Modern Slavery Statement

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MODERN SLAVERY STATEMENT 2019
 



esure Group Modern Slavery Statement 2019

Introduction

This Statement set out the steps taken by esure Group plc, esure Services Limited and esure Insurance Limited, (together, the “Group”), pursuant to section 54 of the Modern Slavery Act 2015. This Statement covers the period during the financial year ended 31 December 2019. It is our aim to introduce and maintain strong, robust policies and protocols which seek to prevent modern slavery and human trafficking from taking place within our own business or supply chain. We understand our responsibility as a business to assist the authorities in any way we can with the collective support of our employees, suppliers and our wider network.

Our Business

esure Group plc is the holding company for a group of companies including esure Services Limited and esure Insurance Limited. The Group provides motor and home insurance products and ancillary services through the esure, Sheilas’ Wheels and First Alternative brands. Customers are able to purchase our products online, either direct or through price comparison websites, or over the phone. The Group operates UK call centre operations and has outsourced arrangements in the UK to supplement this operation. In 2019, the Group employed over 1,800 people in the UK, across our three sites in Reigate (Head Office), Manchester and Glasgow.

Our Supply Chain

Our procurement procedure requires confirmation from any prospective supplier that they will abide by the esure Group Code of Business Ethics. The Code incorporates the Group’s values and ethos, and includes references to modern slavery legislation and compliance, ensuring that there is a consistent approach to tackling modern slavery across our supply chain. Activities are undertaken based upon an assessment of the risks associated with the services and/or the supplier.

This may include:
• reviewing the supplier’s HR vetting process;
• understanding where the supplier’s services will be performed from, i.e. within the UK, or any other country;
• implementing an approval process with the supplier for their use of subcontractors prior to use; or
• ensuring that we have a right to conduct audits of the supplier.

A risk-based segmentation assessment of esure suppliers is conducted to define appropriate levels of oversight throughout the contract life cycle including the frequency with which checks are undertaken to ensure ongoing compliance by the supplier. esure's Supplier Relationship Management Procedure requires each supplier be assigned a Supplier Manager who is responsible for ongoing oversight of the supplier’s performance and its compliance with esure's policies and procedures.

Our Human Resources

We conduct pre-employment checks to verify the identity and background of anyone recruited to work for us. Our screening also ensures all employees have the right to work in the UK.

Updates to Policies

Building on from our review of internal and external policies last year, our Employee Code of Conduct, which sets out the expectations we have of our employees, has been updated to provide a greater emphasis on the issues surrounding modern slavery and human trafficking. Through this, we’ve strengthened the need for our employees to work collectively to identify and report any activities which they suspect are contrary to the Modern Slavery Act.

Training & Development

Classroom training: In accordance with initiatives highlighted in our previous statement, we have successfully extended our training programme to a wider range of staff including supplier managers and those closer to our approved network of repairers. In 2019, we delivered modern slavery awareness training to our motor repairer relationship management team, providing guidance on how to spot the signs of exploitation and how to successfully report potential cases. By providing this training, we’ve strengthened our lines of communication to those employees closest to our approved network of repairers.

Online Training: All employees and contractors are required to complete our Whistle-blower online module annually and new starters take this module within 3 weeks of their start day. The module provides information on how to report potential or actual incidents. In 2019, the module was completed by 1937 colleagues.

Anti-Slavery Day awareness campaign: On the 18th October 2019 we joined the UK national campaign to mark Anti-Slavery Day. Via our internal website and employee newsletter we provided employees with practical information about how to spot and report modern slavery and human trafficking.

Risk Assessment

Our Modern Slavery Compliance Team (“MSCT”), which includes representatives from the Legal, Risk, Procurement and HR departments, continue to review and assess our annual Modern Slavery Risk Assessment to identify any risks which arise in the business and generate strategies to prevent modern slavery and human trafficking from taking place within our business or our supply chain. there were no incidents relating to modern slavery or human trafficking identified during the year ending 31 December 2019, nor were there any incidents reported by our employees or suppliers.

Approval

This Statement was approved by the Board of Directors of esure Group plc on 1 April 2020.

David McMillan
Chief Executive Officer
esure Group plc
1 April 2020.

Download the 2019 Statement
 

Modern Slavery Statement 2018

 

This statement (“Statement”) is made pursuant to Section 54 of the Modern Slavery Act 2015 (“Act”) in respect of the companies that exist within the esure Group (“Group”). This Statement describes the steps which we have taken during the financial year ended 31 December 2018 to ensure that slavery and human trafficking is not taking place in any part of our own business or supply chains.

We actively work with authorities to support their actions against modern slavery related crimes and require both our employees and wider network to engage collectively to combat modern slavery and human trafficking.

Our business 

The Group is an efficient, customer focused personal lines insurer, founded in 2000 by Chairman, Sir Peter Wood, Britain’s foremost general insurance entrepreneur. The Group is one of the UK’s leading providers of Motor and Home insurance products through the esure, Sheilas’ Wheels and First Alternative brands.

Customers are able to purchase our products online, either direct or through price comparison websites, over the phone, or through the use of our brokerage network.

We have over 2,000 employees in the UK across our three sites in Reigate (head office), Manchester and Glasgow.

Review of our work in 2018

• Enhanced the role of the modern slavery compliance team Last year, the Group created the esure modern slavery compliance team (“MSCT”). This is a specialist team made up of representatives from Legal, Risk, Procurement and HR departments, created to identify and implement changes within the Group to combat modern slavery. This year, the MSCT helped to concentrate endeavours in preventing modern slavery through providing a structured framework and plan for the Group to adopt in the coming years.

• Updated our external policy used to tackle modern slavery Our Code of Business Ethics, distributed to our new suppliers, which incorporates the Group’s values and ethos was updated to include references to modern slavery law and compliance, ensuring that there is a consistent approach to tackling modern slavery with our wider network.

Similarly, our Procurement Policy, which sets out the expectations of our suppliers, includes a strict adherence to our Code of Business Ethics. A supplier’s compliance with the Code is paramount to us forming or re-entering into an existing relationship.

We strive to encourage the right behaviours by fostering long term relationships with our suppliers and, for example, by encouraging minimum standards to be met such as paying (at least) the real UK Living Wage for suppliers who provide us with additional resource in servicing our customers.

• Reviewed and updated our current Risk Assessment Each year we update and maintain our modern slavery risk assessment which was created to identify and investigate changes in risks raised in new business processes. After engagement with several stakeholders, changes were made to align them with our updated policies for both employees and suppliers.

• Provided specialised training for key esure employees In 2018, esure conducted specialised training for key departments in the business including Procurement and Facilities. This training helped to bring more attention to the nature of operations that exist within our supply chains and wider network.

It is important to us that all our employees feel comfortable to voice their concerns. Last year we sent all employees an internal news update outlining the basics of modern slavery, as well as a ‘beginner’s guide’ to identifying and reporting potential cases. We also provided employees with contacts and references to wider organisations, along with links to our internal and external policies.

What we intend to do next

We understand that tackling modern slavery is an ongoing process. With that in mind, we have outlined our steps in 2019:

• Extend our training programme to a wider range of staff including supplier managers and those closer to our repairer network.

• Continue to review and assess our annual modern slavery risk assessment to identify any new risks which arise in the business.

• Conduct more onsite visits with key suppliers to better understand the nature of their business and employee conditions.

• Monitor changes to legislation regarding modern slavery.

Download the 2018 Statement

 

Modern Slavery Statement 2017

 

INTRODUCTION

We are a provider of insurance in the UK financial services sector and are the parent company of the esure Group (Group). We are committed to the highest standards of ethics and integrity and are dedicated to conducting our business in a lawful manner, which includes engaging with suppliers to ensure that they share our high standards. As required by the Modern Slavery Act 2015 (the Act), this statement describes the steps which the Group has taken during the financial year ended 31 December 2017 to ensure that slavery and human trafficking is not taking place in any part of our own business or supply chains.

RISK MONITORING AND COMPLIANCE

As part of our initiative during 2017 we have carried out a risk assessment to identify potential areas of risk in our business and supply chains. Our risk assessment takes account of the country, sector, transactions and partners of the business. We identified that the overall risk of the esure Group facilitating modern slavery was low. We have acknowledged in our assessment that the following areas of our business have a slightly higher level of  risk: Non-UK service staff; On-site service providers (such as catering, security and cleaning staff); and Off-site service providers (such as repairers and loss adjustor services carried out by third parties). As part of the action taken by esure in 2017, we have formed a Modern Slavery compliance team, made up of representatives from Legal, Risk, Procurement and HR departments. This compliance team is responsible for identifying and implementing changes within the Group to combat modern slavery, including: Maintaining and updating the modern slavery risk assessment annually; Investigating risks raised in the risk assessment; and Implementing changes in the business to combat modern slavery risks which have been identified.

OUR POLICIES

Our Code of Conduct sets out our core principles of our business ethics and demonstrates our commitment to fair employment practices in relation to our own employees. We also have a Code of Business Ethics (Code) and a Whistleblowing Policy and these standards and principles are embedded in our day-to-day activities and are covered in inductions for new staff and are reinforced through staff training. All employees undergo pre-employment vetting. We expect our suppliers to have fair employment practices too and our Procurement Policy sets out the expectations of our suppliers, which includes adherence to our Code. A supplier’s compliance with our Code is an important factor in forming or re-entering into a new relationship with a supplier and we carry out due diligence on our suppliers through the ongoing supplier management processes we have in place. Any breach of our Code may result in us terminating our arrangements with the supplier.

OUR SUPPLY CHAIN RELATIONSHIP

Key suppliers to the Group are the businesses which help us to run our premises and operations, which includes our catering and cleaning providers as well as, for example, our call centres, repairer networks and loss adjusters. This year we have incorporated clauses in our contracts with our existing repairers to create contractual obligations on repairers to comply with the Act. These clauses are also incorporated into our standard terms for all new repairer agreements. We strive to encourage the right behaviours by fostering long term relationships with our suppliers and, for example, by encouraging minimum standards to be met such as paying (at least) the voluntary UK Living Wage.

RISKS AND COMPLIANCE

We are committed to buying quality products and services from trusted suppliers and price is not our only driver. We meet formally with our key suppliers on a regular basis and also occasionally visit them at their own premises. This enables us to observe first hand their working conditions and have the opportunity to speak to workers directly. We have a contractual right to audit the performance and working practices of our suppliers in many cases, and monitor overall compliance with the Code.

Download the 2017 statement 

 

Modern Slavery Statement 2016

 

INTRODUCTION

We are a provider of insurance in the UK financial services sector and are the parent company of the esure Group (Group). We are committed to the highest standards of ethics and integrity and are committed to conducting our business in a lawful manner, which includes engaging with suppliers to ensure that they share our high standards.

As required by the Modern Slavery Act 2015 (the “Act”), this statement describes the steps which the Group has taken during the financial year ended 31 December 2016 to ensure that slavery and human trafficking is not taking place in any part of our own business or supply chains. 

OUR POLICIES

Our Code of Conduct sets out our core principles of our business ethics and demonstrates our commitment to fair employment practices in relation to our own employees. We also have a Code of Business Ethics and a Whistleblowing Policy and these standards and principles are embedded in our day-to-day activities and are covered in inductions for new staff and are reinforced through staff training. All employees undergo pre-employment vetting.

We expect our suppliers to have fair employment practices too and our Procurement Policy sets out the expectations of our suppliers, which includes adherence to our Code of Business Ethics. A supplier’s compliance with our Code is an important factor in forming or re-entering into a new relationship with a supplier and we carry out due diligence on our suppliers through the ongoing supplier management processes we have in place. Any breach of our Code may result in us terminating our arrangements with the supplier.

OUR SUPPLY CHAIN RELATIONSHIP

Key suppliers to the Group are the businesses which help us to run our premises and operations, which includes our catering and cleaning providers as well as, for example, our call centres, repairer networks and loss adjusters. We strive to encourage the right behaviours by fostering long term relationships with our suppliers and, for example, by encouraging minimum standards to be met such as paying (at least) the voluntary UK Living Wage.

RISKS AND COMPLIANCE

We are committed to buying quality products and services from ethical suppliers and price is not our only driver. We meet formally with our key suppliers on a regular basis and also occasionally visit them at their own premises. This enables us to observe first hand their working conditions and have the opportunity to speak to workers directly. We have a contractual right to audit the performance and working practices of our suppliers in many cases, and monitor overall compliance with the Code.

BOARD APPROVAL

The Directors of esure Group plc approved this statement on 17 May 2017.

 

Download the 2016 statement