Standing up for what’s right
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps that Ageas (UK) Limited (Ageas UK) has taken to make sure there’s no slavery or human trafficking in our business or supply chain.
This statement relates to the financial year 1 January 2016 to 31 December 2016, and to the activities of Ageas UK and our subsidiaries, including Ageas Insurance Limited, Ageas Retail Limited and Tesco Underwriting Limited.
Our approach to human rights
Respect for human rights is one of the principles we operate to across the world. Our Principles of Business Conduct are set out in our Corporate Governance Charter and state that: “We are of the opinion that respect for human rights, as described in the Universal Declaration of Human Rights of the United Nations of 1948, is a condition for maintaining a sustainable society. We apply the relevant human rights principles in our relationships with employees and we acknowledge our responsibility for promoting the application of human rights whenever we, as a private enterprise, are in a position to make a meaningful contribution to this cause.”
The people in our business
All our people based in the UK are engaged in the development, sale and administration of insurance products. For this reason, we don’t consider there to be a high risk that the people in our business are the victims of modern slavery or human trafficking. Nevertheless, we have policies in place that are intended to make sure they’re not.
We have procedures in place to make sure that only people with the right to work in the UK are employed in our business. These are set out in our Employee Vetting Policy, which is reviewed every year. During our recruitment process, identity and right to work documentation is required, in line with Home Office guidelines. Where we employ people on a temporary basis using recruitment agencies, the agency is required to carry out the appropriate right to work and reference checks on our behalf.
Suppliers to our business
We use a wide variety of suppliers. Like most large businesses, we engage with suppliers of facilities management services, such as catering and cleaning providers. As an insurer, we also engage with suppliers of goods and repair services where customers’ property has been lost or damaged, and medical and assistance services where customers have suffered accident or injury. We recognise there’s a risk that modern slavery and human trafficking may occur in supply chains of this nature.
We have procedures in place to ensure oversight of the selection and management of all our third-party suppliers. These cover the due diligence process, contractual requirements, and continuous relationship management. During the course of 2016, the due diligence process was extended to cover suppliers’ recruitment of staff and compliance with the Modern Slavery Act. Where appropriate, provisions were also included in contracts that requested suppliers to comply with the Modern Slavery Act and to provide information on request regarding such compliance.
Plus, during the course of 2016, we’ve communicated with our existing facilities management and claims fulfilment suppliers to highlight the policies and procedures that we expect them to have in place to make sure there’s no slavery or human trafficking within their businesses or supply chains. The letter also requests that they tell us if they suspected a breach of the Modern Slavery Act.
Our procedures ensure our employees can raise any concerns about wrongful behaviour within our business, including in relation to ethical standards, without fear of reprisal. These procedures are described in the Ageas UK Whistleblowing Policy, which is reviewed at least one a year. Ensuring the independence, autonomy and effectiveness of the whistleblowing procedures in place, including those for the protection of staff raising concerns, is the responsibility of our Chair of the Audit Committee.
Safeguarding our continuing compliance
Ageas UK has procedures in place to ensure continuing compliance with the policies referenced in this statement. Ageas UK’s Compliance department monitors adherence to the policies and applicable legislation and guidance.
Ageas (UK) Limited
28th April 2017