Aviva Insurance Limited director Ian Edward Clark and Sabre Insurance Company
In reaction to an article in today’s Insurance Business UK, about Aviva and Probitis, I did a quick check on the first three directors listed of Aviva Insurance Limited, the Aviva subsidiary involved, in Companies House.
Aviva inks major deal for Probitas | Insurance Business UK (insurancebusinessmag.com)
Jason Storah is director of Aviva Insurance Limited, according to Companies House (https://find-and-update.company-information.service.gov.uk/company/SC002116/officers).
As part of my due diligence checks I've started to test whether an individual has registered more than one identity in Companies House. By maintaining two or more identities, interests are concealed from auditors, due diligence software, and KYC processes.
I note that whilst Jason Storah and and Christopher John Clark each maintain a unique identity in Companies House, there are several identities registered for co-director, Ian Edward Clark, with date of birth Feb 1960.
The Aviva Insurance Limited appointment is held in an identity with "Total number of appointments 1" (https://find-and-update.company-information.service.gov.uk/officers/SSsbyq712xfthYrjh7dNmX7tsgU/appointments). ie audit software would conclude he has no other interests. However, there is a second identity holding an active appointment to Sabre Insurance Company Limited (https://find-and-update.company-information.service.gov.uk/officers/fdPDmEzJ_dn1_TaLNtBu_xZiXeM/appointments).
A third identity holds a single active appointment to Sabre Insurance Group plc (https://find-and-update.company-information.service.gov.uk/officers/w5d8BwLcxQ-wiVOuWnCuGsG9aU4/appointments). A fourth identity holds a single active appointment to Vigilis (Holding) Limited (https://find-and-update.company-information.service.gov.uk/officers/EM2LF2hfTAP-qiMIMeHEHrYSYYg/appointments). There are 7 insurance related, resigned appointments in a fifth identity (https://find-and-update.company-information.service.gov.uk/officers/waMEZKUBDKhUkhtePqE-Tggd0QU/appointments).
A sixth identity has 3 resigned investment related roles (https://find-and-update.company-information.service.gov.uk/officers/gv14Q4HRsrzA60t5YNvPuUPOGuc/appointments). A 7th identity (https://find-and-update.company-information.service.gov.uk/officers/3dXqMKDa6KzuIFF-ztoBajNLrPI/appointments).
The 8th identity (https://find-and-update.company-information.service.gov.uk/officers/WAjLSlnUQqiM75St-5SI9kGC12U/appointments) includes resigned appointments to Saffron Group companies. This is a group I was looking into yesterday, in relation to the MHRA CEO Dame June Munro Raine who failed to declare she has been a director of Saffron Underwriting Limited, since 2016, until a year ago (https://find-and-update.company-information.service.gov.uk/officers/XyFokkmXDyVTTgWfgictbyC_mI4/appointments). Dame June Munro and Saffron Underwriting is a report I’m presently drafting.
Ian Edward Clark has a 9th identity with a resigned appointment to Deloitte LLP (https://find-and-update.company-information.service.gov.uk/officers/5Lr55Yh1wOdT9EDmJZpKy0P266M/appointments). There is a very small probability that two people with the same three names and date of birth have registered companies in Companies House, the probability drops even further for two people with the same 3 names and date of birth, being involved in the same industry. Therefore on balance of probability there in one Ian Edward Clark, date of birth February 1996, who has varied the attribute "usual residential address" in subsequent registrations gaining multiple “unique identifiers” (I’ve been referring throughout to these being “identities”) in Companies House in order to conceal interests from audit for related party transactions. A person must only have one unique identity to be compliant with Section 1082 of the Companies Act 2006.
I note that Sabre is not disclosed as a related party in the Aviva Annual report and accounts 2022. Failure to disclose related interests is an offence. It is a material misstatements that jeopardises the integrity of Aviva’s reporting.
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