ANTI SLAVERY STATEMENT


MCE Insurance Ltd is proud of the conditions of employment for all our people throughout the Company. Given the nature of our business, our board and management teams each consider that there is minimal risk approximating to no risk that, either within MCE Insurance Ltd or the very limited supply chains which support our business activities, that are in any way involved in or even tangentially supportive of, or complicit in slavery and human trafficking. The employment and procurement practices operated by the Company are rightly viewed as excellent and supportive. In addition, as a purchaser of goods and services we expect a high level of ethical conduct from those businesses with which we do business within our limited supply chain.

Organisation’s Structure & Activities

MCE Insurance Ltd is an independent insurance intermediary with its Head Office based in Rushden, Northamptonshire. The Company operates from three sites in Northamptonshire and has around 330 employees.

The Company is regulated and authorised by the Financial Conduct Authority. The Company 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.

Our Supply Chain

MCE Insurance Ltd’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 use a small number of professional service, estate maintenance and people providers.

MCE Insurance Ltd has zero tolerance to slavery and human trafficking and is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

This Anti-Slavery Policy Statement is the principal articulation of the MCE Insurance Ltd’s policy on slavery and human trafficking. It is intended to inform and influence all the operational procedures within the Company.

Our stated Anti-Slavery Policy Statement reflects our 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 or related supply chains.

Due Diligence

As part of our initiative to identify and mitigate risk (including in relation to that of human trafficking and slavery) we operate a range of policies and procedures appropriate to the Company. These include policy and procedures in the following 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 is in the process of policy development in the following areas:

  • Employee Code of Conduct
  • Foreign Contract Worker Policy
  • Training Policy

MCE Insurance Ltd also articulate a series or employee rights and benefits available to employees in its people policies and individual contracts of employment for each employee.

MCE Insurance Ltd operates a HR department led by the Head of People and a Compliance department and internal audit processes led by the Head of Compliance. The Company has a Chief Executive, Operations 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 MCE Insurance Ltd.

MCE Insurance Ltd 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 functions operates to help identify, assess and monitor potential risk

This is the first articulation of a formal Anti-Slavery Policy Statement for MCE Insurance Ltd. In future we will seek to ensure when entering into material contracts that all those in our supply chain and contractors comply with our stated Ani-Slavery Policy in particular when seeking tenders for service or when auditing our suppliers.

Training

We will communicate this statement and our Anti-Slavery Policy to all our people to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business and in future will include references as part of the Company’s, induction, training and information materials.

Legal and Regulatory Purpose of this Statement

This statement is made with regard to the obligations arising under section 54(1) of the UK’s Modern Slavery Act 2015 (the Act). MCE Insurance Ltd recognises the importance of these issues for all its stakeholders and accordingly this statement should be considered to constitute the slavery and human trafficking statement for MCE Insurance Ltd for the 2016/17 financial year and all future financial years until it may in future be modified or amended.

Julian Edwards

Chief Executive of MCE Insurance Ltd

Date: 1st November 2016