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This Anti-Slavery and Human Trafficking Statement (the “Statement”) is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Fidelis Group’s slavery and human trafficking statement for the financial year ending 31 December 2019.
Fidelis Insurance Holdings Limited is the holding company of the Fidelis Group which provides insurance and reinsurance services on a global basis. The companies within the Fidelis Group are either regulated insurance and/or reinsurance companies or service companies or serve a purpose ancillary to its principal insurance and/or reinsurance activities. Fidelis Insurance Holdings Limited has its registered office in Bermuda. There are approximately 100 employees across the Fidelis Group which operates in Bermuda, Republic of Ireland and the UK.
The Fidelis Group has zero tolerance to slavery and human trafficking and is committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.
This Statement contains the Fidelis Group’s vision and commitment to be a responsible organisation in the insurance industry to combat slavery and human trafficking. We have devised a robust operational procedure to ensure that our values and ethics are integrated into our operations and to prevent slavery and human trafficking. We provide more detail on these steps below.
In 2018, Fidelis has become the first financial services company to sign up to the Anti-Slavery Charter.
The Anti-Slavery Charter sets out basic measures that states, NGOs, businesses and societies must take to end slavery across the globe. As a business committed to preventing slavery and human trafficking, Fidelis pledges to using its power to empower those vulnerable to slavery, to advance emancipation, and to promote access to decent work.
As part of our commitment to the Anti-Slavery Charter, the Fidelis Group has established a robust due diligence process to ensure that the recruitment agencies we work with are adhering to the basic standards of human rights protections.
Detail of the Anti-Slavery Charter can be found here:
We have received confirmation from Anti-Slavery International that there has been no change to the Anti-Slavery Charter in 2019.
To ensure an understanding of the risks of modern slavery and human trafficking in supply chains, we have conducted compulsory compliance training for all staff, both in London and Bermuda, in respect of modern slavery and the Fidelis Group’s Anti-Slavery and Human Trafficking statement for the year ending 31 December 2019. Annual training will be provided in respect of each annual statement. In 2020, we will continue this training for all staff in our London, Dublin and Bermuda offices. All staff have also been provided with a copy of this statement to raise awareness.
OUR SUPPLY CHAINS
The Fidelis Group is a provider of insurance and reinsurance services and the Fidelis Group engages with brokers on a global basis. The Boards of the Fidelis Group companies consider that the risk of it or its supply chains being involved in or complicit in slavery or human trafficking is very low due to the nature of the services. The Fidelis Group is not involved in the activities of producing or manufacturing goods which typically involve supply chains which can be susceptible to this risk. There is a risk, however, that whilst not being within its supply chains in the everyday sense, insurers can become involved and thereby complicit, by virtue of their insurance of supply chains or development projects, which could involve slavery or human trafficking.
As such, the Fidelis Group has been driving an initiative, in cooperation with a number of London market brokers and underwriters, to produce a model clause in marine cargo insurance contracts to mitigate the risk of inadvertently supporting slavery or human trafficking in the insured supply chains. In 2019, the Fidelis Group has continued its work to try to mitigate this risk by seeking to exclude coverage under marine cargo insurance contracts for goods produced by forced, slave or child labour. The work has expanded to incorporate major brokers and following pro bono advice from a leading insurance law firm, a new approach has been agreed in principle. For 2020 Fidelis will use its best efforts to advocate for the adoption of the clause.
The Fidelis Group also mitigates the risk of insuring development or construction projects which could involve slavery or human trafficking by its standard underwriting process which requires its underwriters to be satisfied that the highest social and environmental standards are upheld before it underwrites such risk. If the underwriter is not satisfied that these standards are met, Fidelis will not underwrite the risk.
The Fidelis Group procures services in areas including catering, cleaning, IT support, IT software development, investment management and actuarial consultancy. We have taken steps to confirm with the property manager for our UK premises, from whom we procure cleaning and other building services, their procedures for mitigating the risk of slavery and human trafficking in their supply chains, and are satisfied with their compliance. The managing company of our Bermuda premises has confirmed that while it is not subject to the Modern Slavery Act 2015, its policies reflect the same philosophy and standards in relation to its staff and the procurement of services. The managing company of our new Dublin office has also confirmed its compliance and that it has adequate procedures in place to ensure that all of its third party suppliers comply with the applicable anti-slavery and human trafficking laws. We have taken steps to include a clause into our material service contracts to ensure that compliance with anti-slavery and human trafficking law is embedded in our relationships, beginning with our actuarial consultancy and IT software development services contracts, to raise awareness and to oblige our service providers to ensure there is no slavery or human trafficking in their businesses or supply chains. We are satisfied that our investment managers share our philosophy of having a zero tolerance to modern slavery and human trafficking and are committed to mitigate the risk of modern slavery and human trafficking in their businesses and supply chain.
In 2019, we have embedded in our centralised IT procurement process a procedure to vet all IT service providers who are not only compliant with the applicable modern slavery and human trafficking laws, but also taking positive actions to mitigate the associated risks in their business and supply chain. In 2020, we shall continue to assess the risks associated with our procured services and if appropriate, expand the scope of our assessment as our business continues to grow.
All employees continue to be contractually required to behave in a professional manner and not bring the company into disrepute; this is inclusive of the approach to engaging suppliers. Additionally, employees are required to uphold the Fidelis Group’s ethos which acts as a set of guiding principles in how to conduct business activities.
This Statement is the principal articulation of the Fidelis Group’s policy on slavery and human trafficking and is intended to inform and influence all the operational procedures within the Fidelis Group. In order to identify and mitigate potential risk areas, including risk of slavery and human trafficking in our supply chains, we operate a range of policies and procedures, including the following:
Our Compliance function provides regular training on the above policies and procedures to all staff and new joiners. The Group Compliance Officer monitors compliance with these policies, which is reinforced by the Internal Audit function.
Whilst reputable employment agencies are engaged to source candidates, the Fidelis Group’s Human Resources function carry out checks to ensure that employees have the right to work and are protected by relevant employment legislation.
We also expect all our staff to enjoy the following basic rights:
By stating its clear policy in this Statement and by ensuring its staff’s awareness of modern slavery as a result of the training described above, the Fidelis Group is able to effectively mitigate against the risk of slavery and human trafficking within the context of its limited supply chain. In addition to staff awareness when engaging suppliers, the adoption of the Fidelis Group’s Anti-Slavery and Human Trafficking policy in its material service contracts is effective in placing a contractual obligation on Fidelis’ counterparties. The effectiveness of the steps to introduce a clause to marine cargo insurance contracts making payment of claims conditional upon insureds meeting their obligations under the existing Trade legislations, whilst not yet implemented, shall be actively monitored.
Richard Brindle, Group Chief Executive Officer
Date: 3 March 2020