Norwegian Hull Club constantly monitors the risk of impairment to the organisation’s business model, reputation and financial condition, from a failure to meet laws, regulations, internal standards and policies.
The company operates within a low overall risk range; the lowest risk appetite relates to compliance where the risk level is set to a minimum. The risk tolerance level regarding HSE issues is zero.
This is a new US law established to prevent tax avoidance by US tax payers and will come into effect from the 1st July 2014.
The legislation impacts Insurance and Reinsurance premium payments for US-sourced business and requires all non-US carriers which underwrite such business to demonstrate their compliance with the law. Failure to do so will result in 30% of the premium having to be withheld by way of a Withholding Tax. Compliance can be demonstrated by completion and submission of the W-8 BEN-E form.
According to EIOPAs "Guidelines on Complaints-Handling by Insurance undertakings" published 16th of November (EIOPA-BoS-12/069) and directive "Retningslinjer for forsikringsselskapers interne klagebehandling" published by The Financial Supervisory Authority of Norway (Rundskriv 4/2013), all insurance companies are to have in place a well functioning complaints handling process and they are also obliged to make this information public.
A complaint is a formal document in writing from the assured to the insurer that expresses dissatisfaction associated with the insurance policy or services delivered. The complaint is to set out the facts and reasons that the filing party or parties believes are sufficient to support the complaint. Complaints handling do not involve regular claims-handling or cases referred to an adjuster for his opinion or subject to legal proceedings by way of arbitration or before any court in Norway or any other country. Nor does complaints handling involve request for execution of the insurance contract, information or clarification.
The Compliance Officer is responsible for the complaints-handling process within Norwegian Hull Club and all complaints are to be directed, in writing, to the following email address: compliance@norclub.com
All complaints received by the Compliance Officer are to be investigated fairly and possible conflicts of interest to be identified and mitigated. The Compliance Officer is also responsible for issuing a receipt for received complaints including an indicative handling timeline. The Compliance Officer is also responsible for communicating with the complainant, in a clear and accurate manner and also communicates the outcome of the complaint-handling process.
The Compliance Officer is to analyze, on an on-going basis, complaints-handling data to ensure that we identify and address any recurring or systematic problems, and potential legal and operational risk, for example, by:
The Code of Conduct defines the professional ethical standards that apply to all employees of Norwegian Hull Club and its subsidiaries. It helps to inspire and build confidence in the company, its people, products and services, both internally and externally among – for example - clients and supervisory authorities, as well as day-to-day business contacts.
Norwegian Hull Club’s mission is to secure lives, health, environment and property to help protect both people and the planet. As such, The Club require its business partners and suppliers;
Suppliers and business partners;
Any violation of this clause may jeopardize the business relationship with Norwegian Hull Club, including termination of this instruction.
Norwegian Hull Club - Transparency Act 2024 Report
Transparency Act relates to companies' transparency and work on fundamental human rights and decent working conditions.
The Act shall promote companies' respect for fundamental human rights and decent working conditions in connection with the provision of services and ensure that the general public's has access to information regarding how companies address negative impacts on fundamental human rights and decent working conditions. The Act came into force on July 1, 2022.
The new act obligates companies to conduct due-diligence into human rights and decent working conditions and follow-ups throughout their supply chain and business relationships. Due diligence shall be carried out in proportion to the size and nature of the company, the context of its operations, and the severity and probability of adverse impacts on fundamental human rights and decent working conditions.
Norwegian Hull Cub has implemented new internal policies and guidelines regarding the Transparency Act. The Club has identified and assessed actual and potential negative impacts through our own operations and also our value chains and business partners' operations and several mitigants have been identified.
The Club's Transparency Act report is available in our latest, published Annual Report.
Norwegian Hull Club is committed to user privacy and ensures your personal data is handled lawfully, fairly, and transparently.
This Privacy Notice explains situations in which Norwegian Hull Club processes personal data as a data controller. The following sections outline the types of personal data collected and processed, the purposes and methods of processing, and an overview of applicable data protection rights.
Personal data refers to information connected to an identifiable individual (the data subject), either directly or indirectly. The collection of personal data is required to provide agreed-upon insurance services to clients and members.
Processing of personal data includes operations such as collection, recording, storage, usage, disclosure by transmission, dissemination or other forms of making data available, as well as erasure or destruction.
Contact
NHC ensures the protection of your personal data in full compliance with the General Data Protection Regulation (GDPR), as well as relevant UK and Norwegian data protection laws.
As the designated data controller, NHC may be reached via email at: mail@norclub.com or by mail at:
Norwegian Hull Club – Gjensidig Assuranseforening
Solheimsgaten 5
5058 Bergen
Norway
For any enquiries regarding our processing of your personal data, or assistance in exercising your rights, you are welcome to contact NHC’s Data Protection Officer (DPO). The DPO is bound by a duty of confidentiality.
Contact details for the DPO:
Birger Christian Kindt
Compliance Officer
Office: +47 55 55 95 27
Mobile: +47 476 86 490
E-mail: dpo@norclub.com
Collection of Data and Legal Basis for Processing
NHC collects and processes various categories of personal information that you provide directly or via your use of our website and Managed Websites. Below, we outline the types of personal data collected, the purposes for which it is used, and the corresponding legal grounds for its processing.
The personal data pertains to employees, clients, brokers, surveyors, lawyers, service providers, additional business partners, and other relevant individuals.
We process the following categories of data:
Transfer of personal data
As a standard practice, NHC processes personal data predominantly within the EU/EEA. However, as an international marine insurance provider, there are instances where the transfer of personal data outside the EU/EEA is necessary to support our operational requirements.
Personal data may be transferred outside the EU/EEA in the following circumstances:
To ensure an adequate level of protection during the transfer of personal data, a Transfer Impact Assessment (TIA) will be conducted, and Standard Contractual Clauses (SCC), adopted by the European Commission, will be implemented. The SCC is designed to ensure that your personal information receives an adequate and consistent level of protection.
All personal data processed within the NHC Group is treated as confidential and accessible only to authorized staff who require the information to fulfill their professional responsibilities.
Internal email transmissions within NHC are encrypted by default. In certain cases, emails containing health information may be sent externally to correspondents, crew agencies, legal representatives, or brokers as part of claims handling procedures; these communications are also encrypted to ensure confidentiality.
Use of Cookies
Cookies are small pieces of data sent from a website and stored in a user's web browser, enhancing the performance of our website and providing better user experience. NHC currently uses cookies for the following purposes:
When you visit norclub.com, our website uses necessary cookies that are essential for our website to function properly. These necessary cookies enable basic features, such as being able to access different pages of our website. However, some cookies are so-called 'non-essential cookies'. These cookies are not necessary for our website to work, they rather help us better understand how visitors interact with our website. We can only use these non-essential cookies if you give us your consent. If you choose not to consent, your data will not be collected or analysed for such purposes.
The use of cookies is regulated by Section 3-15 of the Electronic Communications Act."
The following cookies will be stored on your device for these purposes:
If you consent, optional cookies will be stored until you withdraw your consent. Optional cookies will in any case be automatically deleted after 90 days if you have not visited our websites during this period.
How to opt out of non-essential cookies
You can easily opt out of the use of non-essential cookies after giving consent, by changing the security settings in your browser. The following links give guidance on how to change your settings for the most popular browsers:
Your rights
You have several rights, and it is important that you are aware of them. Below you will find an overview of your rights.
Whether you want to access your data, or if you believe we have incorrect information stored about you and you wish to correct your data, we are obliged to respond to your request within one month after receiving it.
In the event of a delay from our side, we will inform you within one month (after receiving your request) that the response will be delayed and explain the reason for the delay. We are then obliged to provide a final response within three months of receiving your initial request.
The right of access
You have the right to know if we process your personal data, including the right to access or obtain a copy of it. Additionally, you are entitled to detailed information about the personal data we collect and how it is being processed.
The right to rectification
You have the right to request that your personal data is corrected or supplemented with additional information if you believe that the personal data we process is inaccurate or misleading. To do so, you must demonstrate the inaccuracy of the data and provide us with the correct information. Once we receive your request, we will correct the inaccurate data promptly.
The right to erasure/be forgotten
In certain situations, you have the right to request the deletion of personal data we process about you.
Deleting the information is necessary to comply with a legal obligation we are bound by.
However, there are instances where we are obligated to retain your data, even if you request its deletion. This includes during the course of the customer relationship with your employer and for a period after it ends, as required by law or to protect our legitimate interests. For example, we may need to retain your data to meet legal obligations, safeguard our legitimate interests, or establish, exercise, or defend legal claims.
The right to restrict processing
You have the right to request that we limit how we process your personal data. This means your data will not be actively used during the restriction period. This right often works alongside other rights, such as when you request the correction or deletion of your personal data
The right to data portability
Individuals may request access to certain personal data held about them, with the ability to transfer this information securely to other systems or services. The data will be supplied in a standardized, machine-readable format to facilitate its migration to a different service provider. This right, known as "data portability," applies exclusively to:
The right to object
Under certain conditions, you may request that we discontinue processing your personal data. We are committed to assessing and responding to such requests. If your personal data is processed because it is necessary to fulfill a legitimate interest, you have the right to object based on your specific situation. We assess such objections on a case-by-case basis and may deny them if there are prevailing reasons to continue processing your data.
Complaints
You also have the right to contact the Norwegian Data Protection Authority (Datatilsynet) or the Information Commissioner’s Office in UK. They are the supervisory authority responsible for ensuring compliance with data protection regulations in Norway. For more information on how to submit a complaint, you can visit their website at:
The material and information contained in this website is provided without warranties of any kind. Norwegian Hull Club accepts no responsibility for any loss whatsoever, direct or consequential, arising out of or in connection with the use of this website.
This website also contains information supplied by third parties, and provides links to other websites. Norwegian Hull Club does not guarantee the accuracy of such information, and do not accept any liability or responsibility which might arise as a consequence of relying upon it.
The whistleblowing service for Norwegian Hull Club - Gjensidig Assuranseforening (NHC) is managed by KPMG on behalf of NHC. The service ensures secure and confidential treatment of electronic whistleblower reports and is open for employees and any external stakeholders.
You can report any censurable conditions and any matters, hereunder the Working Environment Act, The Anti-Money Laundering Act, the Norwegian Transparency Act and sanctions, regulations. Any questions regarding Norwegian Hull Club and the Transparency Act can also be directed through the contact form on The Club’s contact pages.
You may choose to report anonymously. No matter how you choose to report, be assured that your report will be handled with confidentiality and professionalism. Thank you for helping us in maintaining the integrity and ethical standards of Norwegian Hull Club.
Norwegian Hull Club's Code of Conduct and Supplier Code of Conduct reflect our commitment to ethical business practices. Employees must report any unethical practices rapidly. Likewise, The Club encourages external stakeholders to disclose any unethical, illegal, damaging, or harmful behavior addressing NHC or its suppliers and partners.
Link to KPMG managed reporting service