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Zurich UK Modern Slavery and Human Trafficking Statement 2018

This statement has been published in accordance with the Modern Slavery Act 2015 (“the Act”) and in line with the Home Office statutory guidance. It sets out the steps taken by Zurich UK to ensure that its business and supply chains are slavery free. This statement applies to our practices for the financial year ending 31 December 2018 and continues to apply until any amendments are required. The statement will be subject to an annual review each year.

When we talk about “Zurich UK” in this Statement, we are referring to the companies within the Zurich Insurance Group which are in scope under Section 54 of the Modern Slavery Act 2015 and listed at Appendix 1.


We oppose modern slavery and human trafficking in all of its forms, and do not tolerate it within our business or within our supply chain.

Our commitment to respect human rights is part of our Group’s Code of Conduct, which all of our employees are committed to following. We respect the protection of international human rights within our sphere of influence, and work hard to ensure we are not complicit in human rights abuses. Zurich became a signatory to the United Nations Global Compact in 2011, which means we are committed to aligning our strategy, culture and day-to-day operations with the Global Compact’s ten universally-accepted principles in the areas of human rights, labour, environment and anti-corruption. Six of the ten UN Global Compact principles relate to human rights and Principle 4 specifically commits us to the elimination of all forms of forced and compulsory labour.

Organisational Structure

Zurich Insurance Group is a multi-line insurer that serves its customers in global and local markets. With about 54,000 employees, it provides a wide range of property and casualty, and life insurance products and services in more than 210 countries and territories. Customers include individuals, small businesses, and mid-sized and large companies, as well as multinational corporations. The Group is headquartered in Zurich, Switzerland, where it was founded in 1872. Further information about Zurich is available at

Our business and supply chains in the UK

Zurich in the UK provides a suite of general insurance and life insurance products to retail and corporate customers. We supply personal, commercial and local authority insurance through a number of distribution channels, and offer a range of protection, retirement and savings policies available online and through financial intermediaries for the retail market and via employee benefit consultants for the corporate market. Based in a number of locations across the UK - with large sites in Birmingham, Farnborough, Glasgow, London, Swindon and Whiteley - Zurich employs approximately 6,000 people in the UK.

Zurich UK operates in a sourcing environment that includes third parties and outsourcing arrangements. We deal with market leading expert suppliers and have robust procurement processes and control oversight in place, delivered through a mature assurance model. We have zero tolerance to slavery and human trafficking and expect that those in our supply chain comply with Zurich’s values.

Our policies applicable to slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or supply chains. As part of our initiative to identify and mitigate the risk of slavery and human trafficking in our business, all Zurich UK employees are required to meet the standards set within our Anti-Slavery and Human Trafficking Policy which reflects our commitment to:

  • Act ethically and with integrity in all our business relationships; and,
  • implement and enforce effective controls to mitigate the risk of slavery and human trafficking taking place anywhere in our supply chains.

Our Reporting Concern’s Policy supports employee’s to confidentially report suspected, potential or actual concerns, in good faith, including illegal or unethical conduct.

Our Corporate Responsibility strategy aims to create value for both our company and for society as a whole. We use our core skills, risk and investment management expertise, to have a positive impact on both. For more information about the Zurich's commitment to Corporate Responsibility and the Trust's work, please visit our website here.

Due diligence processes in relation to slavery and human trafficking

We have systems in place to identify and assess potential risk areas in our supply chains.

Our established procurement process is in place to support with the on-boarding of third parties, which includes a rigorous due diligence process. This process includes using hard data to assess potential financial, legal and regulatory exposures of the potential transaction. It also gives insight into the third party’s structure, operations, culture, human resources, supplier and customer relationships, competitive positioning and future outlook. We have processes in place to:

  • Identify and assess potential risk areas in our 1st tier supply chains;
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains;
  • Monitor potential risk areas in our supply chains; and
  • Protect whistle-blowers

A governance framework is in place and has been designed to support every step of the supply management lifecycle to ensure effective and efficient management our suppliers. The framework takes into account industry best practice & methodologies, Zurich’s internal policies as well as legal and regulatory requirements applicable to outsourcing and supplier management and is updated on a continuous basis. Zurich assesses our directly contracting suppliers in line with this framework and only retains suppliers who comply with our core competencies.


Zurich's Code of Conduct is built around the recognition that everything we do is in accordance with the highest ethical, legal and professional standards. Our annual Code of Conduct training is completed by all Zurich staff and includes content around fair and compliant conduct, including the protection of human rights. We require directly contracted business partners to meet the standards within our Code of Conduct.

Our effectiveness in combating slavery and human trafficking

Zurich has measures in place to assess the business or supply chain in complying with our stance on slavery and human trafficking, including:

  • The number of employees trained through our Code of Conduct; and,
  • Identification of any risk areas in our 1st tier supply chain

Further Steps

Following a review of the effectiveness of the steps we have taken in 2018 to ensure that there is no slavery or human trafficking in our supply chains we intend to take further steps to combat slavery and human trafficking, including continuing to review and update our:

  • Our internal HR policies and processes
  • Our internal training and support materials
  • Our procurement and governance processes that oversee our supply chain

This Statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Zurich UK’s slavery and human trafficking statement for the financial year ending 2018.


Tulsi Naidu
CEO, Zurich UK
May 2019

The boards of the relevant Zurich UK entities approved this statement between May and June 2019.

Appendix – Zurich companies in scope of Section 54 of the Modern Slavery Act 2015 and the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015

Zurich Insurance plc, Zurich Insurance plc (UK Branch), Zurich Assurance Ltd, Sterling ISA Managers Limited, Zurich Employment Services Limited, Zurich Management Services Limited, Access Franchise Management Limited, Allied Dunbar Assurance plc, Allied Dunbar Healthcare Marketing, Allied Zurich Holdings Limited, Ashdale Land & Property Company Limited, Dunbar Assets Ireland Unlimited Company, Dunbar Assets plc, Eagle Star (Leasing) Limited, Eagle Star Holdings Limited, Eagle Star Securities Limited, EFS Financial Services Limited, Employee Services Limited, Zurich Global Corporate UK Limited, Zurich UK General Employee Services Limited, Zurich UK General Services Limited, Endsleigh Pension Trustee Limited, Grovewood Property Holdings Limited, Oak Underwriting plc, Tennyson Insurance Limited, The Liverpool Reversionary Company Limited, ZPC Capital Limited, Zurich (Scotland) Limited Partnership, Zurich Advice Network Limited, Zurich Building Control Services Limited, Zurich Community Trust (UK) Limited, Zurich Finance (UK) plc, Zurich Financial Services (UKISA) Limited, Zurich Financial Services EUB Holdings Limited, Zurich General Partner (Scotland) Limited, Zurich Holdings (UK) Limited, Zurich Intermediary Group Limited, Zurich Investment Services (UK) Limited, Zurich Legacy Solutions Services UK Limited, Zurich Pension Trustees Limited, Zurich Project Finance (UK) Limited, Zurich Specialities London Limited, Zurich Transitional Services Limited, Zurich Whiteley Investment Trust Limited, Zurich Whiteley Trust Limited, ZGEE 16 Limited, Allied Zurich Limited, Zurich Insurance Company (UK) Limited