Introduction
The Modern Slavery Act 2015 (the “Act”) is a UK law that came into force in 2015. The Act requires commercial organisations with an annual turnover of more than £36 million to publish a slavery and human trafficking statement for each financial year. As a major provider of insurance broking and associated services, the Ardonagh group of companies (the “Ardonagh Group”) is fully supportive of the Act and, as required by the Act, this statement sets out the steps taken during the financial year ended 31 December 2019 to combat slavery and human trafficking in our business and supply chains.
Our business
The Ardonagh Group brings together leading businesses in their respective fields within the insurance broking and services industry. For all or part of 2020, the Ardonagh Group comprised the following businesses: Autonet, Bishopsgate, Broker Network, Carole Nash, Compass UK, Ethos Broking, Footman James, Geo Underwriting, Healthy Pets, insurance4carhire, Paymentshield, Price Forbes, Swinton, Towergate Insurance Brokers, Towergate Health & Protection and URIS Group. As a group, we provide a wide range of insurance products and services to businesses and consumers, and the legal entities that carry out insurance-related activity are authorised and regulated by the Financial Conduct Authority. As a group we have over 6,000 staff in our nationwide offices and most of our business is within the UK. More information about our business can be found at: http://www.ardonagh.com.
Our supply chains
Our supply chains include business partners in the provision of insurance services such as insurance companies, brokers and distributors; and also providers of other services necessary to run our business effectively, such as IT, payroll, and facilities.
Recruitment practices
We recognise the right of each employee to freedom of association, including the right to join trade unions. We ensure that we comply with employment legislation as regards child employment and we do not employ people who do not have the right to work in the UK.
Due diligence and contracting
The Group Outsourcing and Procurement Policy mandates the requirement for checking compliance. The businesses that make up the Ardonagh Group have varying processes in relation to ensuring that slavery and human trafficking risks are appropriately managed. Within Bishopsgate, Geo Underwriting, Paymentshield and Towergate businesses (and their respective trading brands), a question set and declaration called Know Your Supplier (KYS) is required to be completed by the Suppliers. This includes a section on slavery and human trafficking. The KYS has been used for due diligence since the beginning of 2017. In contracting, standard contractual documentation with suppliers requires compliance with the Act and for all Material Suppliers and includes a requirement for an annual attestation confirming compliance. Additional tools such as tiscreport.org are also being used to check statements by some businesses. Price Forbes continues to review its supply chain to verify that its key suppliers are committed to observing best practice when it comes to slavery and human trafficking issues and compliance with the Act and is starting to use the KYS process. Autonet, Carole Nash and Swinton audited appropriate business partners’ websites to confirm that they had posted modern slavery statements. URIS Group does not fulfil the turnover requirement within the Act but has committed to adopting minimum standards in relation to the Act.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we take the opportunity annually to remind key staff involved in procurement and supplier management of our obligations under the Act.
Further steps
As part of the rollout of our Group Policies and Business Standards it was recognised that there is a need to clearly articulate the minimum standards required to comply with the Modern Slavery Act which require to be adopted and embedded across all businesses within the Ardonagh Group. This was rolled out in early 2019, to ensure a consistent approach going forward.
As part of our annual review a supplier health check will be completed which will include compliance with the Act.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2019.
The board of directors of the Group holding company, The Ardonagh Group Limited, approved this statement on 16th February 2021.
David Ross
Group CEO