MODERN SLAVERY ACT STATEMENT 2019
The Utmost International Group of companies (“Utmost International”) is committed to working towards the eradication of slavery and human trafficking. We are a global provider of life assurance products, owned by our two Founders and a number of funds managed by Oaktree Capital Group LLC. Further details of our ownership structure are available in the Governance section of our Annual Report, available online at www.utmostgroup.co.uk.
The Group has over 800 employees worldwide and operates predominantly in the United Kingdom, the Isle of Man, the Republic of Ireland, and Guernsey, with additional operations in the Bahamas, Dubai, Hong Kong, Singapore and Switzerland.
This is Utmost International’s first combined statement on its approach to modern slavery following the introduction of the UK Modern Slavery Act 2015 (the “Act”). As a business that places corporate and social responsibility at the heart of its values, Utmost International recognises that respecting human rights is the right thing to do and ensures the appropriate actions are taken to manage risks relating to modern slavery.
This statement sets out the steps taken by Utmost International or actions underway during the financial year ended 31 December 2019 to assist in the detection and prevention of modern slavery across its business operations and supply chains.
Utmost International is an international life assurance business which serves two key markets. It provides international life assurance to affluent, high net worth and ultra-high net worth individuals, and group risk solutions to multi-national corporates.
The principal business lines of Utmost International are Utmost Wealth Solutions and Utmost Corporate Solutions.
Utmost Wealth Solutions offers specialist life assurance and capital redemption bonds and investment and savings solutions. Through a unique combination of complementary strengths, Utmost Wealth Solutions offers outstanding service and focused expertise to our clients and their advisers who are seeking intelligent and efficient solutions to manage and pass on their wealth.
Utmost Wealth Solutions manages approximately £29bn (c. €33bn) in assets for over 130,000 clients as at 31 December 2019.
Utmost Wealth Solutions includes Utmost Limited in the Isle of Man, Utmost PanEurope dac in Ireland and Utmost Worldwide Limited in Guernsey (together, the “subsidiaries”).
Utmost Corporate Solutions provides group risk solutions for Irish domestic and multinational corporates and EU-based multinationals from Utmost PanEurope dac, and for non-EU based multinationals from Utmost Worldwide Limited. The business provides cover for over 900,000 lives.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING:
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. The Group is committed to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere within its businesses or in our supply chains.
We have in place systems to:
- Protect employees and whistle blowers
- 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.
When developing our internal policies we ensure that we consider measures which will assist in preventing modern slavery from taking place in our business dealings and these polices are kept under review on an annual basis.
We follow the principles of good corporate governance and Enterprise Risk Management and do not tolerate any malpractice, whether committed by senior managers, employees, suppliers or contractors acting on our behalf (“our Governance Framework”).
A Code of Conduct (“Code”) is included in the Governance Framework applied by each of the subsidiaries and applies to all directors, officers and employees, requiring that they adhere to the Principles of Conduct and Ethics (the “Principles”). The Principles put in place by the subsidiaries state that employees must act with integrity, objectivity, confidentiality and in a professional manner. Our employees are actively 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.
In each of the subsidiaries, our Whistleblowing Policy sets out the procedure for reporting practices which are inappropriate, unethical or otherwise inconsistent with the Code. This policy enables an employee to report any improper conduct or unethical behaviour in the first instance to their manager, senior manager or the local Chief Executive Officer directly if they wish. This Policy and the associated Guidance Notes are communicated to all employees at least annually and are easily accessed.
Where employees feel that they cannot raise a concern with these individuals, they may make contact on a confidential basis with the Chairman of the local Audit Committee, after which their report will be investigated and considered by all of the Non-Executive Directors of Utmost Limited, Utmost PanEurope dac or Utmost Worldwide Limited. At all times during any investigation the Whistleblower’s identity will be kept confidential. All employees are reminded of their right to raise concerns under the Whistleblowing Policy, and to consult with associated guidance, by the Chairman of the local Audit Committee annually.
It is important to us that our commitment to human rights is shared by our suppliers. Utmost International accepts a range of goods and services from suppliers located across the globe, although the majority of suppliers have their operations locally (in the Isle of Man, Ireland or Guernsey) or the United Kingdom. Goods and services utilised by the Utmost International Group and its subsidiaries primarily consist of catering, cleaning, office furniture and stationery, electrical equipment, IT software, property maintenance and utilities.
As Utmost International’s businesses operate in the financial services sector, the risk of being exposed to modern slavery is considered lower than in other industries. However, we recognise that financial services firms cannot be complacent as to the risks that exist in their supply chains and to reduce this risk further we review all existing suppliers annually, irrespective of their size, and assess any new suppliers prior to using them.
Suppliers of Utmost Limited and Utmost PanEurope dac and UK-based Utmost International operations are currently assessed annually using a risk-based approach to identify those which may 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 medium or high risk, they are contacted to inform them of what is expected from 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.
Where we enter into or renew a contract with a supplier, we will negotiate terms to include standard contractual obligations seeking to ensure that the supplier operates in compliance with the Act.
OUR ONGOING APPROACH AND NEXT STEPS
There is a commitment throughout Utmost International to ensure that we respect human rights and continue to act as a responsible corporate citizen. To achieve this we have ensured that robust and effective processes are in place and that the level of employee awareness is appropriate to detect and ultimately prevent modern slavery from occurring anywhere in our supply chain.
Ongoing oversight and ownership of these processes and polices is provided by the Management teams and Board members through reporting to the Audit Committee.
Utmost International will be taking steps to ensure that there is a common approach to procurement and supplier management throughout the three different businesses in 2020 and beyond. This will ensure that when a supplier is selected (regardless of jurisdiction), that a consistent principle-based approach is adopted under the selection process. One of the principles requires that the Act be observed as part of this process.
Utmost PanEurope DAC and Utmost Limited have published individual Modern Slavery Act statements for the 2019 year, which are available at utmost.ie and utmostwealth.com. In future years, a single Group Modern Slavery Act Statement will incorporate the relevant information from each of the businesses and apply to each of Utmost PanEurope DAC, Utmost Limited and Utmost Worldwide Limited.
All employees of Utmost International will be provided with ongoing training to ensure that there is the appropriate level of awareness and consistency across the entire business.
This statement has been approved by the Board of Utmost International Group Holdings Ltd and signed on its behalf by the Utmost Group CFO.
16 June 2020