This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Admiral Group Plc and other relevant group companies1 (‘Admiral’ or ‘Group’) during year ending 31 December 2016 to prevent modern slavery and human trafficking in its business and supply chains.
This is the first articulation of a formal Modern Slavery Statement for Admiral.
Slavery, servitude, forced labour and human trafficking (Modern Slavery) is a global and growing issue, existing in every region in the world and in every type of economy, whether industrialised, developing or in transition. No sector or industry can be considered immune.
We support the aims of the Act and seek to ensure slavery and human trafficking does not feature in our business or supply chain. We run our business in a responsible manner and our employment practices provide a foundation for operations which are viewed as excellent and supportive employers. To the extent that the Group operates as a purchaser of goods or services we expect a high level of ethical conduct from those businesses with which we do business. We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain. Employees are expected to report concerns, using the appropriate reporting channels, and management are expected to act upon them.
Our organisation and business
Admiral Group Plc is the holding company for a group of companies providing insurance and ancillary products and services. Admiral is incorporated in the UK and is listed on the UK Stock Exchange. The companies within the Group are either regulated insurance or service companies or serve a purpose ancillary to the Group’s principal activities in insurance. Admiral operates from its Head Office in Cardiff in the UK and has over 9,000 employees worldwide. Admiral operates principally in the UK but is licensed to underwrite insurance business in Europe and the United States of America. Further details of Admiral’s structure can be found on our website (https://admiralgroup.co.uk)
Our supply chain
Our supply chain is varied and includes direct (claims settlement) and indirect supplies. We provide insurance and ancillary products and services in the UK and internationally and, in addition, use services in India and Canada to support these operations. We do not act as a manufacturer or retailer of physical goods.
Policies and contractual controls
Admiral internal policies include our General Standards of Conduct and our Anti-Fraud and Suspicious Events Policy, Anti-Bribery Policy, Equality, Diversity and Dignity at Work Policies where we confirm we expect staff to act with honesty and integrity and comply with all relevant legislation and requirements. In addition, during 2017 Admiral has introduced an Anti-Slavery Policy to advise all employees of our commitment to eliminating unethical working practices. It will also provide guidance on who to contact should they spot a problem not just at work, but in their local community. We also operate a Whistleblowing Policy, aimed principally at our employees but also available to others working in our supply chain which encourages staff to report any wrongdoing which extends to human rights violations like Modern Slavery. All reports are fully investigated and appropriate remedial actions taken.
Our policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to minimise the risk of Modern Slavery taking place in our business or related supply chain.
Risk assessment, due diligence, suppliers and supply chain
We have developed a risk assessment process to assess the likelihood of modern slavery occurring in our supply chain which takes into account a number of factors including geographic location, nature of goods and services being supplied, supply chain length and the use of temporary or migrant labour. The risk assessment process allows us to identify potential areas of concern within our supply chain.
During the year our approach to preventing Modern Slavery in our supply chain has been enhanced with the appointment of a Head of Procurement and the development of a Procurement Policy.
The Procurement Policy sets out supplier due diligence requirements and requires suppliers to comply with the Procurement Policy including:
• providing employees with good working conditions, fair treatment and reasonable rates of pay; and
• respecting workers’ human rights and complying fully with all applicable laws.
Modern Slavery training
We will communicate this statement to all our staff to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chain and our business. The Group’s training team have been trained on Modern Slavery and have developed awareness training to be included as part of our compulsory induction and ongoing compliance training for all employees.
In addition, and recognising the extremely complex nature of Modern Slavery, we continue to emphasise the importance of collaboration with others and have participated in government consultations on the Modern Slavery Act.
Assessment of effectiveness in preventing Modern Slavery
We understand that Modern Slavery risk is not static, and will continue our approach to mitigating this risk in the year ahead.
In order to assess the effectiveness of the measures taken by Admiral we will be reviewing the following key performance indicators and reporting on them in future Modern Slavery Statements:
• staff training levels; and
• investigations undertaken into reports of Modern Slavery and remedial actions taken in response.
This statement was approved by the Boards of Admiral Group plc, Admiral Insurance Company Limited, EUI Limited and Inspop.com Limited.
This statement sets out the steps taken by Admiral Group plc, Admiral Insurance Company Limited, EUI Limited and Inspop.com Limited, all of which fall within the scope of section 54(2) of the Modern Slavery Act 2015 and the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015. Admiral subsidiaries that are not required to comply with the requirements are required to follow Group guidance.