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Before we explain our arrangements for post-Brexit Britain, it’s important to stress that there have been no changes to our UK staffing levels, the benefits or coverage provided by our insurance plans, or our member experience. Our relationship with Allianz continues, and there are no changes to our relationships with our assistance service and regional insurance partners.
We set up a subsidiary company in Brussels called William Russell Europe SRL. Since 01 January 2021, we’ve adminstered insurance policies through this subsidiary. We also established a UK branch of the subsidiary at William Russell House, Lightwater, to avoid operational disruptions.
Finally, we set up an association in Brussels for insurance, health, and well-being. Existing policyholders were automatically enrolled into this association upon their first renewal date after 01 January 2021. Employees and dependants were also enrolled into the association, along with new customers purchasing one of our insurance plans.
The insurer of the plans remains AWP Health & Life SA, an Allianz company with an AA financial strength rating from Standard & Poor’s (as of July 2022).
There are some exceptions to these arrangements. For policyholders who hold a health plan and who are resident in the UK, we arrange insurance cover with AWP P&C SA UK, a UK-based insurance company in the Allianz group. Again, this change has no effect on the benefits and coverage that the plans provide.
Further, these arrangements do not apply to customers whose plans are insured by our regional insurance partners located outside the EU: Dubai Insurance Company in the UAE, Lippo Insurance in Indonesia, and Orient Insurance Company in Egypt.
Glossary
| WRA | – The William Russell Association for Health, Financial Protection, and Well-Being |
| WRL | – William Russell Limited |
| WRE | – William Russell Europe SRL |
| FCA | – The UK Financial Conduct Authority |
| TPR | – The FCA’s Temporary Permissions Regime |
| FSMA | – The Belgian Financial Services & Markets Authority WRA The William Russell Association |
| EEA | – European Economic Area |
Introduction
The trade deal between the UK and the European Union came into force on 01 January 2021. This article explains what William Russell has done to remain compliant and to preserve relationships with our insurance partners and brokers.
This article also explains the William Russell Association for Health, Financial Protection, and Well-Being, what it does, and how it affects our customers.
WRL, a company incorporated in the UK, acts as an insurance intermediary for AWP Health & Life SA, an Allianz insurer incorporated in France.
Before Brexit, our relationship with Allianz was made possible thanks to the freedom of services afforded by the UK and France’s shared membership of the EU. Since 01 January 2021, these freedoms have not existed for British companies, meaning:
- As a UK company, WRL cannot sell policies to residents or businesses in the EU
- As a French insurer, Allianz cannot insure policies administered by WRL, a UK company
Our company in Belgium
We want to preserve and grow both our business in Europe and our relationship with Allianz, so we needed to incorporate a company in an EU member state.
In September 2019, we incorporated WRE in Belgium as a wholly-owned subsidiary of WRL. We received authorisation from the FSMA a few weeks later. WRE is now authorised as a Mandated Underwriter (the Belgian equivalent of a Managing General Agent).
We chose Brussels, Belgium for three reasons:
- Its geographical proximity and transport links to the UK
- Its growing international community, including the European outpost of Lloyd’s of London
- The FSMA is taking a pragmatic view on companies like WRL that are dealing with the fallout of Brexit
WRE has a UK branch
Most of our staff members work at William Russell House, Lightwater, and we didn’t want this to change. So, to avoid moving staff to Brussels, we opened a branch of WRE in the UK. Conveniently, we registered this branch at William Russell House, Lightwater.
The UK branch of WRE entered an arrangement called the TPR that has been set up by the FCA. The TPR allows EU financial services firms to carry out regulated activities in the UK after 01 January 2021, pending full authorisation. Most broker and customer-facing services (e.g., policy services, claims) that we used to carry out as WRL we now carry out as the UK branch of WRE. In January 2023, the UK branch of WRE received full authorisation by the FCA.
What does WRE mean for existing customers?
The changes above apply to all individual and business policyholders with a plan insured by Allianz, unless they hold a health plan and are resident in the UK. We arranged insurance cover with a UK-based insurer in the Allianz group for policyholders with a health plan who are resident in the UK.
The location of employees and dependants of policyholders is not relevant for determining which arrangement applies: it’s the location of the policyholder that matters. And whichever arrangement applies, the benefits, scope of coverage, and personal underwritten terms provided by the customer’s existing plan are unaffected.
What does WRE mean for our brokers?
As of February 2023, we have worked through all our partners, brokers, and intermediaries and we have issued new terms of business agreements where necessary. When we switched a customer to WRE at their renewal date in 2021, any commissions we pay to the holding broker would henceforth come from WRE’s bank accounts.
WRL remains the provider for customers resident in the UK, so commission payments for these customers will continue from the regular WRL bank account for 2021 and beyond. The situation for customers for whom WRE became the provider was fully normalised as of 01 January 2022 (once we were able to renew all of our customers in 2021).
Introducing our members’ association
An association is a group of people who come together under a common goal. The common goal can be anything from people forming a local sports association or a group of people working for a charitable association. Insurance providers can use associations to organise insurance cover for a group of members.
Our association is called the William Russell Association for Health, Financial Protection, and Well-Being, or WRA for short.
It’s important to note that the WRA does not insure our products. The WRA is a free-to-join and not-for-profit organisation, set up solely for the benefit of its members. The WRA is the policyholder of the collective, ‘master’ policies issued by the insurer (AWP Health & Life SA, or to keep things simple—Allianz).
The WRA holds the master policies with Allianz. Customers that we define as the ‘Policyholder’ on Certificates of Insurance and plan agreements (the employer for group policies and the policyholder for individual policies) no longer enter into insurance contracts directly with Allianz.
Rather, those customers are members of the WRA. As members, those customers (and their dependants and employees) are insured under the master policy that the WRA has taken out with Allianz. However, members retain their existing date of entry.
Benefits of the WRA
We were planning for an association for a couple of years before 2019, but Brexit accelerated our timelines.
Brexit has been a complex political, cultural, and economic exercise. It has made things extremely difficult for many British companies, and we are certainly not the only British insurance intermediary who has formed a company in Belgium or another EU member state.
That said, forming an association does have clear advantages:
- Community of people
Our customers have enrolled as members of an association, which is a community of people rather than a corporate entity - No grey areas
We can offer products and services to potential new members, including some increased scope to insure local nationals in countries where barriers have traditionally existed. - Altruistic goals
The WRA has altruistic goals and exists solely for the benefit of its members: a real point of difference against our direct competitors - Setting strong foundations
There is no change to our products, services, insurance partners, internal teams, or commitments to data protection, member experience, and developmental roadmaps
Anything else to know about the WRA?
The WRA is not a subsidiary or a department of WRL or WRE. It’s an entirely independent, not-for-profit organisation, and it has a duty to act in the interest of its members. If there is any conflict between the interests of the WRA’s members and any other party, such as WRE or Allianz, then the WRA’s directors have a legal obligation to act in the interest of its members.
The WRA does not involve itself in arranging cover for its members or providing policy administration services. It does not offer insurance advice, nor does it assist with claims. WRE and WRL handles all of the above activities.
However, membership of the WRA allows the member to become insured under the master policies the WRA takes out with Allianz in its own name.
The WRA has a defined purpose, which appears in the foundational documents for the association and which also appears in the plan agreements.
