Scope

The Modern Slavery Act 2015 came into force on 29th October 2015 having received royal assent on 26 March 2015. The Act consolidated legislation in respect of slavery, servitude, and human trafficking offences.

Modern slavery is a crime and a violation of fundamental human rights. It takes numerous forms such as slavery, forced and compulsory labour and human trafficking. All of these activities have in common, the deprivation of a person’s liberty in order to exploit them for personal or commercial gain.

The MSA 2015 gave government and law enforcement the tools required to fight modern slavery, ensure perpetrators receive suitably severe punishments for their heinous crimes and enhance support and protection for the victims.
The Act also requires certain firms to be able to demonstrate what action they have taken to ensure that there is no modern slavery within their business or supply chain.

As a result, firms are required to consider this matter at the highest level, requiring the attention of the Board.

The Act includes a new reparation order which encourages courts to confiscate assets from perpetrators to compensate victims. In addition, where organisations or individuals fall short, the Act created new powers and sentencing guidelines that can result in severe consequences for those held accountable which can include life imprisonment.

While we are not obligated under the Act to have a policy on Modern Slavery, we feel that it important that we adopt one to be transparent about our stance and achieve best practice.
We operate a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships. We have therefore implemented systems and controls that are sufficiently robust to respond to the requirements of the law and to ensure that modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring that there is transparency in our own business and in our approach to modern slavery. We expect the same high standards from all the parties we work with. This policy documents our approach to how we meet our responsibilities under the MSA 2015.

To Whom This Policy Applies

This policy applies to all persons working for our business or on our behalf, in any capacity including employees at all levels, directors, officers, part-time and temporary staff and agency staff, in addition to sub-agents, appointed representatives and all other business partners.

This policy does not form part of any employee’s contract and we may amend it at any time.

Structure of Our Business

We are an independent insurance intermediary formed in 1946 and are based in Southend-On-Sea with an office in Westcliff-on-Sea.
Our portfolio includes consumer and commercial clients, from individuals and small to medium enterprises to large complex clients. We have an annual premium income of £xx.

 
We specialise in providing Property insurance cover, however, we are also able to offer a wide range of personal and commercial policies and covers from Private Car and Home insurance to Liability, Directors & Officers cover and Business Interruption.

Our policies on slavery and human trafficking

This Modern Slavery and Human Trafficking policy reflects our commitment to interacts with the following policies:

• Policy Towards Outsourcing
• Policy Towards Business Partners
• Whistleblowing

All staff are encouraged to familiarise themselves with this and the above policies and should refer to a Manager or Director if they have any queries or concerns.

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or supply chains. Our policy towards Modern Slavery reflects our commitment to:

• Act with integrity and ethically with all our business relationships
• Implementing and maintaining effective systems and controls to ensure human trafficking and slavery is not taking place anywhere in our supply chains

Our Supply Chains

We work with various business partners in the provision of insurance services, such as insurance companies, brokers and distributors, in addition to IT, HR and training, business consultants, cleaners and stationery suppliers etc. We expect from all of them, the same high standard with which we comply, including compliance with all appropriate regulations and laws.

We will terminate the relationship we have with any individual or organisation working on our behalf if they are found to be in breach of this policy or the MSA 2015.

Recruitment

We will not employ any person who is underage or who does not have the right to work in the UK. Furthermore, we recognise the right of each member of staff to freedom of association, including the right to join trade unions.

 
Training

In order to ensure a high level of understanding of the risks associated with modern slavery and human trafficking in our business and supply chains, our Senior Managers and Board are aware of the provisions and requirement of the Act.

 
All staff are required to undertake training on modern slavery.
Due diligence processes for slavery and human trafficking
We have taken a proportionate and risk-based approach when assessing the possibility of modern slavery occurring in our supply chain. Areas considered include the nature of the businesses we are dealing with, the length of the supply chain, geographical location from which services are provided, use of migrant or temporary labour and the nature of the goods or services being supplied.
We carry out due diligence checks on new key direct suppliers prior to engagement, tailoring the approach according to (amongst other factors) the potential modern slavery risks.

Any concerns highlighted will be immediately referred to Board of Directors for review. No supplier would be appointed until such time as our Board have satisfied themselves that they do not pose a risk under the MSA 2015.

 
Responsibility for this policy

Our Board has overall responsibility for policy. The successful implementation of this policy requires that all staff, across all areas of our business are aware of this policy and our zero-tolerance towards modern slavery and human trafficking.
Management at all levels of our business are responsible for ensuring that those reporting to them understand and comply with this policy and are given adequate and regular training on the issue of modern slavery in supply chains.

The prevention, detection and reporting of any incidents, or suspected incidents of human trafficking or modern slavery in any part of our business, or supply chain, is the responsibility of all those working for, or on behalf of, our business. All employees and business partners are required to avoid any activity that might lead to, or suggest, a breach of this policy or the requirements of the MSA 2015.

Staff are required to notify a Manager or Director as soon as possible if they become aware of or suspect that a conflict with this policy has occurred or may occur in the future.
We have a whistleblowing policy and procedure in place and staff are encouraged to raise concerns about any issues or suspicions they may have about modern slavery in any part of our business or within any of our business partners, at the earliest possible stage.
Any employee found to be in breach of this policy will face disciplinary action and may be subject to dismissal for misconduct or gross misconduct.

This policy and matters arising from it are reviewed annually and are the responsibility of Richard Burgess, Director
Last reviewed July 2022