Our Responsibilities

Modern Slavery Statement 2017

  1. Introduction
    1. This statement is made by Police Mutual Assurance Society Limited, PMGI Limited, Mortgage Excellence PLC, PM Central Services PLC, PM Advisory Limited, Abacus Limited, PMHC Limited, Police Housing Fund Limited, Forces Insurance Limited, PM Holdings Limited and Police Housing Fund Limited. It is a statement made in accordance with section 54 of the Modern Slavery Act 2015 and covers the financial year from April 2016 to 31 May 2017.
  2. Our Business
    1. We are an insurance, savings and welfare business with responsibility for the interests of over 200,000 customers. As a not-for-profit financial services organisation, we set ourselves challenging goals to achieve a long-term competitive advantage to enable us to fulfil our purpose. As a mutual, we have no shareholders, meaning we can use our resources to help improve the lives of our members and customers.
    2. Our values underpin what we stand for and will help us achieve our purpose and vision. We exist to improve the lives of the Police family and we offer this to the Military and others who lay their lives on the line and those who support them.
  3. The Purpose of this Statement
    1. The Modern Slavery Act 2015 came into effect on 29 October 2015. This law requires companies doing business in the UK which supply goods or services and have an annual turnover exceeding £36 million to disclose information regarding their policies to eradicate slavery, servitude, forced or compulsory labour and human trafficking (‘modern slavery’) from their supply chain and within their business.
    2. We are proud of the integrity measures we take in this regard which stand alongside our values. This statement covers the activities of the Police Mutual group which has over 600 employees across the UK and in Europe (the “Police Mutual”).
    3. Police Mutual has zero tolerance towards modern slavery and we strive to ensure that slavery and human trafficking is not taking place within any part of the Police Mutual group or our supply chain. Our principles are set out in more detail in our own Modern Slavery Policy in which we communicate our ethical principles and associated expectations to our employees and our supply chain.
  4. Supply Chain Management and Risk Assessment
    1. Whilst Police Mutual exercises a vital role in the insurance distribution chain, it does not have a supply chain that is reliant on factories or other entities that would normally be associated with slavery or forced labour. To this end, we pay particular attention to the following higher risk parts of our business when testing our existing processes.
      • Our temporary workforce.
      • Our second and third tier supply chains such as cleaning, security and maintenance services.
      • Suppliers based overseas.
    2. As a general rule, contractors and suppliers used by Police Mutual are therefore not likely to be susceptible to the risk of slavery and trafficking. However, we are mindful that others may not always uphold standards to the same level as Police Mutual. We acknowledge that we must remain vigilant to the risks and ensure that our suppliers understand and play their part in ensuring that modern slavery and human trafficking does not take place in our organisation or supply chains. Consequently, employees responsible for managing suppliers and others involved with the Group are, themselves, responsible for ensuring that our values and ideals are upheld.
    3. From June 2017, we have required all new and renewing Police Mutual suppliers to sign up to a legally binding Clause which details all requirements around modern slavery but in essence commits our suppliers not to be involved with modern slavery in any form.
    4. Police Mutual has found no evidence within its own business of any practices which contravene or individuals who are affected by the Modern Slavery Act 2015.
    5. We are developing our supplier risk assessment process to allow us to assess and categorise new and existing vendors based on criteria including vendor type, categorisation of spend profile, geographical location and anti-slavery documentation.
  5. Due Diligence
    1. To embed zero tolerance of modern slavery and trafficking in our business and supply chains we have begun a due diligence process which includes the following steps:-
      • We are writing to all key suppliers and prospective suppliers and other agencies involved in the supply of services in risk areas identified above seeking confirmation they are complying and requesting evidence of this (for example their own Modern Slavery policy where applicable).
      • We are carrying out a review of the steps we take when engaging new suppliers, contractors and business partners to assess the likelihood of slavery or trafficking existing in those organisations and what measures are in place to combat those risks.
  6. Staff Recruitment and Training
    1. So far as our own business is concerned, Police Mutual will only recruit staff after ensuring that they are legally permitted to work in the UK (or in whichever country they are employed) and will pay wages in accordance with all UK laws, rules and regulations.
    2. We ensure that we benchmark pay to establish that our terms and conditions are fair and competitive and we are committed to equality of opportunity.
    3. Police Mutual conducts training to emphasise the importance of acting in line with our own internal policies. This training will include our obligations under the Modern Slavery Act and the importance of ensuring that both we and those we conduct business with comply with this legislation.
    4. Compliance officers incorporate guidance regarding the Modern Slavery Act into regular company training sessions and part of our ongoing risk and compliance practices monitor any concerns and evaluate risk areas relating to modern slavery so that we can take further action if required.
    5. In keeping with Police Mutual’s commitment to act with integrity in all its business dealings, many of our existing policies are relevant in ensuring that there is no slavery or human trafficking in any part of its business or supply chains.
    6. We have a comprehensive Whistleblowing Policy through which we encourages our employees and others who have serious concerns about wrongdoing or suspected wrongdoing in the workplace to come forward and voice their concerns.
  7. This Year
    1. During the current financial year, we have taken the following steps to ensure that slavery and human trafficking have not taken place whether within our own business or in our supply chains:
      • We have verified that there is no evidence to suggest any modern slavery occurs – but this will be kept under ongoing review.
      • We have written our own Modern Slavery policy.
      • We have reviewed or set in train a programme for the review of all our existing supplier contracts.
      • We have developed a template ‘Modern Slavery’ clause to be inserted into all supplier contracts.
      • We are writing to all key suppliers and prospective suppliers of and other agencies involved in the supply of services in risk areas identified above seeking confirmation they are complying and evidence of this (for example their own Modern Slavery policy where applicable).
    2. The measures adopted by Police Mutual are considered to be proportionate to its operations; the level of risk it faces and to be effective to uphold the aims of the Modern Slavery Act.
  8. Measuring effectiveness – performance indicators
    1. We propose to measure the progress that we are making with the initiatives that we have undertaken (and take any necessary subsequent action) by:
      • Reviewing the effectiveness of our Anti-Slavery and Trafficking
      • Reviewing our success in training staff on slavery and trafficking issues during the next financial year.
      • Reviewing our progress in entering into communications with suppliers to raise awareness of the Modern Slavery Act.
      • Developing our supplier due diligence process to ensure that we engage appropriately with new suppliers.
      • Considering the appropriateness of developing further measures including audit with specific suppliers where we assess that there may be a heightened risk of slavery and trafficking within those organisations
  9. Feedback

    If you have any concerns and want to make a complaint, or just want to give us some feedback on our statement or approach, you can find out how to do this here.

    This statement was reviewed and signed by Stephen Mann, CEO of the Police Mutual group, on behalf of the Managing Board on 6 July 2017.