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 2017, 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 part of the Covea group of companies. Our immediate parent company is Swinton (Holdings) Limited (company number 01741892) and our ultimate parent company is Covea Mutual Insurance Group Company (SGAM), the head office of which is located in France.

Our supply chain primarily consists of goods and services purchased to assist in the delivery of 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 via the following:

1. 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. Dealing with 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 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 to audit those suppliers to ensure compliance with its obligations under the contract. It is one of Swinton’s contracting principles that in all contracts with new suppliers Swinton has the obligation to audit that supplier;

c. when engaging a new supplier and as part of the tender process, Swinton will request details of proposed suppliers’ policies on modern slavery, and will review and assess the modern slavery policy for any winning bidder.

Swinton's business

We are committed to ensuring that there is no slavery or human trafficking in any part of our business via the following:

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 General Conduct Policy, which details Swinton’s commitment to ensuring the highest standards of integrity and honesty from its staff;

c. Swinton’s Dignity at Work Policy, which details Swinton’s commitment to providing a working environment free from harassment, discrimination, bullying and victimisation, where unacceptable behaviour is easily identified, challenged and stopped;

d. Swinton’s Resourcing Policy, which details Swinton’s approach to the recruitment of Swinton colleagues, including the principle that an appropriate selection process will be applied fairly and consistently to all candidates to ensure the best candidate is selected for the role;

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 which does not encourage activities or behaviours that are inconsistent with achieving fair customer outcomes;

f. Swinton’s Financial Crime Policy, which details Swinton’s approach to mitigating the risk of financial crime within the business, including its commitment to conducting all business in an honest and ethical manner, and ensuring employees act professionally, fairly and with integrity in all business-related activities.

2. Training

To help embed the principles set out above, we provide online training to staff, including on Whistleblowing and Financial Crime.

In the next financial year

In this financial year ending 31 December 2018, 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;
  • Further review our supplier due diligence process to make sure issues of slavery and human trafficking are properly addressed, and make changes as necessary;
  • 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.

Signed:

Gilles Normand
CEO
Swinton Group Limited
Date: 26/09/2018