Human Rights and Modern Slavery Statement
Slavery and human trafficking statement as required under s54, Part 6, of the Modern Slavery Act  2015 for the financial year ending 30 September 2020.
Howden Group Holdings Limited (the “Company”/“Howden Group”) is registered in England and Wales under company registration number 2937398. Registered office: One Creechurch Place, London, EC3A 5AF.
The Company has a number of subsidiaries including DUAL International Limited, Howden Broking Group Limited, Howden Insurance Brokers Limited, HX Limited and Howden Group Services Limited (together, the “Group”).
The Group is committed to ensuring that its business dealings are carried out in compliance with the relevant laws and, in doing so, we endorse the implementation and promotion of ethical business practices to protect workers from being abused and exploited.
The Group is committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.
This statement covers the activities of the Group which is headquartered in London and has over 6,000 employees in entities across the world.
The Group has a devolved structure where each business is managed in country and in accordance with local governance and regulation, therefore with the exception of whistleblowing and activity within our international shared service centre, the policies and procedures are those implemented in the UK.
The Group has a commitment to be a responsible global business, recognising the importance and advancement of Human Rights as an issue that is integral to our core business, our operations and us as employers across all of our entities worldwide.
In May 2020, we became a signatory to the UN global compact and as of 2021 we will be communicating annually on the progress we make against the ten guiding principles, which in particular cover human rights, labour standards, environmental protection and anti-corruption.
The Group operates a suite of policies adopted within group companies and at Group level that reflect and embed its commitment to human rights. In 2019, we also formed a Sustainability Committee tasked with furthering environmental, social and governance interests within and external to the Group. As part of this in 2020, we developed an internal ESG benchmark, which included sections specifically on our employees, clients, human rights and supply chain to ensure we understand our ESG baseline and able to identify where risks may lie and how we can improve. In 2021, we will work to improve our policies and procedures to ensure best practice is shared amongst the Group, whilst also being sensitive to local regulations and legislation worldwide. This is part of our continued commitment to human rights.
We respect human rights standards for the workforce of our suppliers and promote sustainability standards in our supply chain. We share best practice widely across the Group and globally, we ensure clients of the Group are treated fairly and data privacy protected at all times.
As an employer we respect international human rights standards. At present all Group entities are located in jurisdictions which have signed to the Universal Declaration of Human Rights or equivalent. The Group promotes fair reward and recognition, diversity, inclusion and equal opportunities in all employee dealings including decisions on hiring, remuneration, training and promotion.
To date no infringements on human rights have been reported, but should a human rights risk be identified, we will involve the Group sustainability committee and Group services including risk, operations and communications to address and mitigate future human rights risk.
Supply chain management
Whilst the Group 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.
As a general rule, contractors and suppliers used by the Group are therefore not likely to be susceptible to this risk. However, we are mindful that others may not always uphold standards to the same level as the Group. Consequently, employees responsible for managing suppliers and others involved with the Group are, themselves, responsible for ensuring that our values and ideals are upheld. This continues to be a work in progress and we are strengthening our controls as new contracts are agreed, this includes modern slavery questions within our due diligence questionnaire and training/raising awareness communications amongst employees. At present we are undertaking a due diligence process for supply spend in excess of £100,000, this figure aligns with the sourcing principles adopted by our UK businesses. For example, serious violations by suppliers may lead to the termination of the business relationship, to date this has never occurred.
The Group continues to review and categorise its supply chain and ensure this information is shared across UK subsidiaries. For example, following modern slavery training, recruitment has been identified as an area of potential risk requiring specific focus, and we will be reviewing the contracts we have in place with all of our preferred recruitment partners to ensure our approach to modern slavery is fully incorporated. We have created a set of UK procurement principles that have been shared with all key subsidiaries.
The Group operates a number of policies to mitigate the risk of modern slavery and set out steps to be taken to prevent slavery and human trafficking in its operations, for example:
The Group encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. To this end, the Group has an Incident Report link displayed prominently on its webpages, via which anyone can report an incident which may ‘negatively impact the business, our employees (individually or collectively) or our reputation’. The Group’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, who have concerns can use our confidential helpline through SafeCall, an independent reporting line, which is widely advertised across all UK offices and monitored by our Group COO. Alternatively, disclosures can be reported by notifying their line manager, who will conduct or arrange for a senior individual to conduct an investigation, or notified directly to either our Group General Counsel or the Chief Risk Officer of their division. Otherwise, the individual may deem it appropriate to contact a legislative body, in which case examples of the relevant authorities are listed in the Group Policy. Across both disclosure routes, no calls or direct disclosures were made in 2020 in relation to modern slavery and trafficking.
Recruitment and Selection
All entities in the Group ensure appropriate controls are in place to ensure employees have the right to work and are therefore protected by employment legislation. This includes checking right-to-work documents, visas and passports. Additionally, we also verify that employees have supplied a proof of address/residence in the UK. The Group is also actively adopting more inclusive hiring practices, globally, through increasing line manager awareness and accountability of unconscious bias in the hiring process and therefore driving a more objective recruitment process. We are also sourcing candidates through more diverse job boards, aiming to increase representation of under-represented groups in the workplace. Likewise, the Group uses only specified, reputable employment agencies to source labour. To ensure this, we mandate that agencies for both temporary and permanent workers enter into our agreements which place obligations on those agencies to comply with all applicable laws (including modern slavery legislation), provide us with their modern slavery policy (where applicable) and carry out all appropriate checks on workers. Additionally, we conduct quarterly and annual business reviews with our recruitment agencies to ensure compliance and alignment to our Group goals and values.
The Group does not employ individuals that would be considered to be ‘child workers’. Young and inexperienced workers may be employed or given work experience, but they are subject to the rights and protections that we afford all workers.
Basic rights which we expect all employees to have access to, include:
- The right to a reasonable wage (e.g. UK Living Wage)
- The right to a safe working environment
- The right to an appropriate level of holiday and cover for period of sickness
- The freedom to complain directly or via our whistleblowing policy free of charge.
If employees believe that they are not being fairly treated or have any other concerns. The above are all monitored by the respective HR Business Partners, COO’s and Chief Risk Officers, made available by our global communications platform, ensuring that all employees have access to the whistleblowing policy and phone number. In 2020, there were no breaches of basic rights reported.
A worldwide employee engagement survey was conducted in April 2020, to gather confidential feedback from our employees on their experience working for the Group. The survey measured engagement across a number of factors as well as our emergency response to COVID-19. Participation was very strong with 86% of employees (4537 out of 5298) choosing to share their views. This means we can be very confident that the data is representative of our employee population as a whole. 67 questions were asked across 15 different factors some of which included Work & Life Blend, Social Connection, Alignment & Involvement and Enablement. Our overall engagement score was a very strong 80%.
An example of some of the questions in the survey has been provided below.
- Our physical workspace is enjoyable to work in
- I have access to the things I need to do my job well
- I believe my total compensation (base salary/any bonuses/benefits/equity) is fair, relative to similar roles at other companies
- The Group’s commitment to social responsibility is genuine
- Workloads are divided fairly among people where I work
- Howden Group Holdings is truly a People First organisation
- If I raise a concern about an individual’s behaviour I am confident that the appropriate action will be taken
- We have enough autonomy to perform our job’s effectively
- I receive appropriate recognition for good work at the Group
- We are genuinely supported if we choose to make use of flexible working arrangements
- I am able to arrange time out from work when I need to
- Genuinely, I believe my workload is reasonable for my role
Our results around our emergency response were exceptional and there were a number of factors we came out as being very strong in including Leadership, Company Confidence, Enablement, and Social Connection. We were also strong on Work & Life Blend (74%) and Alignment & Involvement (76%).
The intention is that the Global Engagement Survey will be run on an annual basis to allow us to benchmark ourselves and measure progress year on year. The next survey is provisionally scheduled to take place in May 2021.
Throughout FY20, employee Wellbeing was an important focus for us, especially through the global pandemic. We launched a number of Mental Health Champions early in FY20, who were trained mental health first aiders. As the global pandemic impacted, we provided a range of supportive guides and webinars through the early stages of the pandemic to help employees. We made HR policy enhancements to offer more support in light of the challenges employees were facing, including up to 5 days of paid leave for carers. We added a further element of support to UK employees by adding the Thrive mental health wellbeing app to our employee benefits package in July 2020.
Code of Conduct
With effect from the 31 March 2021 the Financial Conduct Authority (FCA), the regulator for the UK regulated entities, mandated a number of conduct rules that all employees working within the Financial Services industry must comply with. These include ensuring colleagues act with integrity, due skill, care and diligence whilst being open and transparent with regulators and customers. Additional rules apply to the company’s Senior Managers and actions will be taken against employees in breach of these conduct rules.
All employees (UK) were asked to complete a short training module to ensure understanding and compliance with the new Senior Managers & Certification Regime (SMCR) Conduct Rules. This training was rolled out in October 2020 with completion being mandatory. SMCR Conduct Rules training was also rolled out to WNS employees (from our shared service centre) who provide services to UK Regulated Entities.
Additionally our outsourced shared service centre, which has offices in a number of high-risk countries has a Code of Conduct which is updated annually. Our internal audit team regularly audit the team against this, to date no issues have been identified.
Right of Audit
All offices in the Group are subject to periodic audits. Audit work includes an assessment of our modern slavery processes within relevant audits. During the year ended 30 September 2019 there were no incidents relating to modern slavery identified within audits performed across the Group.
In 2020 our senior leads including: Head of Operations, Procurement Officer, Head of CSR, HR representatives, COO, Shared Service Centre representation attended Modern Slavery and Human Tracking Training. Whilst no further in-person training was delivered in 2020, we were able to share some educational videos on modern slavery to help raise awareness, which received over 1,000 views and this will continue to remain on our Sustainability Committee’s agenda.
Our modern slavery and human trafficking statement for the financial year ending 2020, has been approved by the Board, as reflected by the Group CEO’s signature below.
22nd March 2021