Modern Slavery Statement 2019
  1. Introduction
    1. This statement is made by Police Mutual Assurance Society Limited (“Police Mutual”).
    2. This is Police Mutual’s third statement under section 54 of the Modern Slavery Act 2015 (MSA15) and covers the financial year from 1st July 2018 – 30th June 2019
    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 business providing financial products and support to our Police and Military customers and members including Police staff and family members. 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 circa 500 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:
      1. identify and assess potential risk areas in our supply chains.
      2. mitigate the risk of slavery and human trafficking occurring in our supply chains.
      3. monitor potential risk areas in our supply chains.
      4. 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 a 2018 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 financial year ending 30 April 2019, 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. During 2018/2019 we continued to review supplier and other third party relationships, assessing risks and concentrating on those markets and economic sectors where it considers the risk to be greatest. The application of the Third Party Management Framework is under review, covering Modern Slavery as well as other financial crime risks and a separate Outsourcing Policy is in development.
    3. 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.
    4. In our 2017 statement we said that, wherever possible, we would include in contracts with suppliers an obligation to comply with a Modern Slavery clause, and that we would update our standard terms to reflect this. 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.
    5. During 2018 and 2019, Police Mutual aims to conduct an enhanced audit of our major suppliers in sectors or geographies where there is material inherent risk and including subcontractors. This will be a pilot to test new processes, focusing on areas where we perceive the risk to be greatest.
    6. To date, Police Mutual has found no evidence within its own business of any practices which contravene or individuals who are affected by the MSA 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.
    7. 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:
      1. 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.
      2. We have reviewed our own Modern Slavery policy and are not proposing any changes.
      3. We have reviewed or set in train a programme for the review of our existing supplier contracts and where necessary refresh and update the contractual obligations on our suppliers to include a Modern Slavery clause.
      4. We have enhanced the Third Party Management Framework and designed an approach to mitigate the risk by including low cost suppliers in the Supplier Registration Process. This means that new suppliers from July 2019 will be required to answer declaration questions and provide policy documentation to evidence that there is no malpractice.
      5. We have commenced onboarding of a supplier where Far East sourcing is involved and obtained all documentation to ensure we are compliant with MSA15.
      6. We continue to use a model ‘Modern Slavery’ clause for all relevant supplier contracts which anticipates the consequences of a breach of the MSA15.
    8. 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 MSA15.
  7. Further Steps – 2019/2020
    1. In 2019/2020, we shall continue to monitor adherence to the MSA15 (and take any necessary subsequent action) by:
    2. Continuing the use of the Modern Slavery model clauses.
    3. The training will be made mandatory for the Commercial Finance, Procurement Cross Functional Decision Making Panel, Marketing, IT, Senior Manager. This will ensure that we are creating a culture in the business which is aware of the risks and routes to mitigate them in the supply chain.
    4. Considering the appropriateness of developing further measures including audit with specific suppliers where we assess that there may be a risk of slavery and trafficking within those organisations.
    5. Aligning the reporting Key Risk Indicators to include the Management Information on compliance from the supply chain in relation to the Modern Slavery Act 2015.
    6. Review the Supplier Healthcheck Programme for this to be completed this year as part of Contract Management. This will mean that the high risk suppliers in the organsiation will have answered the reviewed questions regarding Modern Slavery on the Supplier Registration document.

Statement Date 4 July 2019


Investing on Behalf of Our Members
The Financial Conduct Authority policy statement (19/13) was published on 31 May 2019, which brings in new requirements for firms to develop and publicly disclose their approach in relation shareholder engagement and increased transparency around stewardship, or to explain why they have chosen not to do so.

Stewardship aims to promote the long term success of companies in such a way that the ultimate providers of capital also prosper. Effective stewardship benefits companies, investors and the economy as a whole. (UK Stewardship Code, Financial Reporting Council).

We are in the process of preparing an engagement policy which is intended to describe how our stewardship and engagement activity requirements will be met. The engagement policy will be made available on our website once it has been approved by the Managing Board.