Direct Line POLITICAL

Corporate Communications & Public Stance

No public evidence identified of any statement by Direct Line Insurance Group, its board, or its executives specifically addressing the Israel-Palestine conflict, the war in Gaza, or related boycott/divestment debates, in the company’s own disclosed communications record reviewed for this audit.^{1, 2} The company’s most recent disclosed public-facing community communications, its 2024 charity-partnership announcement, name only four UK domestic causes - Parenting Mental Health, Race Equality Matters, Spear, and The Diversity Trust - accompanied by a £50,000 community-fund donation, with no reference to international or conflict-related causes of any kind.² On comparative silence, the only identifiable public commentary from within the Direct Line/Aviva corporate family on any active 2024–2026 conflict is market-risk commentary from Aviva group chief executive Amanda Blanc about the Israel-Iran war’s potential effect on motor-claims costs, delivered on 5 March 2026, in which she explicitly drew a comparison to the inflationary effect of Russia’s 2022 invasion of Ukraine on vehicle-parts and repair costs; this statement addressed claims-cost risk management only and contained no reference to civilian harm, human rights, or the political dimensions of either conflict.³ Market framing: Direct Line’s own public disclosures frame its operations and growth purely in UK personal- and commercial-lines insurance terms - motor, home, and related product lines sold directly and via price-comparison channels - with no disclosed unique geopolitical partnerships or Middle East-linked market description found in the company record reviewed.^{1, 4}

Operations in Occupied or Contested Territories

Direct Line Insurance Group’s disclosed geographic scope of operations is the United Kingdom; its prior international operations in Italy and Germany were sold to Mapfre in 2014, and no public evidence identified of any current or former Direct Line operations, equipment sales, service contracts, dealership networks, or subsidiary activity in Israel, the Occupied Palestinian Territories, or Israeli settlements.^{1, 4} Direct Line, Churchill, Privilege, and Green Flag do not appear in the United Nations OHCHR database of business enterprises involved in settlement-related activity; the most recent (2025) update of that database lists 158 companies from 11 countries after review of 215 submissions, screened under the UN Guiding Principles on Business and Human Rights for activity such as supplying construction materials, supporting demolitions, surveillance, and natural-resource exploitation in the settlements, and the reporting on that update names no insurance company and no Direct Line brand.⁵ no public evidence identified of any organized boycott, divestment, or sanctions campaign naming Direct Line, Churchill, Privilege, or Green Flag as a target on Israel-Palestine grounds, across the campaign and protest-reporting sources reviewed for this audit.^{6, 7, 8, 9, 10}

By contrast, Direct Line’s parent company since 1 July 2025, Aviva plc, is a repeatedly and independently named target. Aviva reportedly provided the mandatory employer’s liability insurance for UAV Engines Ltd, a Staffordshire drone-engine factory that is a subsidiary of Elbit Systems Ltd, Israel’s largest weapons manufacturer; campaigners say that cover ended around 7 September 2025 after sustained direct action, with Aviva declining to comment on the claim.^{9, 10, 11} Palestine Action occupied Aviva’s Bristol head office on 22 January 2025 over the UAV Engines link, and on 28 February 2025 targeted Aviva offices in Perth and Motherwell, Scotland, with an Aviva spokesperson confirming “disruption overnight” at those offices and stating that staff safety was the company’s first priority.¹¹ Boycott Bloody Insurance, a campaign group whose shareholder-members disrupted Aviva’s AGM in York on 6 May 2026, said Aviva underwrites or invests in companies linked to immigration detention and surveillance, fossil-fuel extraction, and weapons firms; Aviva declined to comment when approached.¹² Al-Haq’s March 2025 report “Ensuring Genocide: The Insurance Industry and Israel’s War Machine” names Aviva, alongside Allianz, AIG and AXA, as an insurer that “underwrite[s] and invest[s] millions of dollars in ‘defence’ companies selling equipment to Israel.”¹³ Independent secondary reporting on the same report’s findings states Aviva was linked to 13 of 16 named defence suppliers and carried the largest reported investment exposure among the insurers named - approximately US$881 million across 12 companies, including BAE Systems (US$345m), Rolls-Royce (US$238.6m), Caterpillar (US$106m) and Honeywell (US$89.3m), which the report frames as suppliers of equipment used by Israel; an Aviva spokesperson said Aviva “has no operations in the region and no active equity exposure to Israeli companies” and declined to confirm the accuracy of the cited figures.¹⁴ This 2025 allegation follows an earlier, structurally similar one: a War on Want report publicised in September 2018 [pre-2020] named Aviva as a shareholder in companies said to be “profiting from Israel’s war crimes against the Palestinian people,” to which Aviva responded that it was “unable to comment on specific allegations” but would engage with the companies in which it held active investments to understand their response to the allegations before deciding on next steps.¹⁵ As of the research date, no source reviewed confirms whether Aviva’s disputed equity positions in the companies named by Al-Haq remain current, were reduced, or were divested; the status of this relationship is therefore unknown on the evidence available, and Aviva’s own public position is that it disputes having Israel-specific exposure at all.^{14, 15}

Act record. Acting entity Aviva plc; recipient/counterparty UAV Engines Ltd (Elbit Systems Ltd subsidiary); channel is third-party reporting (middleeasteye.net, eco.sapo.pt) of campaigner claims, not Aviva’s own site; earliest dated observation of the insurance relationship is implicit in 2025 protest reporting, with the reported end-date of cover given as 7 September 2025; status is reported as ended by campaigners but unconfirmed by Aviva, which declined to comment, so status is best described as disputed/unconfirmed at the research date.^{9, 10} Acting entity Aviva plc; recipient/beneficiary is the general shareholder base of BAE Systems, Rolls-Royce, Caterpillar and Honeywell via equity holdings; channel is Al-Haq’s own report (alhaq.org) and independent reporting of it (insurance-portal.ca), not Aviva’s site; earliest dated observation is the 2018 War on Want allegation [pre-2020], latest is the March 2025 Al-Haq report; status is unknown/contested, since Aviva disputes the characterisation and declined to confirm figures, and no later divestment or confirmation has been identified.^{15, 13, 14}

The Insure Our Survival campaign’s own primary statement, published by the trade-press site Emerging Risks under the headline “Insurers under fire as month of protests is announced,” explicitly names Direct Line Insurance Group as one of five “worst offending insurers” subject to a call for a full boycott: campaigners are quoted calling for a boycott of “the worst offending insurers - AXA, Allianz, Aviva, Direct Line and LV= and all their sub-brands.” The same statement gives the action’s start date as “8 September” (no year appears on the page itself) and frames the grounds as insurers “underwriting fossil fuel expansion and the manufacture of weapons used in mass atrocities - particularly in Palestine,” with a further explicit reference to “the arms trade sustaining Israel’s assault on Gaza.” The page carries no visible publication date and records no response from either Direct Line or Aviva; neither company appears in the article text beyond the boycott list itself. This is a primary campaign statement naming Direct Line, by name, as a boycott target on grounds that include Israel-Palestine-linked weapons underwriting, a finding not reflected in the existing audit text.¹⁶

Direct Line and LV= do not appear, however, in the other primary and secondary Insure Our Survival campaign sources reviewed for this addendum. Extinction Rebellion UK’s own “Insure Our Survival” campaign page names only AIG, Lloyd’s, Liberty Mutual, Tokio Marine, Brit, Chaucer and the broker Marsh as its stated targets, makes no reference to Direct Line, LV=, Aviva, Allianz or AXA anywhere on the page, and gives no September 2025 date at all - its only dated “Wave of Action” is “2–14 July,” concerning fossil-fuel underwriting (EACOP, Mozambique LNG, Arctic LNG 2, Papua LNG), with no reference to Israel-Palestine or weapons manufacturing.¹⁷ no public evidence identified, via any source fetchable for this addendum, corroborating or disconfirming a further report said to cover the campaign’s 18 September 2025 East Croydon office protest - including whether that protest’s reporting named AXA, Allianz and AIG as the insurers physically targeted, whether it recorded a warning that Aviva and Allianz could be next, whether its stated grounds included an explicit Gaza reference, or whether it mentioned Direct Line or LV= - since the only identified report of that protest returned an HTTP 403 response on direct fetch for this researcher, the host is known to block automated retrieval generally, and no archived copy could be retrieved. The Canary’s 13 August 2025 article on the same campaign (thecanary.co/uk/news/2025/08/13/insurance-companies-protests/), cited in the audit questions as parallel coverage of the Direct Line/LV= boycott list, returned an HTTP 403 response on direct fetch for this researcher and could not be retrieved via an archived copy, so it could not be used here to corroborate or disconfirm the Emerging Risks list. On the evidence this researcher was able to access, the Emerging Risks list’s specific inclusion of Direct Line and LV= is not corroborated by the other dated, campaign-affiliated or local-press reporting on the same September 2025 wave of action.^{16, 17}

Aviva’s own dated statement following the 11 March 2025 Palestine Action occupation of its Manchester office at the Observatory, Chapel Walks - reiterated in reporting on a second, overnight disruption at the same office around 13 April 2025 - was a statement of intent rather than a confirmed court filing: “We have had some disruption at our Manchester office this morning… We will not tolerate any criminal behaviour towards our people or property and will take appropriate legal action,” per Mancunian Matters’ 15 April 2025 report on the second incident, which also records Greater Manchester Police investigating the associated criminal damage.¹⁸ The Canary’s 12 March 2025 claim that Aviva, “like Allianz,” sought an injunction against further Palestine Action protests (thecanary.co/uk/analysis/2025/03/12/allianz-aviva-palestine-action/) returned an HTTP 403 response on direct fetch for this researcher and could not be retrieved via an archived copy, so that specific injunction claim could not be independently verified here. No evidence of a court filing, granted injunction, or civil claim by Aviva against Palestine Action or named individual activists was identified in the sources this researcher was able to access; this is a materially less-advanced legal step than Allianz’s position, where a civil claim - initially sought at a lower sum and later increased to £289,604 plus costs against six named activists (the “Allianz6”) - was permitted to proceed by Central London County Court Judge Alan Johns in a ruling reported on 11 June 2026, with the court separately rejecting the activists’ request to pause the claim pending related criminal trials scheduled for October 2026 and January 2028; that report makes no mention of any equivalent Aviva claim.^{18, 19}

Independent secondary reporting on the “Ensuring Genocide: The Insurance Industry and Israel’s War Machine” report attributes its authorship to researcher Monika Nielsen and its publication to the Boycott Bloody Insurance campaign rather than to Al-Haq: one such account states the report was “authored by Monika Nielsen,” who “also led the research,” on behalf of that campaign, and separately describes the document as having been “released on March 26” (year not stated on the page itself, but the article carrying this claim is dated 14 April 2025, placing the release in March 2025).¹⁴ Al-Haq’s own hosting page for the same document, by contrast, carries no author byline anywhere in its visible text, names neither Monika Nielsen nor the Boycott Bloody Insurance campaign, lists the report under the site’s own “Al-Haq Publications” section heading, and shows a page date of 11 March 2025 that matches the PDF file’s own upload path.¹³ This is a genuine, unresolved conflict in the public record rather than a confirmation of either candidate framing in the audit’s existing text: the two source types disagree both on who authored and published the report (Al-Haq, on the evidence of its own publications listing and page date, versus Monika Nielsen for Boycott Bloody Insurance, on the evidence of secondary reporting) and on its publication date (11 March 2025 per Al-Haq’s own page versus 26 March 2025 per secondary reporting); no evidence identified in this research resolves the discrepancy, so both the authorship and the exact date given in the audit’s existing text should be read as contested rather than settled.^{14, 13}

A separate, independently reviewed source that links directly to the “Ensuring Genocide” report credits it as the origin of a narrower investment-only figure for Aviva: the American Friends Service Committee’s Investigate database states that “Aviva Investors” invests “more than $880 million in 12 weapons companies on the BDS divestment shortlist,” sourcing that $880 million/12-company figure explicitly to a hyperlink labelled “Ensuring Genocide Report,” with no separate “linked to 13 of 16” or similar broader tally appearing anywhere on that page.²⁰ Secondary reporting on the report elsewhere in this research combines two distinct metrics for Aviva under the same underlying document: a narrower, investment-only figure that Aviva was “the largest investor, with US$881 million invested in 12 of the 15 military suppliers” the report names (a 15-company base that excludes Maersk, which the same reporting treats as a transporter rather than a supplier), and a separate, broader figure stating “Aviva plc has links with 13 of the companies” out of 16 total named companies, alongside AXA (also said to link to 13 of 16), Zurich (7 of 16), RSA-Intact (7 of 16) and AIG (4 of 16).¹⁴ On the evidence reviewed for this addendum, this corrects rather than confirms the audit’s existing text, which presents “linked to 13 of 16 named defence suppliers” and “approximately US$881 million across 12 companies” as though describing the same finding: the report’s own investment-specific figure, as independently corroborated by the AFSC Investigate database’s citation of the report, is a 12-company count (consistent with a 15-supplier base excluding Maersk), while the 13-of-16 figure is a separate, broader “links” metric that includes companies - Elbit Systems and Maersk among the 16 - that the narrower investment count excludes; no source reviewed states that the 12-company investment figure and the 13-of-16 links figure describe the identical set of relationships.^{14, 20}

Internal Governance, Content & Retail Policies

No public evidence identified of any report, controversy, or legal action concerning Direct Line Group’s HR enforcement of employee speech, political symbols, or union activity related to the Israel-Palestine conflict, across the company-profile and controversy record reviewed.¹ Direct Line Group does not operate a social-media platform, search engine, or content-distribution service, and no public evidence identified of any independent report, academic study, or regulatory inquiry regarding algorithmic moderation, content suppression, or editorial stances related to the conflict.¹ Direct Line Group is an insurance underwriter rather than a retailer or distributor of physical goods, and no public evidence identified of any report or regulatory action regarding labelling, sourcing, or categorisation of products originating from the Occupied Palestinian Territories or Israeli settlements in connection with the company.^{1, 4}

Brand Heritage & State Partnerships

Direct Line’s brand heritage derives from being the United Kingdom’s first telephone-only direct motor insurer, founded in 1985 as the direct-insurance division of the Royal Bank of Scotland Group and separately listed via a 2012 initial public offering; no public evidence identified of the company using military heritage, defence-sector ties, or state-security origins in its commercial branding or public relations.¹ no public evidence identified of Direct Line Group accepting state honours, hosting Israeli (or other state) government officials, or sponsoring an Israeli state-backed cultural or public-relations campaign such as “Brand Israel.”¹ One disclosed institutional tie is at the level of a named individual rather than the corporate entity: Danuta Gray, Direct Line Insurance Group’s chair from 1 February 2017 to 1 July 2025 (when Aviva’s acquisition completed), concurrently served as a non-executive member of the UK Ministry of Defence’s Defence Board and chaired its People Committee from 2015 to 2021, a role disclosed in the department’s own published register of board members’ interests, which lists her Direct Line Group board seat alongside the MoD role in the same entry.^{21, 22, 23} This is a UK-government defence-sector governance role rather than an Israel-specific one, and no public evidence identified of it extending to Israeli settlement organisations, Israeli defence-industry directorships, or anti-BDS advocacy bodies.^{21, 22}

Aviva holds the naming-rights sponsorship of Factory International’s Manchester venue, rebranded Aviva Studios: the deal was announced 20 June 2023 and valued at an estimated £25m, with naming-rights income split 70/30 between Manchester City Council and Factory International against a council-set minimum fundraising target of £24m; the venue itself cost approximately £210m to build.²⁴

On 9 July 2025, performers Chloe Slater and TTSSFU announced their withdrawal from a Manchester International Festival show over this sponsorship, with Slater stating “AVIVA Plc insures UAV Engines, owned by Elbit Systems” and that she would not play the venue “until AVIVA Plc cuts its ties with Israel,” while TTSSFU said backing the venue would be inconsistent with opposing harm to children and voiced continued support for “Factory International and all that they do for grassroots communities in Manchester”; performer Adult DVD withdrew hours before their scheduled set the same night, citing the venue’s “ties to Elbit Systems who provide arms to Israel.” Factory International responded that it “respect[s] the individual views and decisions of the artists in question,” that it was “sorry the artists felt unable to work with” it, and that it “welcomes open conversations on issues affecting artists and audiences”; no statement by Aviva itself addressing the withdrawals was identified in this or any other source reviewed for this addendum.²⁵

Aviva, which had sponsored Norwich Pride since 2016 and been its main sponsor since 2022, ended that sponsorship ahead of the event held 27 July 2024, following campaigning by Norwich Trans Pride members who called for organisers to drop Aviva “in solidarity with our siblings facing a genocide in Palestine,” citing the insurer’s investments in Barclays, which the campaigners linked to defence firms supplying Israel and to fossil-fuel companies; this is corroborated here via Wikipedia’s sourced account of ITV News Anglia’s 26 July 2024 reporting, since this researcher’s own two attempts to fetch the ITV article directly (itv.com/news/anglia/2024-07-26/aviva-pulls-out-as-pride-festival-sponsor-after-trans-boycott-pressure) timed out and no archived copy could be retrieved by the tools available. Aviva’s verbatim statement, as quoted in that reporting, was: “A small number of interest groups have recently campaigned against our sponsorship of Norwich Pride, leading to concerns about the safety of our people at the event,” adding, “This is very disappointing but we remain committed to the Pride agenda and, together with our Pride Community, will continue the important work we do at Aviva to make our workplace even more inclusive.”²⁶

A primary campaign document directly consulted for this addendum, the Action Network petition “No Pride in Genocide! Call for Norwich Pride to Drop Aviva as Sponsor,” created by the group Norwich Queer Solidarity and addressed to the Norwich Pride Committee (no date is shown on the page itself), states its grounds as: “Aviva holds shares in companies that have links to Israel,” that this “contradicts” the insurer’s own stated “Investors Baseline Exclusions Policy,” and alleges that “their shareholdings in the brutal Zionist campaign are valued at £801 million”; the petition frames Aviva’s Norwich sponsorship, despite the branch’s record as “a safe employer & keen supporter of Norwich pride,” as “pinkwashing” given “the wider actions of its parent company.”²⁷

Lobbying, Advocacy, Financing & Logistics

The only verifiable corporate-lobbying activity identified for Direct Line in the sources reviewed is domestic and unrelated to the Israel-Palestine conflict: a June 2013 Thompsons Solicitors news release criticised Direct Line for describing itself, in its own annual results, as a “leader” in “lobbying for change” on UK motor-accident personal-injury legal reform, and for paying a £101m shareholder dividend shortly after the UK government proposed restricting third-party lobbying disclosure; this predates the audit’s relevant conduct window by over a decade and concerns UK civil-litigation policy, not the Middle East.²⁸ no public evidence identified of Direct Line Group lobbying, PAC-equivalent donations, or leadership roles in geopolitical pressure groups concerning Israel-Palestine policy, boycott legislation, or related trade matters, and no public evidence identified of Direct Line Group donations, sponsorships, or financial support directed to the IDF, FIDF, JNF/KKL, Israeli settlement organisations, or other military-welfare funds.^{28, 1, 2} no public evidence identified of Direct Line Group directing corporate resources, free services, cloud-computing credits, flights, or logistics to Israeli state, military, or state-aligned NGO efforts during the conflict.¹

At the parent-company level, Aviva plc’s disputed equity exposure to Al-Haq-identified defence suppliers of Israel (set out in the Operations section above) is the only identified financial-contribution-adjacent finding in this domain, and it concerns portfolio investment holdings rather than direct donations or sponsorships.^{13, 14}

Corporate Structure & Primary Mission

Direct Line was founded in 1985 as the direct-insurance division of the Royal Bank of Scotland Group, became an independently listed company via a 2012 initial public offering, and its SEC depositary-share registration describes a standard England-incorporated financial-services issuer with no sovereign golden-share or state-mandated structure disclosed.^{1, 4} no public evidence identified of a corporate charter, founding document, or ownership structure tying Direct Line’s primary mission to advancing state geopolitical goals, separate from ordinary commercial insurance underwriting.^{1, 4} On 23 December 2024, Aviva plc agreed to acquire Direct Line Insurance Group plc in a scheme of arrangement valuing it at approximately £3.70 billion; the scheme received Competition and Markets Authority and court approval and completed on 1 July 2025, making Direct Line Insurance Group a wholly owned subsidiary of Aviva plc.¹ Companies House records confirm that, effective 1 July 2025, Aviva Company Secretarial Services Limited became company secretary of Direct Line Insurance Group Limited and a slate of Aviva-linked individuals were appointed directors, including Aviva group chief financial officer Charlotte Claire Jones and Aviva UK & Ireland general insurance chief executive Jason Philip Storah, while former chair Danuta Gray’s directorship (held since 1 February 2017) and former chief executive Adam Winslow’s directorship ended the same day.²³ Direct Line Group’s retained consumer brands are Direct Line, Churchill, Privilege, Green Flag, Darwin, Direct Line for Business, Churchill Business, and Direct Line Motability, underwritten through the regulated subsidiary UK Insurance Limited.¹

Named entities searched individually. Aviva plc - 100% parent since 1 July 2025 - searched for Israel-Palestine links - found: named in Al-Haq’s “Ensuring Genocide” report and in Elbit/UAV Engines insurance-withdrawal and protest reporting detailed above.^{13, 14, 9, 11} UK Insurance Limited - Direct Line’s regulated underwriting subsidiary - searched - none found.¹ Direct Line Insurance Group Limited - operating subsidiary - searched via Companies House primary filing - none found beyond the routine 1 July 2025 director/secretary changes already described.²³

Executive & Leadership Footprint

No public evidence identified of personal donations, family-foundation grants, or fundraising by Direct Line’s former chief executive Adam Winslow (in post January 2024 to 1 July 2025) directed toward Israeli-advocacy groups, parastatal organisations, or military-welfare funds; no public evidence identified of the specific content of any public remarks he made on leaving the company, beyond confirmation that he and the rest of the DLG leadership team stepped down upon completion of Aviva’s acquisition on 1 July 2025, with no reference to any geopolitical issue identified in that reporting.^{29, 30} no public evidence identified of any equivalent personal philanthropy or public advocacy by former chair Danuta Gray (in post 1 February 2017 to 1 July 2025) concerning Israel-Palestine; her only disclosed non-commercial governance role is the UK Ministry of Defence Defence Board seat described above.^{21, 22} no public evidence identified of a board seat, leadership role, or advisory position held by either Winslow or Gray in any Israel-Palestine-focused geopolitical pressure group, state-aligned academic institution, or lobbying organisation.^{29, 22, 21}

Named principals and group executives searched individually. Danuta Gray - Direct Line chair, 1 February 2017 to 1 July 2025 - searched - none found on Israel-Palestine; disclosed UK MoD Defence Board role (2015–2021) noted above.^{21, 22, 23} Adam Winslow - Direct Line chief executive, January 2024 to 1 July 2025 - searched - none found.^{29, 30} Owen Morris - appointed chief executive of Aviva’s UK personal-lines business (encompassing the Direct Line brand) on completion of the acquisition, 1 July 2025 - searched - none found.¹ Jason Storah - Aviva UK & Ireland general insurance chief executive, appointed a director of Direct Line Insurance Group Limited from 1 July 2025 - searched - none found.²³ Charlotte Jones - Aviva group chief financial officer, appointed a director of Direct Line Insurance Group Limited from 1 July 2025 - searched - none found.²³ Amanda Blanc - Aviva plc group chief executive (ultimate parent-level executive) - searched - found: on 5 March 2026 she stated that a prolonged Israel-Iran conflict could raise Aviva’s motor-claims costs through supply-chain disruption to vehicle parts, explicitly citing “the Ukraine situation back in 2022” as a precedent for this inflationary effect, while describing travel-claims exposure as “very limited”; no statement by her addressed the conflict’s human-rights or political dimensions, and no equivalent statement by her on Ukraine itself, as a standalone political matter, was identified.³