Remote working

Key definitions

Remote worker: An employee of the coverholder carrying out roles outlined within the contract of delegation working away from a Lloyd’s approved coverholder office.

Why guidance is needed

With the development of technology and modern working practices, there is an increase in companies employing staff who work remotely, often from home via remote internet connections or other locations such as coworking spaces. While Lloyd’s supports remote working as an attractive option for employees, where it is suitable, these arrangements can involve certain risks if not appropriately implemented, which includes but is not limited to:

• Regulatory breaches
• Licencing breaches
• Customer detriment
• Breach of data security
• Improper sub-delegation

Lloyd’s requirements

When remote working is permitted, managing agents must ensure that appropriate controls are in place to mitigate the risk of individuals acting outside the scope of the authority granted under the contract of delegation. 

This must include:

• All key personnel be directly employed by the coverholder. Where individuals are employed by a holding company or engaged as contractors, the managing agent must be satisfied that robust contractual arrangements exist to ensure effective oversight and accountability.
• If located in a different territory (i.e., state, province, or country), the remote worker must have the necessary regulatory permissions to carry out their activities for the coverholder.  Those permissions must be consistent with Lloyd’s licences in the territory. Attention to this requirement is particularly important in federated regions such as the United States, Canada, Australia, and the European Union, where it is more common that individuals may reside in a different state, province, or territory from the coverholder they are employed by.
• The employee must not undertake any roles from the remote location without individual authority.
• The IT systems used must be the same as and linked to the approved office systems.
• Documents must not be signed outside of the coverholder’s centralised system or issued from the remote address.
• Insurance documents must not feature the remote address.
• No premiums should be paid to the remote address; payments must only be directed to the bank account of the coverholder
• The employee must not handle or account for insurer monies from the remote location. This relates to cash transactions only. Employees are allowed to access the coverholder’s electronic accounting systems.
• The address of the remote worker's location must not be advertised as the coverholder’s business workplace and must not appear on any of the coverholder’s business correspondence or websites.

Coverholders are required to declare to Managing Agents if any of their staff are remote workers.

Lloyd’s expectations for managing agent oversight

Managing agents are expected to assess the risks involved prior to authorising remote working arrangements of their coverholders and to ensure that the location of the remote worker does not require approval as a branch or trigger any risk location and/or Regulatory requirements, as set out in Crystal+. It is also expected that managing agents apply appropriate controls to remote workers, this may include obtaining an independent legal opinion.

Further information on the coverholder branch approval process is available on our New Branch Applications webpage.

Lloyd’s no longer requires the completion of a remote worker form. 

Other contractual considerations

Managing agents may however want to stipulate remote workers clearly in the contract of delegation.