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 2021.
Howden Group has always been a company with a difference – with employee ownership at its heart and clients at the front of its mind.
Founded in 1994 as a specialist D&O broker, we were by definition the smallest broker in the world. Today, the Group comprises Howden, the largest non-US broker in the world and DUAL, one of the largest international MGAs in the world, with £1.4bn in revenue and managing premiums of more than £12bn. We are a group of international experts with a local touch and a digital backbone. Alongside our long term, aligned growth equity investors, employees make up the single largest shareholder group.
The Group is committed to ensuring that it carries out its business dealings in compliance with the relevant laws. 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 working with our suppliers to tackle modern slavery.
This statement covers the activities of the Group which is headquartered in London and, excluding A-Plan Holdings, has over 6,200 employees in entities across the world.
For the purposes of our FY21 statement, A-Plan Holdings acquired in March 2021 will be reporting separately for the period 1 March – 30 September 2021 with the plan to align statements and activity in FY22. You can see their latest statement here.
The Group has a devolved governance and operating structure. 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 commits to being 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.
As a signatory to the UN global compact and our commitment to their ten guiding principles, which in particular cover human rights, labour standards, environmental protection and anti-corruption, we published our first Communication on Progress.
We operate a suite of policies adopted within the Group’s companies that reflect and embed its commitment to human rights. The Sustainability Committee is tasked with furthering environmental, social and governance interests internally and externally.
We undertake an annual internal ESG benchmarking assessment, which includes sections specifically on our employees, clients, human rights and supply chain to ensure we understand our ESG baseline and are able to identify where risks may lie and how we can improve.
We have analysed our FY21 data are now working with ESG leads from across the Group to improve our policies and procedures to ensure we continue to share best practice, whilst also being sensitive to local regulations and legislation worldwide. This is part of our ongoing commitment to human rights.
We respect human rights standards for the workforce of our suppliers and 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 that have signed to the Universal Declaration of Human Rights or equivalent.
To date, no infringements on human rights have been reported. Still, should a human rights risk be identified, we will involve the Group Sustainability Committee and Group Services’ including HR, risk, procurement, operations and communications, to address and mitigate future human rights risk.
Supply chain management
In our own operations we have zero tolerance for any forms of slavery or servitude and understand our duty to respect human rights. We work with our colleagues and suppliers to uphold our standards and address the risks of modern slavery. Contractors and suppliers are 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.
Supply chain management continues to be a work in progress, and we are strengthening our controls as new contracts are agreed. We are including modern slavery questions within our due diligence questionnaire and training/raising awareness communications amongst employees.
We are presently 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. We have created a set of UK procurement principles that have been shared with all key subsidiaries.
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.
In FY21, the Group identified a series of risk categories specifically identifying ESG and operational risk categories. These include consideration of employee wellbeing and employer/employee relations which will be embedded from FY22 onwards as part of second-line work at the Group and the subsidiary levels. We’re working closely with our colleagues, our suppliers and our stakeholders to continuously improve our approach in a way that respects human rights.
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. We’re working hard to make sure that what we say in these policies happens in practice – and to embed our procurement principles across the business. 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.
The Group has an Incident Report link displayed prominently on its webpages. Anyone can report an incident that 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. This independent reporting line is widely advertised across all UK offices and monitored by our Group COO and our Group Chief Corporate and Legal Affairs Officer.
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 all disclosure routes, no calls or direct disclosures were made in 2021 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.
We also verify that employees have supplied proof of address/residence in the UK. The Group is also actively adopting more inclusive hiring practices globally by 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 the 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.
Equally, we ask our recruitment partners to submit balanced shortlists to support our diversity and inclusion agenda further. Finally, we conduct quarterly and annual business reviews with our recruitment agencies to ensure we’re driving the delivery of high-quality and diverse shortlists, ensuring 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 a period of sickness
- The freedom to complain directly or via our whistleblowing policy is free of charge.
The above are all monitored by the respective HR Business Partners, COO’s and Chief Risk Officers and are made available by our global communications platform, ensuring that all employees have access to the whistleblowing policy and phone number should they believe that they are not being fairly treated or have any other concerns. In 2021, there were no breaches of basic rights reported.
In February 2022, we launched our worldwide employee engagement survey to over 6200 employees. Giving our people the opportunity to tell us how they feel is important to us. Understanding how engaged they are, what matters to them, where we are doing well and taking action on areas where we can improve is key to building a truly People First business. In our 2022 survey, we have included questions on inclusion and sustainability, in addition to engagement, as these are key focus areas for us as a Group.
Our last employee engagement survey in April 2020 was a timely opportunity to reach out to our employees at a time of unprecedented change. The survey measured engagement across a number of factors such as work/life balance and growth & development, as well as our emergency response to COVID-19. Participation was high, with 86% of employees choosing to share their views. The survey provided some good feedback and insights into how employees felt, and our overall engagement score was 80%.
As we begin to analyse the results of our 2022 survey, we will be supporting our local businesses in creating their local action plans.
The wellbeing of our employees is an important focus for us. This has been especially so through recent years with the global pandemic. We provide a range of support for our employees through our employee benefits packages, including a global employee assistance program in many of our international locations and specific local benefits provisions to support employee wellbeing in particular jurisdictions.
For example, in the UK we have created a wellbeing hub that is accessible to all UK employees providing support on:
- Physical and mental wellbeing
- Signposting to wellbeing champions (trained mental health first aiders)
- Wellbeing benefits, e.g. Digital GP, private medical insurance, Thrive mental health app
- Financial wellbeing
- Support for parents and carers
- Our Employee Assistance Programme also provides staff with a secure and confidential way of seeking advice about any modern slavery or human trafficking issues personally affecting them or their families.
Code of Conduct
With effect from 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.
understanding and compliance with the new Senior Managers & Certification Regime (SMCR) Conduct Rules. This mandatory training has been made available since October 2020. 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 that is updated annually. Our internal audit team regularly audit the team against this, and 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 2021, there were no incidents relating to modern slavery identified within audits performed across the Group.
In 2021 we worked with our compliance training providers and Associateship of the Chartered Insurance Institute (ACII) to introduce a modern slavery module into Group-wide UK compliance training for all employees. This started to be rolled out for employees in January 2022, and we are exploring supplementary raising awareness and training for employees in high-risk areas.
Our modern slavery and human trafficking statement for the financial year ending 2021, has been approved by the Board, as reflected by the Group CEO’s signature below.
David Howden, Group CEO
15th March 2022