Zurich modern slavery statement 2016/17
This statement has been published in accordance with the Modern Slavery Act 2015 (“the Act”). It sets out the steps taken by Zurich Insurance Group and its subsidiaries1 (“Zurich”) that conduct business in the UK. This statement has applied to our practices for the financial year ending 31 December 2016 and continues to apply until any amendments are required. The statement will be subject to an annual review in June each year.
Introduction from Tulsi Naidu, CEO, Zurich UK
Our commitment to respect human rights is part of Zurich Basics, our Group’s code of conduct, which all of our employees are also 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 abuses. Zurich signed up 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. 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.
Structure of Zurich and our business
Zurich Insurance Group is one of the world’s largest insurance groups, and one of the few to operate on a truly global basis. We have more than 130 years’ experience of giving people the financial answers they are looking for, and you will find us in more than 210 countries and territories; and to make sure that help’s always there, we have about 54,000 employees worldwide, including 6,500 in the UK. We offer products and services across a range of businesses and markets all over the world. In the UK, Zurich provides a suite of general insurance and life insurance products to retail and corporate customers. These include personal, commercial and local authority insurance offered through a number of distribution channels, and 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. The Group delivered a business operating profit of $4.5 billion in 2016.
Our policies on 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. Our Anti-slavery Policy reflects our commitment to:
- Acting ethically and with integrity in all our business relationships; and,
- Implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Our supply chains
Zurich operates in a sourcing environment that includes third parties and outsourcing arrangements. We deal with market leading expert suppliers and have robust control oversight in place, delivered through a mature assurance model.
To ensure those in our supply chain and contractors comply with our Zurich values, we have in place a supply chain programme. Zurich assesses our directly contracting suppliers in line with this programme and only retains suppliers who comply with our core competencies.
We have systems 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.
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk, Zurich has developed a Policy & Best Practice guidance to demonstrate our adherence to all internal requirements and regulatory requirements when we use third parties. We have an established procurement process 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.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and supply chains, we provide training to our staff on an annual basis. We require directly contracted business partners to provide training to their staff ensuring the same level of understanding.
Our effectiveness in combating slavery and human trafficking
Zurich will introduce measures to assess the business or supply chain in complying with our stance on slavery and human trafficking. These include:
- The number of employees trained through Zurich Basics; and,
- The number of suppliers who provide confirmation that they are compliant with the Modern Slavery requirements set out by the Act.
Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains, we intend to take the further steps outlined below:
- Identify and assess potential risk areas in our 1st tier supply chains;
- Arrange site visits for top risks; and,
- Provide additional training to teams reviewing Modern Slavery risks throughout the supply chain to ensure identification of risk areas and mitigation.
CEO, Zurich UK
1 This statement sets out the steps taken by Zurich (see Appendix for UK Trading companies) 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.
Appendix – UK Trading Companies
Access Franchise Management Limited, Allied Dunbar Assurance plc, Allied Dunbar Healthcare Marketing Limited, Allied Zurich Holdings Limited, Ashdale Land and Property Company Limited, Dunbar Assets plc, Eagle Star (Leasing) Limited, Eagle Star Estates Limited, Eagle Star Holdings Limited, Eagle Star Insurance Company Limited (now Zurich Legacy Solutions Services UK Limited), Eagle Star Securities Limited, Employee Services Limited, Grovewood Property Holdings Limited, Sterling ISA Managers Limited, Tennyson Insurance Limited, The Liverpool Reversionary Company Limited, ZPC Capital Limited, Zurich Advice Network Limited, Zurich Advice Solutions (UK) Limited, Zurich Assurance Ltd, Zurich Building Control Services Limited, Zurich Community Trust (UK) Limited, Zurich Employment Services Limited, Zurich Finance (UK) plc, Zurich Financial Services (UKISA) Limited, Zurich Global Corporate UK Limited, Zurich Group Pension Services (UK) Limited, Zurich Holdings UK Limited, Zurich Insurance plc, Zurich Insurance plc (UK Branch), Zurich Intermediary Group Limited, Zurich Investment Services (UK) Limited, Zurich Management Services Limited, Zurich Pension Trustees Limited, Zurich Pensions Management Limited, Zurich Project Finance (UK) Limited, Zurich Specialties London Limited, Zurich Transitional Services Limited, Zurich UK General Employee Services Limited, Zurich UK General Services Limited, Zurich Whiteley Investment Trust Limited, Zurich Whiteley Trust Limited.