Before we brief you on our arrangements, it’s important to stress that there are 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’ve set up a subsidiary company in Brussels called William Russell Europe SRL. From 1st January 2021, we’re administering insurance policies through this subsidiary. We’ve established a UK branch of the subsidiary at William Russell House, Lightwater, so there’ll be no operational disruption.
We’ve also set up an association in Brussels for insurance, health, and well-being. Existing policyholders are automatically entitled to membership of this association upon their first renewal date after 1st January 2021. Employees and dependants are also entitled to membership of 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.
There are some exceptions to these arrangements. For policyholders who hold a health plan and who are resident in the UK, we’ve arranged 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 changes 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, Sompo in Hong Kong, and Orient Insurance Company in Egypt.
|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|
The trade deal between the UK and the European Union came into force on 1st January 2021. This article explains what William Russell is doing to remain compliant and to preserve relationships with our insurance partners and brokers.
This article also introduces 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.
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. From 1st January 2021, these freedoms ceased to exist, meaning:
- As a UK company, WRL can no longer 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 don’t want this to change. So, to avoid moving staff to Brussels, we have opened a branch of WRE in the UK. Conveniently, we registered this branch at William Russell House, Lightwater.
The UK branch of WRE has 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 1st January 2021. 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.
What does WRE mean for existing customers?
The changes above apply to all individual and business policyholders with a plan currently insured by Allianz, unless they hold a health plan and are resident in the UK. We’ve 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 will apply: it’s the location of the policyholder that matters.
Whichever arrangement applies, the benefits, scope of coverage, and personal underwritten terms provided by the customer’s existing plan will not be affected.
What does WRE mean for our brokers?
We’re working through all our partners, brokers and intermediaries and we’ll be issuing new terms of business agreements where necessary. If we switch a customer to WRE at their renewal date in 2021, any commissions we pay to the holding broker will come from WRE’s bank accounts. That means brokers may, until the end of 2021, notice:
- commission payments from a WRE bank account for customers who have already renewed onto a plan provided by WRE; and
- commission payments from a WRL bank account for customers yet to renew onto a plan provided by WRE.
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 is becoming the provider will be fully normalised by 01 January 2022, once we’ve renewed 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 will 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 currently define as the ‘Policyholder’ on Certificates of Insurance and plan agreements (the employer for group policies and the policyholder for individual policies) will no longer enter into insurance contracts directly with Allianz.
Instead, those customers will become members of the WRA. As members, those customers (and their dependants and employees) will be insured under the master policy that the WRA has taken out with Allianz. However, members will retain their existing date of entry.
Benefits of the WRA
We’ve been planning an association for a couple of years. Brexit has changed our timelines, so we’ve had to bring things forward.
Brexit is 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 are enrolling 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 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.
How do our customers become members of the association?
For existing customers, we’re introducing the WRA at renewals throughout 2021. Renewal invitations will contain full details of the WRA, including the usual information on changes to the plans.
If customers wish to continue their cover with us, we will automatically enrol them in the WRA. Customers need not do anything different from what they would typically do at renewal.
New customers whose plans start on or after the 1st January 2021 will automatically enrol as members into the WRA.
What about customers with health plans when the policyholder resides in the UK?
Prior to 1st January 2021, we treated our customers who were resident in the UK like anywhere else in the world: the insurer was AWP Health & Life SA, and the insurance intermediary was WRL.
From 1st January 2021, we’re offering policyholders who are resident in the UK with a health plan continuation of their cover with a different insurer: one of the Allianz group’s UK-based insurance companies, AWP P&C SA UK. This means the renewal invitations throughout 2021 will contain details of the new insurer.
The benefits, exclusions, and terms and conditions for these UK policies are the same as those for the WRA’s master policies, with a few technical and legal changes.
What about customers with a life or income protection plan in the UK?
Existing customers with a life or income protection plan will be enrolled in the WRA at their renewal, even if they are resident in the UK.