Modern Slavery Statement
MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR THE FINANCIAL YEAR 2022
Cirencester Friendly Society Limited (Cirencester Friendly) find all and any instances of modern slavery or human trafficking to be abhorrent and will seek to ensure that it does not occur in our organisation, our distribution partners, or our suppliers.
This statement is made pursuant to s.54, Part 6 of the Modern Slavery Act 2015 (“the Act”) and sets out the measures that we are taking to ensure that modern slavery and human trafficking are not taking place within our business or supply chains.
The expression ‘Modern Slavery’ covers slavery, servitude, human trafficking and forced labour. Cirencester Friendly has a zero-tolerance approach to any form of modern slavery. We are committed to always acting ethically, with integrity and transparency in our business dealings. We have implemented robust, effective systems and controls that will ensure we will have:
- Supply chain transparency
- A clear understanding of the risks in our business
- Effective means to avoid, anticipate and correct any instances of modern slavery
A. Cirencester Friendly Structure
We are a Friendly Society, registered and incorporated under the Friendly Societies Act 1992. We are authorised by the PRA and regulated by the FCA and PRA.
Business We are a mutual financial services organisation offering income protection insurance to individuals across the UK. Our products are distributed by regulated financial services intermediaries and Appointed Representatives. All our business is conducted within the UK. We employ around 100 employees and operate from offices in Cirencester.
Supply Chains Our supply chains are relatively simple, and the nature of the goods and services procured provides only limited opportunities for modern slavery and human trafficking practices. We do not act as a producer, manufacturer or retailer of physical goods and we have no supply chain in relation to such activities.
Our supply chains include:
- Office services, equipment, furniture or consumable supplies
- Marketing and promotional literature and/or merchandise
- IT and electronics equipment and/or services
- Courier and delivery companies
- Catering providers
- Cleaning service providers
- Professional service providers
- Printing companies
Given the nature of what we do, it is considered that there is a low risk of modern slavery and human trafficking having a connection with our business activities, however we have taken, amongst others, the steps detailed below to ensure compliance with the Act. We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
- Recruitment Policy: We operate a robust Recruitment and Selection Policy and proper hiring procedures, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. We are committed to ensuring that all directly employed and contracted employees receive fair remuneration for the job they perform.
- Whistleblowing Policy: We operate a Whistleblowing Policy so that all employees know that they can raise concerns about fair treatment of colleagues or practices within our business or the businesses of our suppliers, without fear of reprisals or repercussions.
- Procurement and Material Outsourcers & Third Party Arrangements Policies: We operate a Procurement Policy which operates in conjunction with the Material Outsourcers & Third Party Arrangements Policy. The Board of Directors has ultimate responsibility for ensuring that all policies and procedures are implemented. They are also responsible for all wider issues relating to Environmental, Social and Governance (ESG).
C. Due Diligence
Due diligence requires that action is taken that it is generally considered to be reasonable to ensure that our supply chains are free of the taint of modern slavery and human trafficking.
We have undertaken a review of our procurement processes and have identified opportunities to embed both the assessment and reduction of risks of modern slavery and human trafficking in our supply chains into our operations.
D. Risk Assessment
We have assessed our risk of modern slavery and human trafficking in our organisation and supply chains as low on the basis that:
- our distribution channels are regulated financial services intermediaries and Appointed Representatives;
- our business is conducted in the UK;
- we have relevant policies and procedures in place.
We can report that we have not detected nor received reports in the last 12 months of any instances of modern slavery and human trafficking.
We do not believe that instances of modern slavery and human trafficking exists in our supply chains. We cannot categorically confirm this to be the case, but we believe that our policies and procedures are appropriate and reasonable in mitigating the risk of modern slavery and human trafficking.
We will continue to monitor the effectiveness of the steps that we are taking to ensure that modern slavery and human trafficking are not taking place within our business or supply chains.
Our Risk Management Framework requires a risk culture to be embedded within every part of the business: marketing, sales, distribution, procurement, operations, technology, HR and logistics. Regular training is provided to relevant employees to ensure awareness of our applicable policies and our expectations of them.
We will continue to interact with appropriate organisations such as the Association of Financial Mutuals, industry thought leaders and attend, where practical, relevant conferences in person or online. This is to ensure that we have continuous benchmarking and a strong understanding of what current industry expectations are.
Approval for this statement This statement was approved by the Board of Directors on 9 February 2023.
Chief Executive Officer