The Club has always been committed to effective corporate governance as an essential component of a mutual providing insurance and related services to its Members. It is important that the governance process should be transparent and accordingly the Club's Board has set out in a single document and published its Corporate Governance Charter. The Charter is a voluntary code designed to assist the Board in carrying out its responsibilities for conducting the Club's business in accordance with the Constitution and the Rules.

As part of its governance the Club has also established a policy in relation to bribery which gives effect the United Kingdom Bribery Act 2010.

Foreign Account Tax Compliance Act (FATCA)

In order to meets its goal of uncovering U.S. account holders, FATCA imposes reporting requirements on certain non-U.S. entities designed to disclose the identities of those U.S. account holders. Payments of U.S. source fixed income (e.g., coupons, dividends, certain insurance premiums, etc.) to non-U.S. entities that fail to comply with the reporting requirement under FATCA are currently subject to a 30 % U.S. withholding tax.

However, The West of England is treated as a Passive Non-Financial Foreign Entity (“Passive NFFE”) pursuant to FATCA. As a Passive NFFE with no substantial U.S. owners, the Club is exempt from the 30 % withholding tax on payments of U.S. source fixed income. The West of England evidences its FATCA status through the W-8BEN-E form which can be downloaded from the link below.

Please note also that since all insurance related transactions are made through accounts owned and maintained by The West of England, the Club does not issue W-8IMY forms. Therefore, The West of England insurance intermediaries do not receive “reportable or withholdable payments” which is the prerequisite for filling out this form.

Should you have any question relating to FATCA, please contact Olivier Le Bescond at Olivier.LeBescond@westpandi.com.