Slavery and Human Trafficking Statement for the Financial Year 2021
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 ensure that slavery and human trafficking is not taking place in our supply chains nor in any part of our own business. Pool Re has and will continue to maintain zero tolerance for modern slavery and human trafficking.
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 ensuring that there is no 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, ensuring that all are treated fairly and with dignity and respect.
Pool Re has a number of 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 and Whistleblowing Policy which encourages employees to report concerns they might have relating to inappropriate conduct without threat of unfair treatment.
Pool Re has implemented and continued to enforce effective and proportionate risk-based processes and controls 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 Outsourcing Policy, which ensures that appropriate levels of review, approval and oversight are maintained.
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.
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 approved this statement at its board meeting on 16 December 2021.
9 December 2021