MODERN SLAVERY ACT
This statement has been published in accordance with the Modern Slavery Act 2015 and is made by Towergate Insurance Limited and each of its other group undertakings which have met or exceeded the relevant turnover threshold (“Towergate”) during the year ending 31 December 2016. For other subsidiary companies, this statement will be treated by them as a statement of best practice.
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, Towergate 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 2016 to combat slavery and human trafficking in our business.
Towergate provides a wide range of insurance 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 4,000 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.towergate.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.
We recognise the right of each employee to freedom of association, including the right to join trade unions. We ensure that we do not employ people who are underage or who do not have the right to work in the UK.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
During 2016 we looked at our supplier base and questioned a number of our major suppliers who we determined posed the greatest modern slavery risk on how they could demonstrate compliance with the Act.
We have also reviewed and updated our standard contractual documentation with third party suppliers to require compliance with the Act.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, our procurement team has been made aware of the provisions and requirements of the Act. Training is not yet provided to all staff, however we envisage providing training on the Act to staff involved in purchasing and entering into contractual arrangements on behalf of Towergate.
Going forward we will question potential third party suppliers of services to the Towergate group on their compliance with the Act as part of our procurement process. We also envisage developing and updating our group outsourcing and key supplier business standards to include reference to the Act and ensure supplier compliance with the Act. Part of the update to our key supplier business standards will include reviewing our key suppliers on an annual basis, including ensuring that such suppliers are demonstrating their 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 2016.
The board of directors of Towergate Insurance Limited approved this statement on 24 April 2017.