Statement under the Modern Slavery Act 2015
Introduction
This statement is made on behalf of Sea Change London Limited (SCL).
SCL is a niche consultancy business in the Lloyd’s and London insurance markets. Our policies and procedures are designed to ensure that we are supportive of our employees at all times, and that our suppliers operate to the highest ethical and business standards.
We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or supply chains.
Because of the nature of our business size and activities, the risk of our organisation becoming involved in the support or encouragement of slavery or human trafficking is very small. For this reason, other than the processes and procedures described in this statement, no other specific activities have been undertaken by SCL in respect of slavery and human trafficking.
Organisational Structure
SCL has its head office in London, UK
Our Business
SCL’s business consists entirely of supplying consulting services to insurance firms and intermediaries in the London and international re/insurance market. We are not licensed to carry out insurance activities, nor to act as producer or retailer of physical goods, and have no supply chain relating to such activities.
Our Policies
Modern Slavery and Human Trafficking Policy
Our modern Slavery Act Policy reflects latest guidance. This policy applies to all persons working for us or on our behalf in any capacity, including employees, directors, contractors, external consultants, agency representatives and business partners.
Our Supply Chains
As a provider of consultancy services to our customers, our supply chains are very limited. We outsource some ancillary functions relating to our consultancy services from professional firms. We also engage external parties to provide support services to our firm. We undertake ongoing review of our existing supplier contracts / agreements and assess the risk associated with those suppliers, based on sector and jurisdiction. This includes reviewing how we can reduce the potential for risk of modern slavery in our supply chain.
Our approved clause “the supplier shall comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including but not limited to the Modern Slavery Act 2015; and comply with the Anti Slavery Policy and maintain throughout the terms of this agreement its own policies and procedures to ensure its compliance”. The clause is now included where appropriate in all newly entered into supplier contracts or other terms.
Due Diligence Processes for Slavery and Human Trafficking
SCL operates a set of risk management policies and procedures designed to identify and mitigate a wide range of risks, including that of suppliers or business partners engaging in illegal or improper activity. These include our Fraud, Anti Bribery & Corruption and Conflicts of Interest policies, as well as our onboarding process for any new associate to verify ID and ability to work in the UK. Implementation of and adherence to these policies is continuously monitored by SCL management.
These policies and procedures, in combination with SCL’s commitment to ensuring that its employees act ethically at all times, enable us to identify and minimise the risk of slavery and human trafficking occurring within our organisation and our supply chains. We will seek to promote adherence to our policy on slavery and human trafficking by our material third party suppliers through our outsourcing and audit procedures.
Training
In order to promote awareness of the risks of slavery and human trafficking, we will communicate this policy to our staff and associates include it as part of the induction materials provided to all new employees, associates and partners.