Modern Slavery Statement

The Modern Slavery Act 2015

In accordance with the Modern Slavery Act 2015, this is the statement by Swinton Group Limited (“Swinton”, “we”, “our”) for the financial year ending 31 December 2016, which sets out the organisation’s commitment to tackling slavery and human trafficking in our supply chain and in our business.

Organisation's Structure

Swinton is a provider of insurance broking services in the financial services sector in the United Kingdom. Swinton is a part of the Covea Group of companies (“Group”). Our immediate parent company is Swinton (Holdings) Limited (company number 01741892) and our ultimate parent company is Covea Mutual Insurance Group Company (SGAM), which has its head office in France.

Our supply chain primarily consists of goods and services purchased to assist in the delivery of our insurance broking services to our customers.

Swinton's Supply Chains

We are committed to ensuring that there is no slavery or human trafficking in any part of our supply chains or in any part of our business. We have taken a number of steps to assess, address and mitigate the risk of slavery and human trafficking in our supply chain in the previous financial year:

1. Policies

We reviewed our policy library to ensure the issue of slavery and human trafficking is sufficiently addressed, and made some key changes to those policies. A number of Swinton’s policies address the issue of slavery and human trafficking in our supply chains:

a) Swinton’s Procurement Policy, details the principles and standards the business must adhere to when searching, evaluating, selecting, contracting and managing external suppliers. The Procurement Policy explicitly references adherence to the Modern Slavery Act 2015;

b) Swinton’s Outsourcing Policy, details the principles and standards the business must adhere to when outsourcing services (which means the transfer of existing business processes to a third party, or a function which is critical to performance of Swinton’s business). Swinton’s Outsourcing Policy explicitly references adherence to the Modern Slavery Act 2015.

2. Suppliers

As part of Swinton’s initiative to identify, address and mitigate risk in relation to slavery and human trafficking in reference to new suppliers, Swinton:

a) has incorporated clauses into all standard contracts with new suppliers to ensure suppliers contractually commit to comply with the Modern Slavery Act 2015. It is one of Swinton’s fundamental contracting principles that there is an obligation to comply with the Modern Slavery Act 2015 in all contracts with new suppliers;

b) has incorporated audit clauses into all standard contracts with new suppliers to allow Swinton the ability to audit those suppliers to ensure compliance with its obligations under the contract, including in relation to compliance with the Modern Slavery Act 2015. It is one of Swinton’s fundamental contracting principles that in all contracts with new suppliers Swinton has the right to audit that supplier.

Swinton's Business

We have also taken a number of steps to assess, address and mitigate the risk of slavery and human trafficking within our own business in the previous year:

1. Policies

A number of Swinton’s policies address the issue of slavery and human trafficking in the context of our business:

a) Swinton’s Whistleblowing Policy, which details Swinton’s commitment to demonstrate the highest possible standards of openness, probity and accountability, enabling employees to raise concerns without fear of reprisal;

b) Swinton’s Bribery Code of Conduct and Conflicts of Interest Policy, which details that employees must uphold the highest standards of integrity and personal conduct in all matters concerning Swinton, setting out rules regarding bribery, corruption and conflicts of interest;

c) Swinton’s Human Resources Policy, which details Swinton’s approach to the recruitment, retention, management, performance, development and health and safety of all Swinton colleagues, including the principle that all colleagues conduct themselves in an appropriate manner inside and outside of work;

d) Swinton’s Recruitment and Selection Policy, which details Swinton’s commitment to maintain the highest standards of integrity and honesty in our selection process;

e) Swinton’s Pay and Reward Policy, which details Swinton’s commitment to have a legally compliant and transparent pay and reward scheme for employees.

2. Training

To help embed the principles set out above, we provide online training to staff on the Bribery Code of Conduct and Conflicts of Interest Policy.

In The Next Financial Year

In this financial year ending 31st December 2017, we aim to:

  • Further review our policy library to ensure the issues of slavery and human trafficking are properly addressed, and make changes as necessary;
  • Carry out an assessment of our current supply chain, assessing the supply chain in the context of key high risk indicators including geographical location of the supplier and supplier sector, to ensure existing suppliers at risk of slavery and human trafficking practices, are identified. We are then asking those suppliers to declare they are compliant with Modern Slavery Act 2015;
  • Further develop our due diligence processes in our procurement process. We have already developed a definition of ‘high risk’ suppliers in the context of the Modern Slavery Act 2015 to consider whether a supplier is high risk in the context of modern slavery. In addition, we are also in the process of developing a declaration for new suppliers engaged by Swinton with the purpose of assessing the risk of that supplier in the context of the Modern Slavery Act 2015, and are in the process of embedding it as part of Swinton’s overall procurement process;
  • Provide further training on slavery and human trafficking to employees, as appropriate.

This statement is made by Swinton Group Limited on behalf of itself pursuant to section 54(1) of the Modern Slavery Act 2015 and is subject to the governance of Swinton Group Limited.

Gilles Normand
CEO
Swinton Group Limited 
Date: 14 July 2017