Modern Slavery Statement 2020
  1. Introduction
    1. Although Police Mutual Assurance Society was dissolved on 1st October 2020 the essence of the statement remains intact, and Royal London will continue to ensure the continuing business complies with the requirements of the Modern Slavery Act.
    2. This is Police Mutual’s fourth statement under section 54 of the Modern Slavery Act 2015 (MSA15) and covers the period from 1st July 2019 – 30th August 2020.
    3. Police Mutual has a number of subsidiaries, details of which can be found in our Annual Report. Of these subsidiaries, only PM Central Services PLC (“PMCS”) has a turnover of over £36million. PMCS is an employment and services company and is wholly owned and controlled by Police Mutual and is subject to the same policies and procedures as Police Mutual. This Modern Slavery Statement therefore applies equally to Police Mutual and PMCS.
  2. Our Business
    1. We are an insurance, savings and welfare business with a customer/member base covering affinities for the police and military. 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. We offer this to the Military and others who lay their lives on the line and those who support them.
  3. Our Policies
    1. 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 400 employees across the UK and in Europe (the “Police Mutual”).
    2. 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. We also stress that our zero tolerance extends to retaliation against anyone who speaks up in good faith. In accordance with our Whistleblowing Policy, Police Mutual investigates any concerns it is made aware of, and seeks to appropriately remedy or mitigate those breaches.
  4. Our Due Diligence Processes
    1. Whilst Police Mutual exercises a vital role in the insurance distribution chain, the Police Mutual business itself is not inherently high risk in terms of Modern Slavery. To this end, as part of our initiative to identify and mitigate risk, we have in place systems to:
      • identify and assess potential risk areas in our supply chains.
      • mitigate the risk of slavery and human trafficking occurring in our supply chains.
      • monitor potential risk areas in our supply chains.
      • protect whistle blowers.
    2. As a general rule, 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 all of our staff understand and play their part in ensuring that Modern Slavery does not take place in our organisation or supply chains. Consequently, employees and others involved with the Group are, themselves, responsible for ensuring that our values and ideals are upheld.
  5. Progress in 2019 - Employees
    1. Police Mutual treats all colleagues with dignity and respect in an environment that is free from discrimination and harassment. So far as our own business is concerned, Police Mutual will only recruit an individual 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. This was evidenced in the 2020 equal pay audit, the development of the existing Equal Pay Policy and associated processes and the ongoing review of this along with updates to the Dignity at Work Policy.
    3. Police Mutual colleagues are made aware of their employment rights through a variety of channels including written employment contracts, employee policies and the group intranet. Colleagues are required to complete a number of mandatory training modules on a variety of topics, including but not limited to Financial Crime, Conduct Rules, Information Security and Data Protection.
    4. We have a formal Whistleblowing Policy and associated mandatory training that all colleagues must complete. Through the policy we encourage our colleagues and others who have serious concerns about wrongdoing or suspected wrongdoing in the workplace to come forward and voice their concerns.
  6. Progress 2019 – Procurement and Outsourcing
    1. In the period ending 30 August 2020, Police Mutual received a variety of goods and services from over 300 third party suppliers. Most of our manufactured goods (typically IT equipment) are purchased from large multinational corporations who have their own supply chain principles and ethical standards in addition to agreeing to ours where appropriate.
    2. Our dedicated procurement team requires suppliers to go through a detailed on-boarding process. All new and renewing Police Mutual suppliers whose spend is in excess of £100,000 are required to complete a Supplier Registration Questionnaire which formally records and captures the supplier’s type, categorisation of spend profile, geographical location and anti-slavery documentation. The on-boarding process also allows us to determine which suppliers are most at risk for responsible sourcing challenges.
    3. Model clauses are routinely incorporated into relevant contracts, which sit alongside standard contractual protections such as rights to audit or termination for breach. We may also use a supplier’s own terms and conditions where they are at least equivalent to our own. In such instances, we aim to engage with suppliers who are on a comparable path to our own standards, including those related to Modern Slavery but, where a supplier is unable or unwilling to do so, we will end the relationship as soon as contractually possible to do so.
    4. Police Mutual is an insurance company that is at low risk of breaching Modern Slavery requirements. To date there has been no reported or detected evidence within its own business of any practices which contravene or individuals who are affected by the Modern Slavery Act 2015. Notwithstanding the above, we are not complacent and will continue to focus on improving our procedures and policies to endure there is no Modern Slavery in the Police Mutual supply chain.
    5. There is no evidence to suggest any modern slavery or human trafficking activities within the organisation or in the third party supply chain and we continue to review all new and existing suppliers to ensure that appropriate procedures are in place to support the Modern Slavery policy.
    6. During the current period, 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 reviewed our own Modern Slavery policy and are not proposing any changes. It has been published on the intranet and is thus available to all colleagues.
      • We have reviewed our existing material contracts at renewal and where necessary refreshed and updated the contractual obligations on our suppliers to include a Modern Slavery clause.
      • We have deployed a Modern Slavery mandatory training module to all members of the Executive and Senior Management Team
      • We continue to use a model ‘Modern Slavery’ clause for all relevant supplier contracts which anticipates the consequences of a breach of the Modern Slavery Act.
    7. The measures adopted by Police Mutual are considered to be proportionate to its operation; the level of risk it faces and to be effective to uphold the aims of the Modern Slavery Act.
  7. Further Steps – 2020/2021
    1. On 1st October 2020 Police Mutual will merge and become part of Royal London. From this date all modern slavery related activities will be overseen by Royal London, and in particular the Royal London procurement team will bring their wider resource and experience to further improve our existing arrangements

Statement Approval Date: 24th September 2020