Transparency in Supply Chains
What is the Act?
The Modern Slavery Act 2015 is designed to tackle slavery in all its forms and consolidates previous offences relating to trafficking and slavery. The Transparency in Supply Chains (TISC) provision of the Act specifically targets organisations above a certain size in order to encourage them to use their 'purchasing power' to exert influence on their supply chains and discourage others from being involved in slavery.
To which organisations does the TISC requirement apply?
The TISC provision applies to all organisations supplying goods or services with a turnover of £36 million or more, carrying on a business, or part of a business in the UK (not just those registered in the UK).
What do organisations need to do?
All organisations subject to the TISC provision are required to produce a slavery and human trafficking statement for each financial year. The statement must include the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, or in any part of its own business.
An organisation can choose not to take any steps. However, such organisations must still produce and publish a statement reflecting that approach and there is an expectation of progress over time, i.e. organisations will need to build on what they are doing year-on-year.
It could be argued that Lloyd’s managing agents do not have supply chains in a traditional sense, and that the supply chains they might have are not complex (unlike large retail or manufacturing organisations). However, all Lloyd’s managing agents are required to produce and publish a statement, although such statements are likely to be relatively short and simple, compared to organisations in some other industries.
It is worth reiterating that the required statement relates to steps an organisation has taken/is taking (or that it has taken no such steps). It is not an attestation that its supply chains are slavery free.
Who needs to approve the statement?
The statement must be approved by the Board and signed by a director.
When do firms need to publish a statement?
The statement must be published within six months of the end of the financial year and cover the previous year. For managing agents, the first statement will cover the period 1 January 2016 to 31 December 2016, and should be published by 30 June 2017.
How should it be published?
Organisations are required to publish the statement on their website and must include a link to the statement in a prominent place on their website’s homepage.
Outsourced Shared Market Services
Both the LMA and its Xchanging Review Board (XRB) committee have discussed the requirements of the Act with both Lloyd’s and CSC/Xchanging. CSC has published its group statement and has confirmed that all CSC corporate entities, including Xchanging Ins-sure Services (XIS)/Xchanging Claims Services (XCS) and intra-group ‘sub-outsourcers’, are covered by the statement. CSC’s statement is supported by a number of policies and there is an undertaking to carry out audits from 2017. The LMA’s XRB committee (acting on behalf of all managing agents for XIS/XCS’ outsourced shared services) will expect to see the assessments from these audits.
The LMA’s market committees will also ensure that other market service providers within the scope of this Act are aware of the requirements and taking action to comply.
Lloyd’s has also published its own statement which managing agents might find useful.
The government has published a useful guide to the requirements and how organisations can approach the production of their statements. Further guidance and a useful set of tools has been published by the Walk Free Foundation.
Manager, Legal and Compliance
Anti-Slavery & Human Trafficking Statement
This statement is made on behalf of Starr Insurance Companies' (“Starr”) and it sets out the actions taken by Starr to understand all potential modern slavery risks related to its business, and those in its supply chain, and to put in place measures to prevent slavery or human trafficking related to its business. Unequivocally Starr oppose all forms of slavery, servitude and forced or compulsory labour, and human trafficking (collectively hereafter "Slavery"). Starr operates internal controls and procedures to ensure Starr do not engage with third parties that do not uphold these values and standards.
Starr issues this Statement in accordance with Section 54, Part 6 of the Modern Slavery Act 2015 of the United Kingdom for the year ending 31 December 2022.
Starr is a global insurance and financial services company. Its primary business is underwriting property and casualty insurance for large, commercial insureds. Starr primary insurance operating companies are subsidiaries of Starr Insurance Holdings, Inc., a Nevada entity. Starr relies on affiliated agencies and non-affiliated agents and brokers to distribute its insurance products.
Starr, as an insurance and financial services company, presents low overall risk for Slavery. Starr uses a range of global services to provide effective insurance products that deliver expected standards to policyholders and employees. The products and services purchased range from consultants, IT software/hardware, claims handlers, intermediaries, and professional advisors to cleaning and catering services. We only engage with service and product providers that demonstrate the same commitment to opposing slavery.
Supplier due diligence
Each of the Starr entities maintain appropriate controls and oversight to ensure the engagement of third party suppliers is in accordance with accepted business practices and principles. The appointment of a supplier requires a due diligence process to assess the suitability of the provider to deliver the service at the required standard and within agreed values and principles. The level of due diligence undertaken is dependent upon the location of the provider and the product and/or service to be purchased. Due consideration is given to the provider's own processes for the use of third party suppliers to ensure appropriate conduct throughout the business chain. The due diligence process is kept under review in each Starr entity to ensure the process remains appropriate and fit for purpose. The process is outlined in Starr’s Outsourcing process, along with the key responsibilities.
Starr maintain a written Code of Conduct that prohibits, among other things, Slavery and related activities. Starr takes great pride in the people it employees and in their job performance. Starr enforces the high standards it expects from its employees through a rigorous pre-hire screening process, the Code of Conduct and ongoing compliance training, including mandatory training on the Slavery Act. Engaging in any Slavery-related activities would be a violation of Starr’s Code of Ethics and Business Conduct and would expose the employee to disciplinary action up to and including termination.
Starr operate within the local laws and regulations of the countries from which they operate. It offers employees a safe and healthy work environment promoting employee wellbeing and development. Remuneration is in accordance with local laws and regulations and subject to the local taxation regulations.
Each Starr entity also maintains a Hotline program and procedures that ensure protection for employees should they identify and raise concerns regarding conduct and behaviour within the organisation. Should employees witness a violation of the Starr Code of Business Ethics and Conduct or engagement with suppliers that do not uphold the Starr values against slavery, they are able and encouraged, to make an anonymous notification to the Hotline.
Starr’ supports its staff to understand and respond to modern slavery by providing ongoing training.
This Anti-Slavery & Human Trafficking Statement is made in compliance with s54(1) of the Modern Slavery Act 2015.
Chief Operations Officer
Date: 15 June 2023
1 Starr Insurance Companies is the worldwide marketing name for the operating insurance and travel assistance companies and subsidiaries of Starr International Company, Inc. and for the investment business of C. V. Starr & Co., Inc. and its subsidiaries.