Modern Slavery

This statement covers the activities of Uinsure Limited and is our Modern Slavery and Human Trafficking statement for the financial year ended 31st March 2024. Uinsure is not required to produce and update an annual statement under UK law, however it chooses to regardless.

Modern slavery in all its forms of slavery, forced or compulsory labour and human trafficking will not be tolerated within our own operations or our supply chain. We are committed to doing our part to help stamp out modern slavery and are taking the appropriate steps to ensure that everyone who works for Uinsure benefits from a working environment in which their fundamental human rights are respected and anyone that we do business with also upholds these principles.

Background

We provide a wide range of insurance products and services to businesses and consumers and carry out insurance-related activity are authorised and regulated by the Financial Conduct Authority. We are committed to managing our business operations sustainably, reducing our impact on the environment and having a positive impact on the communities we work in.

Assessing our risks

We review our policies on an annual basis to ensure they remain fit for purpose, managing risks and reflecting good practice.

Supporting policies

The following company policies support us in ensuring that modern slavery is not taking place in our supply chains or business:

• Third Party Contracts & Outsourcing Policy: ensures robust standards and processes are in place across our business to manage risks relating to the Uinsure’s contracts with third parties, including supplier selection, contracting and ongoing management. The Policy sets out controls to comply with regulatory and legal requirements and ensures that appropriate assessment of risks associated with services are undertaken to meet human rights commitments.
• Employment Practices Policy: sets out the minimum standards for how we recruit, manage and support our people in a working environment that promotes diversity, respect, integrity, safety and wellbeing. The policy also stipulates that, where there is inappropriate conduct, we will take disciplinary action, which may include termination.
• Whistleblowing Policy: encourages our people to raise concerns, without fear of retaliation, about how both Uinsure and its suppliers do business or operate as an employer. We provide numerous ways for concerns to be raised: in person to a line manager or Human Resources, or online or by phone to an independent reporting channel. In all cases, we treat concerns seriously, confidentially and provide the option for them to be raised anonymously. In addition, should an employee be concerned about how they are personally treated at work, sometimes referred to as a ‘grievance’, they are encouraged to raise this with their line manager and processes are in place for these to be fairly investigated.

These policies apply to Uinsure and, under the governance of our Risk Management Framework and Board Risk Committee, reinforce how we identify, measure, manage and control related risks, including those related to modern slavery.

Our People

To ensure that we recruit and treat colleagues fairly, avoiding modern slavery at all costs, our Employment Practices Policy requires appropriate human resources procedures to be in place throughout Uinsure. These procedures make sure we seek to:

• Recruit, select and screen individuals in a fair, lawful and professional manner;
• Treat all people fairly while working for us; and
• If there is an occasion when an employee does not feel that they have been treated fairly, there are procedures in place to raise concerns.

We make our people aware of our policies and of their employment rights in several ways including: intranet sites, company inductions and written employment offers.

In recognition of the heightened human rights and modern slavery risk at recruitment stage, our Employment Practices Policy stipulates the standards for fair and lawful processes, including checks of candidates’ right to work, integrity and suitability for the role. Our approach applies to all employees and temporary workers, including the use of agency workers.

Our policies and belief in a fair and inclusive culture and ways of working come alive through our Uinsure Values and performance management processes where employee ratings are based not only on what is delivered, but also on how. We regularly assess our Culture Health through a combination of key indicators and employee surveys. Our aim is to identify and manage risks that may lead to a failure of ethics, controls, or governance before they occur; slavery and human trafficking would be picked up as a potential issue through this assessment.

All colleagues are required to complete an e-learning module on whistleblowing which provides guidance on how to raise concerns in a secure and confidential way. The e-learning helps to raise awareness of modern slavery and human trafficking and the signs to spot. If a colleague has any concerns that they want to bring to the attention of the business, including concerns about slavery and human trafficking, they should raise these with a line manager, HR representative or Chief Governance Officer. Through our formal channels of reporting there were no cases of human rights issues raised in 2023.

We comply with the relevant law and regulation regarding paying a minimum wage. Within the UK, everyone working for Uinsure receives the Living Wage, which is reviewed annually.

Our suppliers

We choose to work with partners that hold the same high standards as Uinsure, deliver high-quality products and services, and respect the communities and environment in which they operate. This includes partnering with suppliers who take ethical conduct seriously – providing safe working conditions, treating workers with dignity and respect, acting fairly and ethically and using environmentally responsible practices where practicable.

Our Third-Party Contracts & Outsourcing Policy establishes the requirements for due diligence on suppliers, supplier selection, contracting and ongoing management.

We assess supplier risk before appointment and facilitate monitoring of ongoing supplier relationships. We work with a third-party supplier information to gather information on management practices on a range of subjects including labour practices, human rights, diversity and inclusion and anti-bribery and corruption which is used within our due diligence process. Suppliers are asked for their policies and to confirm the actions they take to manage human rights and modern slavery risks; this provides a risk score which is used to determine whether further engagement or action is required. Oversight of this process is provided by our compliance team.

We ask our suppliers to reconfirm their answers to these questions annually. In addition to our annual due diligence assessments, our regular supplier relationship management process covers a range of topics including responsible business practices.

In standard service agreements and commercial contracts Uinsure sets out its expectations on the environmental, social and governance standards we expect our suppliers to comply with. Where we suspect a breach or become aware of a case of modern slavery, we will work with the supplier to implement remedial action. Uinsure reserves the right to terminate a relationship with a supplier or third party that are unable to demonstrate compliance or progress towards the eradication of modern slavery within their organisations and supply chain.

Training

We ensure employees attain and maintain the skills and knowledge required for their role as well as completing all required mandatory training on topics that are fundamental to upholding our values. Uinsure employees receive training on a variety of topics that support our stance on human rights and modern slavery, including diversity & inclusion, conduct, supplier management, whistleblowing and bribery and corruption.

Brionie Hemingway
Chief Governance Officer
31st July 2024