Slavery and Human Trafficking Statement for the Financial Year 2022

 

This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 and sets out the steps that Pool Re has taken to prevent slavery and human trafficking from taking place in our supply chains or in any part of our own business.   Pool Re has and will continue to maintain zero tolerance for modern slavery and human trafficking.  This statement relates to actions and activities during the period 1 January 2022 – 31 March 2023.

The Organisation’s structure, business and supply chains

Pool Re reinsures property damage and business interruption against terrorism in Great Britain. As such, our own business is conducted entirely in Great Britain and our supply chain is similarly predominantly based in Great Britain.

We are committed to taking appropriate steps to mitigate the risk of modern slavery or human trafficking in our supply chains or in any part of our business.  We are committed to acting ethically and with integrity in all our business relationships and expect all in our supply chain to comply with similar values, particularly with regard to labour practices, health and safety, responsible sourcing and high environmental standards.  It is our policy to offer equal treatment to employees and prospective employees, and to seek to ensure that all are treated fairly and with dignity and respect.

Procurement processes

In respect of new suppliers, our procurement process includes due diligence of potential suppliers. We perform a risk analysis based on the nature and value of the services being provided. This risk analysis includes ascertaining whether suppliers are a relevant organisation under Section 54 of the Modern Slavery Act and if so whether they are compliant with the annual reporting requirements imposed by Section 54.

High-risk activities 

Pool Re does not undertake any activities that are considered to be at high risk of slavery or human trafficking.

Policies

Pool Re has clear corporate policies which reflect its commitment to acting ethically and with integrity and mitigate the risk of modern slavery. Pool Re requires all employees, officers and directors to comply with its policies and procedures and codes of conduct, as set out in the Staff Handbook. In addition, Pool Re requires all employees, officers and directors to comply with our Conflicts Policy, Financial Crime Prevention Policies, which include anti-money laundering, anti-bribery & corruption and fraud prevention, and our Whistleblowing Policy which encourages employees to report concerns they might have relating to inappropriate conduct without threat of unfair treatment.

Due diligence

Pool Re has implemented and continued to enforce proportionate risk-based processes and controls designed to ensure that our standards are upheld at all times. Prior to entering into any contract with a supplier, due diligence on the supplier is carried out to seek to ensure compliance with all applicable laws.

Pool Re’s suppliers are contracted in accordance with our Commercial Policy and Framework, which requires appropriate levels of review, approval and oversight are maintained. 

Risk assessment

Pool Re considers that its business model represents a low risk of exposure to slavery and human trafficking and there are no high risk vendors.  There is a lower risk profile than in many other industries. This can be attributed to the nature of Pool Re’s business and its suppliers.

Training

All staff receive training on modern slavery and human trafficking and are required to comply with the provisions of the Modern Slavery Act and to carry out due diligence prior to entering into any contract with a supplier.

 The board of directors of Pool Re approved this statement at its board meeting on 13 April 2023.

Angela Knight
Chair
13 April 2023