MODERN SLAVERY ACT

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MODERN SLAVERY ACT STATEMENT (the “Act”)

April 2022

INTRODUCTION:

The Utmost Group is committed to working towards the eradication of slavery and human trafficking.  We are a global provider of insurance and savings solutions in the UK and Internationally.  The Group is owned by its two Founders and funds managed by subsidiaries of 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.

As a business that places corporate and social responsibility at the heart of its values, the Utmost Group 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 the Utmost Group or actions underway during the financial year ended 31 December 2021 and to date, to assist in the detection and prevention of modern slavery across its business operations and supply chains.

OUR BUSINESS 

The Utmost Group is a leading provider of modern, flexible solutions which assist our customers in securing their financial futures.  The Group has over 1,500 employees predominantly based in the UK, Ireland, the Isle of Man and Guernsey, with a small number of staff working in worldwide operations in locations across Europe, Singapore, Hong Kong, the Bahamas and the Dubai International Finance Centre.  

The Utmost Group recently completed the acquisition of the Quilter International business (“Quilter International”) and will be undertaking a project during 2022 to ensure that all practices across the Group to assist in the detection and prevention of modern slavery in operations are aligned.  In addition, work will be completed to review the Quilter International supply chain and assess whether there are any high-risk suppliers that require review.  

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

We are committed to preventing modern slavery or human trafficking in our supply chains or in any part of our business. The Group is committed to conducting business responsibly and upholding the highest standards of governance throughout our operating businesses. During 2021 the Group implemented its Group Corporate Governance Manual and Policy Suite framework, which alongside this statement contains relevant policies, such as our Corporate Social Responsibility Policy and Outsourcing Management Policy, which set out the necessary principles to manage and mitigate key risks and safeguard the business and all its stakeholders, including employees, suppliers, and customers. 

The Group’s approach to human rights extends beyond our supply chain, to employees and contracted staff and we are committed to paying the national living wage in the UK and its equivalent in the other jurisdictions in which we operate. The system of internal controls implemented by our operating businesses includes: –

  • Protecting employees and Whistleblowers 
  • Identifying and assessing potential risk areas in our supply chains.
  • Mitigating the risk of slavery and human trafficking occurring in our supply chains.

OUR EMPLOYEES 

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.

A new Group Code of Conduct (“Code”) was developed during 2021 which applies to all directors, officers, and employees, requiring that they adhere to the Code.  Our employees are 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.

The Group Whistleblowing Policy sets out requirements for reporting inappropriate, unethical, or otherwise activities that are inconsistent with the Code. This policy enables an employee to report any improper conduct or unethical behaviour via line management, senior management, the relevant Chief Risk Officer, Company Secretary, Head of HR or Chair of the Audit Committee.  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 the Non-Executive Directors of the relevant subsidiary company.  Employees may also raise their concerns with the Utmost Group Chairman, the Chairman of the Audit, Risk and Compliance Committee or if they deem it necessary, employees may wish to contact the applicable external regulator. At all times during any investigation the Whistleblower’s identity will be kept confidential.  All employees are reminded annually of their right to raise concerns under the Whistleblowing Policy, and to consult with associated guidance.

OUR SUPPLIERS

It is important to us that our commitment to human rights is shared by our suppliers. The Utmost Group 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 Group and its subsidiaries primarily consist of investment services, catering, cleaning, office furniture and stationery, electrical equipment, IT software, property maintenance and utilities.  

As the Utmost Group 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 a risk-based approach is taken to identify any high risk suppliers and prioritise them for review.

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 confirms they have adequate training and policies in place to comply with the Act and avoid slavery.

OUR ONGOING APPROACH AND NEXT STEPS

There is a commitment throughout the Group to ensure that we respect human rights and continue to act as a responsible business.  To achieve this, there is a Group Corporate Social Responsibility Policy in place which ensures that all employees of the Utmost Group are provided with ongoing training to ensure that there is the appropriate level of awareness and consistency across the entire business to detect and ultimately prevent modern slavery from occurring anywhere in our supply chain.  

This statement has been approved by the Board of Utmost Group plc and signed on its behalf by the Utmost Group CFO.