1. Policy
1.1 Policy Ownership
This policy is owned by the Group Chief Risk Officer (CRO) and subject to ultimate governance and oversight of the Group Board. The Chief Risk Officer is responsible for its establishment and implementation and shall ensure that it is reviewed on at least an annual basis to confirm that it continues to meet business requirements and relevant regulation. The Head of Compliance will manage the policy and its implementation on behalf of the CRO, providing confirmation that the policy has been adhered to.
1.2 Policy Objective
The Modern Slavery Policy and Procedure (“the Policy”) describes the company’s approach to its obligations under the Modern Slavery Act 2015. These obligations apply to all employees of IQUW Syndicate Management Limited (the “Company”) within the governance structure of the Company and its parent and subsidiary companies (the “Group”), including its managed syndicates, (collectively the “Group”). The Policy applies to all employees (“employee(s)”), Agents (brokers, cover holder’s, delegated authorities, or third-party arrangements) and Associated Persons (persons who perform services on behalf of the Group).
2. What is Modern Slavery?
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain.
The Modern Slavery Act 2015 sets out guidance on fighting modern slavery, the punishment for perpetrators and support and protection for victims.
3. Responsibility for the Policy
3.1 Group Responsibility
The Group has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships as well as, implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its own business or in any part of its supply chain.
To ensure the Group meets its obligations, the Group has in place
- Due diligence requirements for all third-party suppliers. The Group expects the same high standards from all its contractors, suppliers, and other business partners. As part of its contracting processes, the Group includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. The Group expect that its suppliers will hold their own suppliers to the same high standards.
- Systems and processes to support and protect employees who make disclosures of any suspected wrongdoing.
- Training for key employees on modern slavery.
3.2 Employee Responsibility
- All employees have a responsibility to:
- Understand the implications of modern slavery
- Understand the associate risks to the business
- Ensure Compliance with this policy and all relevant legislation and reporting requirements contained therein
Complete all necessary training relating to modern slavery - Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.
4. Compliance with the Policy
The prevention, detection, and reporting of modern slavery in any part of the business or supply chain is the responsibility of all those working for the Group. All employees are required to avoid engagement in any activity that might lead to, or suggest, a breach of this policy.
4.1 Reporting and Escalation
Any employee who is aware of or suspects any conduct or activity in breach of this Policy should immediately report the matter to the Compliance Function. Notification can be made in writing or verbally. The line manager and Head of Compliance will provide you with guidance on what to do once a report has been made.
The Group encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. The Group is committed to ensuring that no one suffers any detrimental treatment because of reporting, in good faith, their suspicion that modern slavery of whatever form is or may be taking place in any part of the business or in any of the Group’s supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. Should an employee believe that their concerns are not being adequately dealt with by the Group or they have concerns of detrimental treatment, they are able to make a disclosure through the Group’s Whistleblowing Champion, Heather Thomas (ht@ht-consulting.co.uk), the Group’s independent whistleblowing hotline (contact 0800 9886818 or email report@seehearspeakup.co.uk) or the Financial Conduct Authority’s whistleblowing hotline (contact 0207 066 9200 or email whistle@fca.org.uk).
5. Communication and Awareness of this Policy
Appropriate training on this Policy and on the risk the Group business faces from modern slavery is provided to all relevant employees.
The Group’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of any business relationship.
6. Breaches of this Policy
Failure to comply with the requirements of this Policy and any related process could be subject to the Group’s Disciplinary Policy and, where appropriate, legal action.
The Group may terminate its relationship with other individuals and organisations working on its behalf if they breach this Policy.