting the Policy
It is not the intention of the policy, particularly in relation to our international role as an insurer, to prevent normal and appropriate hospitality or the giving and receiving of ceremonial gifts. Such hospitality or gifts must, however, be in moderation and not place any expectation on the recipient to reciprocate either in like or by performing, or failing to perform, any other task in return.
If there is any doubt as to whether an action might constitute bribery the matter should be referred to Mark Argentieri, the Chief Operating Officer at london@ttclub.com.
Preventing and reporting Bribery
All management staff working on behalf of the TT Club have a responsibility to prevent, detect and report bribery. We provide appropriate guidance to our staff in fulfilling this duty.
Should you hold any suspicion of bribery or attempted bribery committed by or against an employee, agent or other party acting on behalf of the TT Club, it must be reported immediately to Mark Argentieri, the Chief Operating Officer at london@ttclub.com.
Complaints Procedure
As a mutual insurer we aim at the highest standards of service - and fairness - towards Members and brokers. If you have a complaint, or any other comment, about the maintenance of these standards by the Club, or by anyone acting on behalf of the Club, we ask that you let us know immediately. This will allow us both to resolve the issue which you raise and to take action to improve our service to other Members and brokers in the future.
We are regulated by the UK Financial Conduct Authority (FCA). We will deal with complaints from eligible complainants according to the requirements of the FCA. These include timescales for acknowledgement and response and an obligation to advise the complainant on further action if he or she remains dissatisfied. The notified person for resolving these complaints is the Chief Operating Officer of the TT Club Managers and complaints may be addressed direct to him at mark.argentieri@thomasmiller.com or through your usual Club contact.
We will deal with complaints other than from eligible complainants for the purposes of the FCA as far as practicable as if they were from eligible complainants.
Financial Ombudsman Service
If you are dissatisfied with the final response we send you, you may refer your complaint to the Financial Ombudsman Service. You may also refer your complaint to the Financial Ombudsman Service if we have not sent you a final response within eight weeks. The Financial Ombudsman Service will write to us requesting a summary of the matter, and will liaise directly with us in resolving your complaint. If the Financial Ombudsman Service makes a determination that they will take up your case, the matter will be decided by them following a thorough investigation.
Further details of the Financial Ombudsman Scheme are available from the Financial Ombudsman Service.
Contact details
Financial Ombudsman Service
The Financial Ombudsman Service
Exchange Tower
London E14 9SR
0800 023 4 567
Website: www.financial-ombudsman.org.uk
Regulation
Through Transport Mutual Insurance Association Limited and TT Club Mutual Insurance Limited, trading as the TT Club. TT Club Mutual Insurance Limited is authorised in the UK by the Prudential Regulation Authority and regulated in the UK by the Financial Conduct Authority and Prudential Regulation Authority. In Bermuda, Through Transport Mutual Insurance Association Limited is authorised and regulated by the Bermuda Monetary Authority. Through Transport Mutual Insurance Association Limited and TT Club Mutual Insurance Limited are eligible surplus lines insurers in all US jurisdictions. For prospective members in the US, coverage is available through licensed surplus lines brokers.
Listed below are the states where TT Club Mutual Insurance Limited (NAIC number AA-1124127) has been granted surplus lines eligibility, and the date when the licence was granted.
| Alabama - 1 January 2004 | Alaska - 10 December 2004 | Arizona - 13 April 2004 |
| Arkansas - 1 January 2004 | California - 20 February 2008 | Colorado - 1 July 2004 |
| Connecticut - 17 October 2006 | Delaware - 1 January 2004 | District of Columbia -1 January 2004 |
| Florida - 29 September 2005 | Georgia - 1 January 2004 | Hawaii - 1 January 2004 |
| Idaho - 13 October 2004 | Illinois - 1 January 2004 | Indiana - 1 January 2004 |
| Iowa - 1 January 2004 | Kansas - 1 January 2004 | Kentucky - 1 January 2004 |
| Louisiana - 13 April 2007 | Maine - 31 January 2005 | Maryland - 1 January 2004 |
| Massachusetts - 28 January 2011 | Michigan - 15 December 2005 | Minnesota - 17 February 2004 |
| Mississippi - 26 July 2004 | Missouri - 1 January 2004 | Montana - 30 November 2004 |
| Nebraska - 1 January 2004 | Nevada - 4 October 2005 | New Hampshire - 21 July 2011 |
| New Jersey - 7 February 2005 | New Mexico - 1 January 2004 | New York - 6 August 2005 |
| North Carolina - 16 May 2005 | North Dakota - 1 November 2004 | Ohio - 1 January 2004 |
| Oklahoma - 16 February 2005 | Oregon - 1 January 2004 | Pennsylvania - 9 December 2004 |
| Puerto Rico - 28 October 2005 | Rhode Island - 22 September 2006 | South Carolina - 13 December 2004 |
| South Dakota - 1 January 2004 | Tennessee - 13 November 2006 | Texas - 1 December 2004 |
| Utah - 23 August 2004 | Vermont - 19 July 2006 | Virginia - 22 November 2004 |
| Virgin Islands - 23 September 2004 | Washington - 1 January 2004 | West Virginia - 23 July 2004 |
| Wisconsin - 1 January 2004 | Wyoming - 1 January 2004 |
Through Transport Mutual Insurance Association Limited (NAIC number AA-3191044) has surplus lines eligibility in all US States and jurisdictions in accordance with The Dodd–Frank Wall Street Reform and Consumer Protection Act, effective July 21, 2011.
In Hong Kong, TT Club Mutual Insurance Limited is regulated by the Hong Kong Insurance Authority, in Singapore by the Monetary Authority of Singapore and in Australia by the Australian Prudential Regulation Authority.