Modern Slavery & Human Trafficking Statement


This statement applies to MCE Insurance Ltd (referred to in this statement as ‘the Company’). The information included in the statement refers to the financial year ending 31st May 2018.

Organisational Structure & Activities

The Company is an independent insurance intermediary with its Head Office based in Rushden, Northamptonshire. The Company also operates from two further sites in the same county and has around 330 employees. It has a Board of Directors who control the day to day running of the Company.

The Company is regulated and authorised by the Financial Conduct Authority and operates principally in the United Kingdom but is licensed to offer its services in Ireland. It provides an intermediary service for general insurance and additional insurance related products.

The labour supplied to the Company in pursuance of its operations is carried out in:

  • United Kingdom
  • Ireland
  • Gibraltar
  • India
  • Philippines

Definitions

The Company considers that modern slavery encompasses:

  • Human trafficking
  • Forced work, through mental or physical threat
  • Being owned or controlled by an employer through mental or physical abuse or threat of abuse
  • Being dehumanised, treated as a commodity or being bought or sold as property
  • Being physically constrained or to have restriction placed on freedom of movement

Commitment

The Company acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Company understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Company does not enter into business with any organization, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Company in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in all countries that it sources labour from.

Supply Chain

The Company’s supply chains are limited. Insurance and insurance related products are purchased directly from a small number of approved suppliers. The Company offers insurance products through a small number of insurance aggregators as well as its own website and contact centre. The Company uses a small number of professional services, estate maintenance and labour providers.

This Statement reflects the Company’s commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing systems and controls to ensure (amongst our other priorities) that slavery and human trafficking is not taking place anywhere in our business, labour supply or other related supply chains.

Due Diligence

As part of the Company’s initiative to identify and mitigate risk, it operates a range of policies and procedures appropriate to the Company. These include policies and procedures in the following areas which are areas which are reviewed on a regular basis:

  • Modern Slavery Policy
  • Recruitment Policy
  • Grievance Policy
  • Whistleblowing
  • Anti-money laundering, bribery and financial crime

The Company also articulate a series of employee rights and benefits available in its people policies and individual contracts of employment for each employee.

The Company operates a People department led by the Head of People, a Governance and Resolution department led by the Head of Service and internal audit processes led by the Director of Compliance. The Company has a Chief Executive, Operation Director and Commercial Director who have reviewed and agreed to the terms of this statement. Each of these departments and executives have reporting responsibilities to management and the board of the Company.

The Company uses the services of Kreston Reeves Ltd as the external auditor and the Company receives annual update reports from the external and internal auditors. A combination of these procedures and the functions operates to help identify, assess and monitor potential risk.

The Company has not, to its knowledge, conducted any business with another Company which has been found to have involved itself with modern slavery.

Training

The Company communicates this statement and its Modern Slavery and Human Trafficking Policy to all its people to ensure a high level of understanding of the risks of modern slavery and trafficking in its business and supply chains.

Slavery Compliance Officer

The Company has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Company’s obligations.

Legal & Regulatory Purpose of this Statement

This statement is made with regard to the obligations arising under section 54(1) of the Modern Slavery Act 2015. The Company recognises the importance of these issues for all its stakeholders and accordingly this statement should be considered to constitute the Modern Slavery & Human Trafficking Statement for MCE Insurance Ltd for the 2017/18 financial year and all future financial years until it may in future be modified or amended.


Approved by:


Julian Edwards

Chief Executive

1st December 2017