Introduction and scope
Modern Slavery is a term used to encompass slavery, servitude, forced or compulsory labour and human trafficking. Modern Slavery is a crime and a violation of human rights. This statement is published by Charles Taylor Limited and extends to all our wholly and majority owned entities within the Charles Taylor Group (the “Group” or “Charles Taylor”). Charles Taylor Limited is a UK domiciled private limited company. In January 2020 Charles Taylor was acquired by an investment company managed and controlled by Lovell Minnick Partners LLC (‘Lovell Minnick’). Lovell Minnick is a US Private Equity firm that invests in the global financial services industry, including related technology and business services companies, with a focus on helping to build long term value for clients, employees and shareholders.
Lovell Minnick recognises the importance of investing responsibly, with sensitivity to environmental and social concerns. This includes avoiding investments in businesses that are known to utilise child or forced labour or maintain unlawful discriminatory employment policies.
This Modern Slavery and Human Trafficking statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 (the “Act”). It sets out the Group’s approach, governance and actions to combat Modern Slavery in its various forms.
Charles Taylor is committed to upholding its responsibilities to our people, those we come into contact with the communities in which we work and the environment. We maintain a high standard of business ethics. We respect and support the protection of human rights in all our business units irrespective of domicile or place of operation.
This commitment requires us to assess human rights risks in all our businesses and resulting from our operations, considering equality, corruption and bribery, child labour, forced labour, slavery and trafficking, non-discrimination, health and safety and working conditions
Organisation, Markets and Structure
The Group is a global provider of professional services and technology solutions to the insurance market. Insurance is a global business and the Group has offices located across the globe to provide services and solutions to our clients wherever they are needed. We operate through several business units organised under three areas: -
The Company operates globally in 120 locations in 30 countries. Full details of our office network can be found under Locations.
The Board of Directors of Charles Taylor Limited is responsible for the Group’s overall strategy and business model. It sets the tone from the top for how we do business. The Executive Committee is responsible for the day to day running of the business and draws its members from core areas of Group management. It comprises senior executives with management responsibilities for individual trading businesses, and representatives of Group functions such as legal, human resources and corporate development.
The Group Chief Operating Officer (Richard Yerbury) is responsible for the Group meeting the standards set out in this statement.
The Group’s risk management framework and processes are designed to identify, evaluate and manage the risk of the Group not achieving its business objectives or incurring losses. The key aspects of the Group’s control activity in relation our various legal, regulatory and policy-related obligations are as follows:
The application of each of the above areas of control activity to the area of Modern Slavery and Human Trafficking is outlined below.
Our Policies relating to Modern Slavery and Human Trafficking
The Group has a comprehensive set of polices which apply to all Charles Taylor operations and employees irrespective of where they are based or deployed. We review our policies on a regular basis (at least annually) to ensure that they remain fit for purpose. Our policies relate to the Group’s relationships with our staff and those who come into contact with the Group; they support the promotion and maintenance of a consistently high standard of business ethics. We believe that high standards of business ethics and a consistency of approach can add value to our operations and further enhance our reputation. Here we have set out our
approach, reflecting our attitudes, adopted processes and our progress in maintaining an ethical and responsible business.
The policies and other documents that are relevant to our ongoing efforts to avoid Modern Slavery and Human Trafficking within our operations are as follows:
Communications and Training
The Group utilises several conduits to ensure that our standards and policies are communicated to – and understood by – our people. Policies are communicated to staff on joining, with acknowledgement of being read and understood required as a key part of the induction programme. Mandatory training takes place annually for certain areas. This is monitored across the Group and compliance reported to the management team. There is ongoing communication via e-mail and regular briefings and seminars for the relevant people on specific topics. Our policies and procedures are available on our Group intranet, Compass, to all staff, and are communicated proactively as appropriate (for example, when they are updated) to all staff by e-mail.
Overall: we continually assess our exposure, and the potential for exposure, to risks and have a control and reporting framework to communicate issues. This includes an assessment of the risk of our operations utilising or being complicit in slavery and trafficking activities. We have assessed that this risk is low. As a of provider of professional and technical services, we are not a direct manufacturer or supplier of goods. Our staff generally have a high level of technical capability and professional qualification.
Risk assessment of our Supply Chain: our supply chain does not have a need for a high degree of manufacturing or a labour-intensive resource. Our main exposure for potential slavery and trafficking risks exists through the maintenance and support of our IT and propertyrelated infrastructure. Our risk assessment in December 2019 showed a low level of risk within our IT procurement, through the use of and relationships with major vendors who have committed to similar levels of adherence to the Act as our own. It also showed a low level of risk in property related procurement, through ensuring that companies involved in the supply, fit-out and maintenance of our office space adhere to suitable standards for their respective workers. More generally we ensure all contracts with our supply partners include clauses covering compliance with the Act. For certain services or projects, which have a potential for additional exposure, a specific and full risk assessment is carried out.
Several group functions have a direct role in compliance with the law, regulation and our own standards. These include our Risk & Compliance teams, Internal Audit, Legal and Human Resources. Individual teams within our client facing businesses are also responsible for ensuring compliance by working within our standards. Each of these teams are responsible for making risk assessments and reporting any exposure or incidents of non-compliance, including in relation to our Modern Slavery and Human Trafficking obligations. No issues of non-compliance with our Modern Slavery and Human Trafficking obligations were reported by our various control functions during 2019, or in prior years.
The Group encourages members of staff to maintain high standards of behaviour and to report any wrongdoing that falls short of this fundamental principle. Our Whistleblowing Policy aims to ensure that any member of staff who raises concerns in good faith can do so on a confidential basis without fear of reprisal or victimisation, and in the knowledge that their concerns will be taken seriously and investigated appropriately. The Policy applies to all employees of the Group acting in any capacity, executive and non-executive directors, officers, secondees, people on work-experience, contractors, authorised representatives and consultants in all Charles Taylor’s business units, divisions and subsidiaries globally.
No issues of non-compliance with our Modern Slavery and Human Trafficking obligations were reported via our Whistleblowing Procedures during 2019, or in prior years.
Whilst we believe our exposure to risks relating to Modern Slavery and Human Trafficking are low, we recognise that all businesses have a duty to ensure that this topic receives continual and appropriate attention and that we remain diligent in our efforts to reduce slavery and trafficking in all its forms. We shall continue to assess our risks both internally and through interaction with our partners, both current and future.
Specific actions that are proposed over the next year are as follows:
Approved on Behalf Of:-
Charles Taylor Limited & Subsidiaries
Group Chief Operating Officer
24 June 2020
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