Direct Line Insurance Group plc (DLG) Earnings Call Transcript & Summary

Good afternoon, everyone, and thanks for joining us for the second time in just a little over a week. As we mentioned in the first of these sessions back in June, we're going to keep providing you with updates on our strategic transformation. Now you'll recognize this flywheel from our half year results. I spoke about how we start from a position of strength with leading customer service, strong brands and market-leading claims capabilities. But our biggest course of friction has been our IT systems, which our technology transformation is aimed to address, providing our pricing and underwriting teams with a step-changing capability. So why have we chosen commercial as the next session to provide you some insight on? Well, there are 3 main reasons. Firstly, commercial furthers through this transformation and show what can be achieved when you combine new technology and data architecture with an agile way of working. Secondly, they demonstrate what can be achieved if we get all the elements of the flywheel working together. Over recent years, it's driven strong growth and improved margin with only a small proportion of this driven by market hardening. And thirdly, commercial is an increasingly important area of the group. Both because it provides a strong diversifying benefit, but also because of its ability to innovate and deliver change at pace, it's building knowledge and capability that the entire group can learn from. So I'm going to pass over to Jon Greenwood, the Managing Director of Commercial to kick us off, Jon.

Thank you, Penny, and good afternoon, everyone. I'm pleased and proud to be here today to talk about our commercial business. For those of you that don't know me, I've been with Direct Line Group for 20 years, starting life in our personal lines business and taking responsibility for our commercial business in 2010 prior to the IPO. In that time, we've been pursuing our strategy of focusing on the SME market, supported by a fundamental rebuild of our technology and data architecture. The commercial market is a very dynamic market. And over the last 10 years, we've been constantly refreshing the business. We believe that the business that we built takes advantage of the opportunities this brings and you will have seen the evidence of this in our financial results. Today, you'll hear from Sonya Bryson, our Managing Director of NIG; and Rebecca Clapham, our Managing Director of Direct Line for Business. I'll kick us off by highlighting the key messages, which we would like to convey through this presentation. Firstly, we know that to compete in the SME market, it's necessary to cater for a very diverse range of customers, from sole traders through to complex businesses. And so we've been on an intensive journey to develop our multiproduct, multichannel offering, which gives customers the choice of how they deal with us. Secondly, we've transformed our technology systems, which has delivered in turn, a step change in our pricing capability and our use of data. Thirdly, we've shown that we know how to succeed in this market and have significantly improved our profitability, whilst at the same time delivering growth. Fourthly, we have a highly entrepreneurial and innovative culture which has enabled us to deliver a series of successful initiatives and get ahead of emerging market trends. And finally, this all means that we look ahead, confident in the belief that we can continue to grow. Moving on to Slide 6. I'll now provide an overview of the journey that we have been on whilst transforming the business. It's been one of improving financial performance, coupled with investing in technology, all of which has been done whilst disrupting the SME market with numerous product and channel launches, which you can see in the time line across the bottom of this slide. The graphs show that 2 years prior to the IPO in 2012, we were a loss-making entity. Since then, we have built a track record in not just improving the margins of the business, but also in consistently delivering growth. In today's presentation, I'll explain how we've managed to achieve this. So earlier, I mentioned how critical it is to hold a diverse portfolio of strong products and brands in order to win in the complex SME market. On Slide 7, you can see how we've built a business that caters to that market and provides access to our products through a broad set of distribution channels. At the time of the IPO in 2012, commercial was made up almost exclusively of NIG and the recently launched Direct Line for Business. In 2018, we recognize the growing opportunity in the PCW channel, and we created Churchill for business. And we continue to innovate with the aim of getting ahead of market trends both for commercial and the rest of the group. Our most recent initiative is focused on the trend away from outright car ownership and towards subscription-based ownership with the associated requirement for fleet insurance. We've already made an excellent start, working with new entrants like Cazoo through our partnership arm, UKI Business Solutions. And whilst the book is modest in size today, we believe it is strategically important for the future. We see a strong overlap between the move to electric vehicles and the move to subscription-based ownership, which is why the commercial division has led the way in developing our recent EV proposition. I'll come back to this later. In summary, we have built a business that leverages a number of strong brands across a range of established and growing channels, which means we are well placed however the market develops. So moving on to Slide 8. I'll now provide some more details on the size of the market and the potential it represents. Whilst it's difficult to accurately size the SME market, we believe it's worth around GBP 9 billion, which means that at the end of the third quarter, we estimate our share to be approximately 7%. This in turn means that there is significant opportunity for us to grow our share. 2021 has been a year of double-digit growth, enabled by our many investments and initiatives which have landed at a particularly favorable point in the cycle. Whilst the market may turn at some point, we believe we are still well positioned to grow. We see growth from 2 key opportunities. Firstly, using our improved capabilities to continue winning share within our existing footprint; and secondly, expanding our footprint into slightly larger risks. Sonya and Rebecca will talk more about these opportunities later. But before I hand over to Sonya, I'd just like to spend some time talking about the data and technology transformation that we've delivered. As I mentioned earlier, it has been a key element in improving our competitiveness. So moving to Slide 9. We've been retooling and improving the quality and visibility of our data and the level of insight that we gained from it. This has delivered a step change in capability for us over recent years. Our data is one of our most valuable resources. And for commercial lines, it's been one of the greatest opportunities because it was previously difficult to access and therefore, underutilized. That's because as with any growing business, multiple products and systems were introduced at different times, resulting in a fragmented and complicated architecture. Recently, significant work has been done to replatform much of our business and capture the wealth of data that it produces. This diagram effectively summarizes the constituent parts of our new architecture, which we have totally rebuilt. There's a lot of detail on this slide, but let me just take you through it step by step. First, across the top, we've replatformed all of our major brands. Secondly, we've built a data layer which essentially means we have consolidated and standardized our data into one accessible system. Thirdly, this data layer is enriched by external data sources, seen on the left-hand side of the diagram. We import this data for both individual pricing and to enrich our pricing models. Fourthly, this rich data flows smoothly to the analytics layer, where because the data is standardized, we can use our models to quickly analyze and interrogate it. And finally, as you can see on the right-hand side, we can then flow this modeling directly into the live environment, through the deployment layer without any loss of granularity. On the bottom of the slide, you can see our business insight layer, which makes the data available to all of our people. We've dramatically increased the reach of insight through our use of dynamic online dashboards. So hopefully, that gives you a feel for how we have completely rebuilt the way we store and leverage our data. But what does that mean for the business performance? I'll now talk you through how these new capabilities have driven a step change in our competitiveness and our financial performance. Moving on to Slide 10. The table shows how this new architecture has driven significant changes in where we spend our time. As you can see from the boxes on the left, the pricing and modeling teams previously spent around 50% of their time pulling data together and wrangling it into a usable format. Thanks to our new technologies, the analytics teams can now spend more of their time focusing on delivering greater benefits to the business. The analytics activity in the third column has seen a remarkable fourfold increase in the time invested in this most valuable of activities. So what does that mean for our pricing capability? Firstly, we've increased our suite of models from 15 to 92, generating a huge increase in our pricing accuracy. Secondly, these changes coupled with the adoption of agile ways of working have made a huge difference to the rate of change. Some products have seen pricing updates move from yearly to several per week. Thirdly, our new infrastructure is also designed for the future, allowing us to enter the world of alternative modeling by utilizing machine learning techniques. The introduction of these new techniques has allowed us to refresh models such as those which look at conversion and retention with considerably less data and much faster than was previously possible. We believe this ability can give us a real competitive edge. So what impact have these changes had? Well, it's been key to improving our current year profitability through significantly improving technical pricing accuracy, which has then enabled us to target the right types of risk and tap into pockets of value we see in the market. This step change has been a core component in commercial's transformation and underpins our business strategy, along with the pursuit of new opportunities, which I will return to later. But first, I'm going to pass over to Sonya to talk about the NIG strategy in more detail. Thank you.

Thanks, Jon, and good afternoon. By way of introduction, I've got over 20 years' experience in the commercial market, the last 10 of which have been here at DLG. So the purpose of this section is to provide an overview of the journey we've been on in NIG, how we've transformed our business and how we are now winning in the broker market. I'll start with an overview of NIG, what we do and where we trade, and then move on to the key ingredients for success in the intermediated SME market. And finally, why we are winning in that market. So on to Slide 12. So firstly, we've been around a long time. So our NIG brand is well known amongst brokers with a reputation for strong customer service. This is crucial in the broker market. Over recent years, we've been on a journey of improving NIG's profitability at the same time as growing. This is incredibly difficult to do at the same time. And so for the next few slides, I'll walk through how we have achieved this and why we believe we're set up well for the future. But first, a bit more detail on what we do. So NIG was originally a provider of personal and commercial lines, but are now solely focused on commercial entities in the SME space, and it's all intermediated by brokers. The NIG book has evolved over time, and today, we underwrite various products that can be easily categorized into 4 key areas. First, our complex business accounts for just under 40% of GWP and have seen good growth, particularly this year. This is our regionally traded business, serviced out of 10 offices, the majority of which are strategically located for easy access to key brokers and markets. Our flagship product here is motor trade where we ensure vehicle garages for motor sales, repairs and servicing. It's a product that's been part of the NIG stable for a long time because of our expertise, and it's also a market that sees changing capacity. And so our reliability here really gives brokers confidence. Second is our niche business, where we have particular specialist expertise that sets us apart from the market. There are 3 main cohorts here. We've set up a dedicated service center for our schemes business which is business where brokers we trade with have a particular specialism and they carry out the majority of policy administration. Niche also includes our agricultural insurance brand, FarmWeb. We're now in the top 3 for provision of agricultural insurance, and our proposition here stacks up really well against the market leaders. And finally, municipal housing. There are only a few other insurers playing at scale in this space. And it's another market that's quite fluid in terms of capacity, but our expertise means we have weathered the peaks and troughs well in recent years to remain a consistent and recognized provider. Third is eTrade, which makes up around 18%, excluding the motor lines and is an online system that allows brokers to self-serve the common set of package policies, such as property owners, offices, shops, [ trades burden ] and the like. This space is evolving as brokers continually seek efficiencies and more complex business is B&E traded. Keeping the journey as simple and as efficient as possible without compromising underwriting integrity is key, and we continue to enhance the system and aim to be best in class. Finally, the Motor business, which is around 18% of GWP and also have seen significant growth in the last 18 months, primarily in the van and mini fleet arena. But across the piece, we've worked hard to improve the profitability of the book over recent years. The portfolio certainly wasn't broken, but the ongoing soft market, some large claims and a few weather events brought the trajectory into sharper focus. From there, we implemented a plan of rate carry both ahead of our competitors and ahead of claims inflation, alongside using data and good old-fashioned underwriting. We took a forensic look at the book to target sectors of underperformance. It was quite a tough journey, especially to be an outlier of other's rate strategies, but the slides I'll cover next will demonstrate that we knew how to navigate it and we have come out stronger the other side. Moving on to Slide 13, where I'll outline what it takes to win in what is a crowded SME market. It's critical we understand what makes a difference to brokers so that we're first on their speed dial. The technology and data transformation that Jon walked through earlier are a crucial underpin to this. But to really excel in this market, there are 5 key things you need to get right. Firstly, you need strong broker relationships. This is, without doubt, a relationship business and nurturing those relationships over time really pays dividends. Secondly, a great service, especially claims. It's essential to reassure brokers and customers that we're there for them when they need us. Thirdly, you need a comprehensive product set that needs to appeal to a broad range of customers' needs and innovation to find ways to add value for brokers. Fourth, having robust effective underwriting is critical. This has been a key part of our fixed journey over the past 4 years. And finally, of course, you need financial stability and capacity. Overall, what we've learned over recent years is that if you get these things right, you can win in the broker market. I'll now bring to life how we have achieved this and what it's meant for the business. So on to Slide 14. So what have we done to make sure we meet the needs of brokers. Our systems journey has met some heavy lifting and the improvements in data that Jon spoke about has helped us grow NIG, and I'll put some of the key points on this slide. As I said, this starts with great broker relationships, and we know that giving brokers access to empowered underwriters who can and will make trading decisions is a key differentiator. We'll continue to look for ways to expand our regional footprint where there's opportunity to add value in local trading regions. An example of this would be the dedicated center that we set up for the smaller brokers to trade with us, those who rarely get any kind of service from competitors. We give brokers choice about how they trade. And so we've enhanced our award-winning eTrade system, award-winning again only last week. And that now utilizes robotics, automation and AI to enable our brokers a quicker customer journey and improved conversion. Now this really is effortless trade-in with around 75% of NIG policies now e-traded. And despite those volumes, we're achieving customer satisfaction feedback scores of over 90%. As a further build, we're aligning our eTrade products to our regional ones to ensure brokers have full channel choice. A recent example would be the mini fleet products, which has been revitalized with the new rate in set, a refreshed underwriting appetite and acceptance criteria, much more aligned to the regional fleet product. Now whilst we're mindful that eTrade business is certainly less sticky, the growth we've seen in that product with absolutely no marketing activity demonstrates that brokers want to use the system for quick and efficient trading. So on to customer service. We pride ourselves on service, and this was evident during the pandemic when we continue to serve brokers without interruption, and our availability delivered a really strong Q2 trading performance. But that's actually only half the story. You need to follow it up with a brilliant claims service. You'll remember Jessie spoke about improved claims processes in June, and we benefited from that in commercial. The improved first notification of loss process and the digitized claims handling now allows customers to notify these digitally, uploading photographs and video to support their claims, which reduces the time it takes us to settle them. We can even pay some claims on the day of receipt. So we've leveraged our technology capability and strong broker relationships to see where we can expand our products and propositions. We've done this through new products such as add-on Cyber and Professional Indemnity for defined tradesmen, and we're looking at areas where we can expand that further. But beyond that, we've looked at what other value adds that will give brokers an edge, a real USP. And so we made a brave decision to launch NIG Risk Assist mid-pandemic, to give brokers and clients help managing their business through an online portal. It's available 24/7. Office advice, training and relevant support such as the business reactivation tool care, which guided businesses through reopening once lockdown restrictions eased. We've had over 50,000 policyholders registered their interest in the tool kit and now have over 6,500 active users. Anecdotal feedback from brokers has been really positive about its power to help win and retain customers because they can see the value it adds to their business. But all of this must be supported by robust and competent underwriting. Our experience in underwriting has been the other proof point on our journey. This was brought to life by the way NIG navigated the FCA test case on business interruption policies last year in response to the coronavirus. 15 years ago, following the SARS outbreak, we have the foresight to future-proof our product and our BI exposure was very limited to just a few broker schemes wordings. Now in addition to the eTrade business, we've been replatforming our complex business onto Acturis over the last 3 years to improve the data sophistication and risk data capture that Jon mentioned. It's given us much more agility to change rates quicker based on the insights from the improved modeling that means we can actively focus on risk selection based on that data. The replatforming has also enabled us to update our products and the way we trade them, replacing outdated proposal forms with current statement of facts and provide an instant online policy documentation to the customer. We're over 3/4 of the way through that journey now with just one more product to go, and we've seen an increase in average new business premium of nearly 30% in 2 of our core products that have benefited from the move. And this last point brings all of these steps together as we expand our strategy of more than before. NIG has nailed the S of SME, but the strength of our underwriting alongside the data and systems improvements demonstrates we're capable of much, much more within the SME footprint. We've been extending our reach and growing by writing more M-sized business now, which has been accelerated by the market changes. Our broker relationships have deepened and to drive this to the next level, we've launched lead and follow line products to respond to the market cycle. This is where larger risks are scheduled as insurers pull back their capacity. And we've also established a new team of experienced underwriters to deliver our niche offering. This is designed to further diversify our portfolio in a controlled and measured way, seeking growth in new areas. So on to Slide 15. What does it all mean? This chart shows the GWP journey and an awesome 15% growth on prior year, demonstrating that we've successfully navigated a period of fixed and systems transformation alongside a period of tooling app, and we're a go-to insurer of choice for SME business, which, of course, we're thrilled with. And by building on what we already do really well, we hone the nuances of the overall NIG proposition for SME customers, and our pricing capability and underwriting discipline will mean we'll continue this fantastic work and strike the right balance between growth and profit whilst further demonstrating our relevance in an ever-changing market. This is why we have confidence in our capability and the momentum to drive future success. I'm now going to hand over to Rebecca to talk about DL4B. Thank you.

Good afternoon. I've been at DLG for 14 years, holding roles across both personal and commercial lines, specializing in product development, trading and regulatory disciplines. We're really proud of Direct Line for Business and what it has achieved. It is a real disruptive brand offering customers an alternative to using brokers. Our mission is to create and capture the direct market through innovation and the ability to deliver change at pace, all underpinned by great technology. It really is an exciting place to be. Since its launch in 2007, it has delivered consistent growth up to a premium base of GBP 147 million in 2020. In recent years, through technology transformation, we continue to expand the footprint of Direct Line for Business. So we have massive potential to go further. We estimate the market size could grow to around GBP 3 billion. And so we have a strategy that continues to innovate and build unique customer offerings in order to win in this market. We have all the right ingredients to achieve that. We have enhanced the way our products are structured to give customers more choice and flexibility to truly build a policy around their diverse needs. And we've rebuilt our systems and rating capability to give SMEs insurance that's great value. This required both a retooling of our business but also a mindset change in how quickly we react to changing customer demands. This transformation has increased our customer base by over 25% since 2016. But we know we have only just started. Over the next few slides, I'll walk you through how we've achieved this and why we are confident for the future. As you can see on Slide 18, we took numerous steps to transform Direct Line for Business to design a solution to better serve customers and capitalize on the opportunity to create and capture the direct commercial market. First, we needed to offer flexible cover that could be tailored to our customers' needs through using modular pick and mixed out products backed up with strong customer propositions. We use the underwriting appetite and experience we had in NIG and expanded our product set to serve SME customers who we believe would come direct. Our new customer journeys ensure simplicity for customers with plain English used to explain cover and provide transparency. We knew we could capitalize on the group data and enhanced our rating capability to ensure our pricing delivered sustainable growth and was competitive. We set up segment aligned squads, so we could build deep customer and product expertise. Squads are empowered multi-field teams brought together to focus on a specific mission. We have built on our strong brand recognition by expanding our marketing capability to give us opportunity to segment our customers. Our customers can be anything from a gardener to a firm of graphic designers. We need to be able to tailor communications for our varied customer base. And finally, and most importantly, our new technology stack, which Jon talked to you earlier, alongside the creation of in-house engineering capability provided the agility to respond quickly. Our IT infrastructure is modular, and we have engineers embedded in our squads, which means we can quickly design and execute the business strategy. This creates speed in things like price, product and customer journey changes, allowing us to respond to what our improved data is telling us. On Slide 19, here you can see a time line of all our key activity. And as you can see, it has been a busy 5 years. We decided that to create and capture the market, we would start small and [ iterate ], building out products for one customer segment at a time. Alongside the building of new products, we also took steps to transform our ways of working to ensure we could fully capitalize on the modern systems we have invested in. One of the key components was the implementation of the agile operating model, which creates squads empowered to execute against a focused mission. This enables us to deliver change at pace and at lower cost. This capability is absolutely essential to win in this market as each product is bespoke and tailored to specific risks. This methodology has been replicated across our Motor and Home [ core ] businesses to create that same agility. Projecting forward, we believe we will be able to continue with a healthy cadence of delivering new products for a further expanding customer base. On Slide 20, you'll see, having the right tools and products and an agile mindset means, we now have all the elements of the flywheel that Penny talked about. This has enabled us to deliver strong growth. It also means we are perfectly placed to take advantage of a growing market. So starting with customer focus, our flexible pick-and-mix SME product suite means we can serve over 850 trades by allowing them to build their insurance cover around their business needs. Our easy-to-use product builders means customers can personalize the cover they choose to what's right for them. And our plain English ensures customers get the right information they need to help them make the right choice. Our agile systems and ways of working mean we can respond rapidly. During the pandemic, we got our customer-facing colleagues working from home within 48 hours. We also launched market-leading propositions, which meant we looked after our customers when they needed it the most. Our money back mileage proposition gave customers refunds when they weren't using their van as much during lockdowns. Our free legal essentials product was given to all our SME customers, giving them vital access to legal advice when navigating through unchartered territory like furlough schemes. Second, our group-wide claims expertise and scale has given us the opportunity to deliver market-leading propositions, giving customers access to rapid resolutions when they need to make a claim. We were the first commercial insurer to offer property emergency covered to landlords. We also replaced [ Sterling Tech ] within 24 hours using our robust claims supply chain. This is when our service really matters most to customers. Their livelihoods are at stake. And so the claims service we provide is a paramount importance to us. Third is efficiency. Our new systems mean we can deliver more product change ourselves, meaning quick iteration of our customer journey and product offering is available. We've also improved the efficiency of our marketing spend significantly over time through test and learn activity, meaning we can achieve more from our investments. Finally, we continue to innovate for sustainable growth, and we're excited about what the future holds. Our online journeys have continued to evolve and adapt to more efficiently serve our customers. Customers now have multiple channels to choose from when they need to service their policy. We have squads actively working on the delivery of our next product enhancements and targeting new customer segments, which will allow us to serve even more trades. So moving to Slide 21. Hopefully, I've given you a feel for why we are so excited for what we believe we can achieve in the future with Direct Line for Business. We have a proven track record of disrupting the SME market and delivering profitable growth. With our technology transformation and ability to deliver change at pace, we look ahead with confidence. And with that, I'll pass back to Jon.

Thanks, Rebecca. DL4B is a great example of where we have seen an opportunity in the market and moved decisively to capitalize on it. It's just these types of opportunities, which we are constantly on the lookout for. Churchill for business is another great example. As I briefly mentioned at the start in 2018 we saw an opportunity to use our powerful Churchill brand in the PCW channel. We stood up a small team. And since then, we are focused on this growing channel selling landlord, van and tradesperson products and they're due to launch a shop and business from home product very soon. At H1 this year, Churchill had grown its GWP by over 60% year-on-year. For 2021, we expect premiums to reach in excess of GBP 25 million. Moving on to Slide 24. We're increasingly seeing an overlap between our commercial and personal lines businesses. And so we have continued to build expertise in a range of areas that we believe will also help the wider group. Starting on the left, we have a number of partnerships that enabled us to build capability in the increasingly popular car subscription space. And I've already mentioned our partnership with Cazoo where we're providing motor insurance to customers within their monthly car subscription. We believe that car subscriptions will become increasingly important for customers making the transition to electric vehicles. Clearly, sustainability is a huge focus for us. And at the start of this month, we launched a new EV proposition with a company called Zoom EV with the mission to make electric easy. We're offering new Direct Line car customers a free bundle of EV essentials, such as discounts on public charging points, fitting of home chargers, and reduced costs on home electricity. In the investor insights session, at the end of June, Penny and the claims management team spoke about our expertise in repairing electric vehicles and all the activity that we have in train to prepare for the growing demand for them. This proposition builds on that expertise and seeks to help our customers make the switch as easily as possible. So to close. Hopefully, we've shown you today how we've managed to transform our commercial business. Commercial is an important part of the group, both in terms of the diversification that it brings and through its focus on innovation. We intend to increase the pace of change in the coming years, harnessing our multi-distribution strategy and utilizing the tools which are now embedded in our business whilst looking for new emerging trends. We've already proven we know how to succeed in the SME market, but we know there is more to go at, both through targeting growth through our existing products and by increasing our customer footprint. I've now spent 11 years leading this business, and I remain as excited as ever about the future of our commercial business. I'll now pass you back to Penny to close and open for any questions.

Thanks. Okay. Well, Jon sits down. I just want to take the opportunity to thank Jon, Sonya and Rebecca. I'm enthusiastic about giving you the chance to understand our business better by meeting the teams who drive it forward. But I also recognize that takes a considerable effort on their part. What I really want you to take away from today is the passion, the expertise and the energy that sit behind this commercial business, and the opportunity that lies ahead for it. I'll pause there and open it up and enable you to ask questions of the team. So I'm going to hand over to Molly, who is going to coordinate our Q&A this afternoon. Molly?

[Operator Instructions] The first question comes from the line of Freya Kong calling from at Bank of America.

In side, I think you talked about growth expected to slow in commercial. What sort of growth should we expect going forward? And is this slowdown because you expect the cycle to turn or something else? And secondly, what is your view of competition in the SME market? And who do you see as your key competitors as you move into the medium segment, what sort of commercial risk or customer segments are you looking to target?

I'll take the first question on future growth, and then I'll pass to Sonya to cover the question on who we see as our key competitors in the M of SME. So look, I mean, you've seen hopefully that we've been on a tremendous journey. We've now got a fantastic range of distribution channels. We've got investment in technology, which means that we have a huge amount of confidence in our pricing capability. We think our service offering is one of the best. And that all points towards a very high level of confidence in our ability to grow in a hard or a soft market. I mentioned in my presentation that many of our initiatives have landed at a particularly good point in the sense that the market has been hard particularly in 2021 and to a degree in 2020. And that certainly helped us. But my belief is that we can continue to grow. I think Penny when she spoke last week, referenced the fact that we would expect growth in the mid- to high single digits after -- in different market conditions. And I think that's good guidance. Sonya, medium.

Yes. So I guess the first part of the question, who are our competitors? The really good news is there are existing competitors. And so we already know lots about them. We know about their footprint. We know where we kind of bump up against them. And we also know why we're different, and we value why we're different. In terms of the types of business that we'll grow into. I mean this is much -- this is very much about growing into our existing footprint. So we're not changing our retention. We're not changing our reinsurance, anything like that. It's just about using more of the space that's available. And so we'll do things that are -- we're not typically known for in NIG, but it's pretty commonplace in the M space. I'm not going to go into product details because we've not released that yet, but we will be having quite a controlled to look at distribution about who we give access to those products to because we want to do it in a controlled and measured way, but a very determined way.

The next question comes from the line of James Shuck calling from Citi.

Good afternoon, everybody. Two questions from me. Firstly, just on NIG, it does fit strangely within the portfolio. It's a B2B business essentially and the rest of Direct Line Group is predominantly a retail one, and it's a broker business. So can you just kind of elaborate a bit on why you're committed to that and wouldn't it make sense as being a home with someone else? And then secondly, direct line to business, I mean, the growth rate has been okay over the last decade or so. We're still doing early about GBP 150 million in premium. If I look across the pond to the U.S., I can see some very interesting start-ups that are growing much quicker than that. I'm just keen to get your views about the structure of the U.K. market and whether it's different to the U.S. and why the U.S. seems to be accelerating much more quickly when it comes to this sort of platform.

I'll take the first one. Jon may want to comment on the second one, I suspect. Look, I've talked about where NIG fits before. So yes, it's a broker business. But actually, we are all about kind of people and small businesses. So it fits across the portfolio in that sense. It's delivering a strong return. It wasn't several years ago, but it certainly is now. So that's another positive thing. And I think what the team have given you today is several examples of whether crossovers and learnings moving between the portfolio in different directions, whether it's pricing or underwriting, agile ways of working, EVs, some of the data techniques which run across the group. So for us, yes, it's a slightly different distribution channel route than we use in other spaces. But actually, there's a huge amount of synergy across the group, and that's the reason we stand behind it and are proud to own it. Jon?

Thank you, Penny. So the U.S. versus the U.K. SME market and Direct specifically. So I think there's a point of real difference. And then I think there's a point of real similarity. The point of real difference is the commercial insurance market in the U.S., I think, is structured very differently, the state-by-state nature of the U.S. market. I think in itself is fundamentally different to the U.K. So I don't draw too many parallels other than to say that we've certainly visited some of the U.S. start-ups and looked at their journey. And one of the things that they have in common with us is a commitment to increasingly make their business as digital and data driven. And we're doing the same thing. And we believe that the kind of trends in society more generally support the shift towards commercial as particularly small commercial businesses buying directly. And you'll have seen one of the investments that we've made is in the new platform for DL4B. It's given us the ability to produce products on a modular basis. I think Rebecca referred to it as a pick and mix. So it's extremely flexible. We couple that with digital journeys, which are very intuitive and then our expertise in pricing. And I think we've got a very powerful combination of strengths within the group that mean that as that trend continues, we're very well positioned to take advantage of it. If you were to break down the Direct Line for Business performance, the fastest-growing part is the part which is focused on small businesses as opposed to landlords and vans. So we're getting double-digit growth in that particular part of the business. So maybe more in common with some of the other businesses that you've observed in that sense.

Molly, have we got any more questions?

We do. The next question comes from the line of Ivan Bokhmat calling from Barclays.

I've got a couple of questions. The first one is perhaps on some midterm targets related to profitability of the commercial. I appreciate you might not give precise numbers here, but can you guide us at least where should commercial stand within the 93% to 95% range? And how do you think about the cycle there? And the second one, I guess, one of the purposes of this session, at least in my mind, has been to see what the benefits of the transformation in commercial can mean to the rest of the businesses, Motor and Home. So I was just wondering whether you could maybe draw some parallels of what has worked in commercial irrespective of the cycle? Because clearly, in commercial, you've highlighted you've had the benefit of hardening rates, in Motor and Home, you might or you might not necessarily next year.

Okay. Jon, do you want to comment on the first one, then Neil may want to add.

Yes. I mean we operate -- short answer, we operate within the same range. We've been moving towards that. You'll see that we're now within the range, and that's where we intend to stay.

I think that's probably covered it. So to read across, I mean, I think what are we saying? We're saying that a lot of the things in transformation effects that have happened in commercial that we've driven there, we're also driving in Motor and Home, although Home is probably a year or so behind the others. So in that sense, it's similar. And commercial, yes, had a few tailwinds from hardening at the bottom end of the market, but we're convinced there's growth there regardless of that because of the things that we've done on pricing, because of the automation and technology that's gone into customer service and broker service specifically, because of the use of data. Now if you look across the group at what's going on, we're investing in data architecture and use of data group-wide, so not just in commercial. We've put the new motor system in over the course of this year, which massively improves the functionality for our pricing colleagues. And so we have a backlog of things that they are working through to take advantage of that, that they have not been able to do in the past. And so the shorthand is either we've got a particular thing to get through with pricing practices that we'll juggle around where rates set across the market in a few weeks' time. But actually, the fundamentals behind that of the investments that we've made in commercial, those similar investments are going into motor and are coming on stream and a notch behind that in Home as well. So I think there is some read across that there are benefits to come through in other parts of the group. I'll pause there, I think. Molly, we got another question?

The next question comes from the line of Faizan Lakhani calling from HSBC.

So the first question on medium-sized risks that you were looking at. Historically, they're quite volatile relative to a small segment of the market. Would you look to use more reinsurance here? And second question is on the competitive environment. A lot of your commercial peers have been sort of scarred by the business interruption saga, if you could call it that. How much of the benefit have you seen from market share from the players who were sort of publicly sort of struggling with the BI scandal?

I'll certainly take the first of those questions. So we believe the reinsurance program that we have in place is well suited, not just to the small risks that we dominate our [ boat ] but also to medium-sized risks. So we're quite comfortable with the existing reinsurance program. In terms of business interruption and the effect it's had on our competitors, you can see quite mixed results from our competitors in terms of their performance over the last 2 years. I wouldn't be specific about where, in particular, we've won business from, but it's undoubtedly true that whilst our competitors were coping with or dealing with the impact of business interruption claims, that would have had an adverse effect on them, which we will certainly have had some benefit from. Couldn't say specifically which particular insurers we've won business from.

I think the only thing I'd add to that is we also saw through the pandemic, service differentials. So one of the things the technology, I think, is enabled as us to carry more volumes on the servicing side. So I think there are a number of factors as to where there have been differential performances between the competitors in that space.

Follow-up. Who are your main competitors across the SME commercial space?

I'll pass that question to Sonya.