This is Utmost PanEurope dac’s (“UPE”) statement on its approach to modern slavery following the introduction of the UK Modern Slavery Act 2015 (the “Act”). This statement sets out the steps that have been taken by UPE in 2019 or that are planned for 2020 to assist in the detection and prevention of modern slavery across its business operations and supply chains.
Who are we?
UPE is based in Ireland and is a part of Utmost Holdings Ireland Limited (the “Irish Group”), which has provided life assurance and capital redemption bonds to high net worth clients in a number of European countries through fully regulated partners and intermediaries since 1999. It has approximately €17.5bn of assets under administration as at 31 December 2019 and strives to offer its clients outstanding levels of service and innovative products. In addition, our Utmost Corporate Solutions business provides life, disability and critical illness cover to the employees of its multinational corporate clients, who are based in Ireland and across Europe.
Our Internal Policies
We are considering our internal policies in respect of measures which could assist in preventing modern slavery from taking place in our business dealings.
We follow the principles of good corporate governance and Enterprise Risk Management and do not tolerate any malpractice, whether committed by senior managers, staff, suppliers or contractors acting on our behalf (“our Governance Framework”).
A Code of Conduct (“Code”) is included in our Governance Framework and applies to all directors, officers and employees and requires that they adhere to the Code. The Code states that staff must act with integrity, objectivity, confidentiality and in a professional manner. Staff are encouraged to report any practices or actions where they believe these to be inappropriate or inconsistent with the Code or that may compromise the ethical standards or integrity of the organisation.
The procedure for reporting inappropriate, unethical or inconsistent practices with the Code is set out in our Whistleblowing Policy. This Policy provides guidance and steps for a member of staff to report any improper conduct or unethical behaviour in the first instance to their manager, senior manager or the Chief Executive Officer directly if they wish.
Where they feel that they cannot raise a concern with these individuals, they may make contact on a confidential basis with the Chairman of the Audit Committee or the Chairman of the Board after which their report will be investigated and considered by all of the Non-Executive Directors. At all times during any investigation the whistle-blower’s identity will be kept confidential. Staff members are reminded of their right to raise concerns under the Whistleblowing Policy on an annual basis.
UPE accepts a range of goods and services from suppliers located across the globe, although the majority of suppliers have their operations locally in Ireland, the Isle of Man or the United Kingdom. Goods and services utilised by us consist of catering, cleaning, office furniture and stationary, Information Technology, property maintenance and utilities.
The following supplier measures have been considered during 2019 and will be fully implemented in 2020:
Supplier Risk Assessment
The Chief Operations Office in conjunction with the Head of Legal and Compliance assesses our suppliers periodically using a risk-based approach to identify those which are deemed to be higher risk. This assessment is based on their area of geographical operation, the type of industry in which they operate and their publicly disclosed policies on slavery and human rights.
Where a supplier is identified as higher risk, they are contacted to inform them of what is expected of them to comply with the terms of the Act. If the supplier indicates that they have no Policy or similar in place, we will, where practicable, identify an alternative supplier.
We have introduced a Procurement Policy for UPE in 2020. The Policy requires that when a supplier is selected, a principle-based approach is adopted under the selection process. One of the principles requires that the Act be observed as part of this process.
Where a supplier contract is to be entered into, or where this is to be renewed, we will include standard contractual terms which seek to ensure that the supplier is in compliance with the Act.
Approved by the Board of Directors of UPE
18 May 2020