Anti-Modern Slavery & Human Trafficking Statement
Last updated: 24-May-2024
This statement is made on behalf of Leadenhall Analytics Ltd. (“Leadenhall Analytics” or “We”)pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”). Leadenhall Analytics is a Private limited Company registered in the United Kingdom.
Our approach
As a service provider within the highly regulated insurance market, we consider the risk of modern-day slavery within our supply chain to be low. Regardless, we are committed to conducting our business with integrity, respect, and transparency. We hold ourselves – and the businesses within our portfolio – to the highest level of legal, professional, and ethical standards.
Employee awareness and Supply Chain due diligence are key elements of this Policy.
Employee Training
All team members are required to undertake mandatory Anti-Modern Slavery training as part of their onboarding at Leadenhall Analytics, in addition to training on diversity and inclusion, anti-bribery and corruption, identifying potential financial crime, and whistleblowing.
Supplier Due Diligence
Leadenhall Analytics does not knowingly support ordeal with any business involved in slavery or human trafficking and will report organisations where there are reasonable grounds to suspect their involvement. All Leadenhall Analytics suppliers are expected to comply with laws and regulations applicable to their business and our procurement policy and processes includes verification of such.
Anti-Modern Slavery & Human Trafficking Policy
- Introduction
Leadenhall Analytics Ltd(“Leadenhall Analytics”) is committed to conducting its business with the highest level of legal, professional, and ethical standards, in compliance with Applicable Laws and based on a strong foundation of integrity. Slavery of any kind is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is areal problem for millions of people around the world, including in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.
Leadenhall Analytics has zero-tolerance for any form of slavery and human trafficking. In accordance with this commitment, Leadenhall Analytics’ employees, contractors, subcontractors, vendors, suppliers, partners and others through whom we conduct business must not engage in any practice that constitutes trafficking in persons or slavery. Failing to recognize and avoid slavery can have a devastating impact on Leadenhall Analytics’ reputation, business, and can create criminal and/or civil liability for Leadenhall Analytics and the individuals involved. - Applicability
This Policy applies to any Leadenhall Analytics company, subsidiary, affiliate, division, and other controlled business entity and operation, including Leadenhall Analytics as well as all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. This Policy applies in all territories where Leadenhall Analytics operates. Wherever local customs, standards, Laws, or other local policies also apply, the stricter rules must be complied with provided that the provisions of this Policy do not conflict with the relevant legislation. - Fundamentals
3.1. We have a zero-tolerance approach to modern slavery and human trafficking in all our operations and supply chains. We will not engage in, tolerate, or condone any form of modern slavery, including forced labour, child labour, debt bondage, human trafficking, or exploitation of vulnerable individuals.
3.2. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
3.3. Members must exercise due diligence while engaging with Business Partners and Third Parties. Reasonable efforts will be made to assess Business Partners and Third Parties with respect to their engagement in any acts of slavery and/or human trafficking, directly or indirectly.
3.4. Members must refuse to enter any transaction that directly or indirectly involves any form of slavery and/or human trafficking.
3.5. Any conflict of interest must be disclosed promptly.
3.6. Members must consider the prevention, detection, and reporting of any form of violation of this Policy as their own responsibility.
- Compliance with the Policy
4.1. You must ensure that you read, understand and comply with this policy.
4.2.Theprevention, detection and reporting of modern slavery in any part of ourbusiness or supply chains is the responsibility of all those working for us orunder our control. You are required to avoid any activity that might lead to,or suggest, a breach of this policy.
4.3. You must notify management as soon as possible if you believe or suspect that a violation of this policy has occurred, or may occur in the future.
4.4. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
4.5. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with management.
4.6. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. - Communication and Awareness of this Policy
5.1. Any violations of this Policy must be reported at enquiries@leadenhallanalytics.com
5.2. Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
5.3. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. - Breaches of this Policy
6.1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
6.2. We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy.
Respectfully,
Leadenhall Analytics
