Modern Slavery Act
TMK Modern Slavery Act Statement 2023
This Statement is made pursuant to Section 54 (1) of the Modern Slavery Act 2015 and constitutes the Tokio Marine Kiln Group’s (TMK) Slavery and Human Trafficking Statement for the financial year ended 31 December 2022.
TMK has a zero tolerance approach towards all forms of illegal and unethical behaviour. This statement sets out TMK’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking in its own business and its supply chains. TMK seeks to promote human rights in all business practices, including its commitment to corporate social responsibility.
As part of the insurance and financial services sectors, TMK recognises that it has a responsibility to take a robust approach to counter slavery and human trafficking.
Organisational structure, business and supply chains
This Statement covers Tokio Marine Kiln Group Limited (TMKGL) and all relevant subsidiaries of TMKGL that are incorporated in the UK. These include: Tokio Marine Kiln Insurance Limited (TMKI); Tokio Marine Kiln Syndicates Limited (TMKS); and Tokio Marine Kiln Insurance Services Limited (TMKIS). The Statement also covers the TMK associated entity, Tokio Marine Underwriting Limited (TMUL).
TMK provides a broad range of specialist insurance products, primarily written via the Lloyd’s of London specialist insurance market.
The majority of TMK’s core business is sourced through trading relationships with insurance intermediaries including brokers, agents and other third parties. TMK products which are distributed to clients through trading relationships with coverholders and brokers are done so with agreements which meet the standards set out by our regulators.
TMK policies in relation to slavery and human trafficking
TMK is committed to preventing slavery and human trafficking in its corporate activities and processes and uses its best endeavours to ensure that its supply chains are free from slavery and human trafficking.
TMK maintains a suite of policies that support its commitment to the identification of modern slavery risks and the steps taken to prevent slavery and human trafficking in its operations.
- Whistleblowing Policy TMK encourages all its employees, customers, service providers and other business partners to report any concerns related to its activities. TMK's whistleblowing procedure ensures that concerns will be taken seriously, investigated independently, treated as confidential and can be raised without fear of any detrimental treatment.
- Code of Business Conduct & Ethics TMK’s Code of Business Conduct & Ethics explains that all employees are expected to act in accordance with the highest standards of integrity and honesty. TMK strives to maintain the highest standards of employee conduct and ethical behaviour. This includes compliance with all laws and regulations, avoiding bribery, adherence to health and safety practices, the proper and fair treatment of all employees, and fairness throughout the supply chain.
- Financial Crime Policy TMK is committed to operating in a way that minimises the likelihood of it becoming a victim of financial crime or facilitating financial crime in any way, including fraud, money laundering, bribery, tax evasion, corruption, market abuse and anti-competitive behaviour, as well as ensuring that sanctions are observed. TMK has robust procedures and controls in place with which to detect and manage financial crime.
- Procurement Framework Procurement at TMK is managed by means of a robust framework for onboarding suppliers and ensuring that all parties TMK contracts to do business with demonstrate a commitment to ensuring fairness and ethical behaviour in their supply chains.
Due diligence processes in relation to TMK’s supply chains
TMK’s supply chains comprise third party suppliers and subcontractors. TMK uses suppliers and contractors for goods and services required for the maintenance and support of its business operations. As TMK operates mainly in financial and insurance related businesses, TMK does not act as a producer, manufacturer or retailer of physical goods and therefore the risk of modern slavery or human trafficking within its business or supply chains is considered to be relatively low.
TMK undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers.
As part of the procurement due diligence process, prospective suppliers are asked to complete a questionnaire and to provide various policies and procedures, which include a description of the activity they undertake to detect and prevent slavery and human trafficking within their networks. Other areas included in the due diligence process include understanding the physical location from which any supplier services are performed on behalf of TMK, establishing that TMK has the right to conduct supplier audits as necessary, and approval of sub-contractors.
New contracts with suppliers contain an explicit reference to compliance with the Modern Slavery Act 2015 as a standard contract term, where applicable.
If suppliers who are required to comply with the Modern Slavery Act 2015 do not have adequate procedures for preventing modern slavery and human trafficking, the relevant third party may not be approved for use.
Should a failing arise during the course of a contract, executive management will be advised and all options will be reviewed and appropriate action taken.
Assessment and management of modern slavery and human trafficking risk in TMK’s business and supply chains
TMK has established a Sustainability Committee of the TMKS Board which considers TMK’s strategic approach to environmental, social and governance (ESG) matters.
The Sustainability Committee has established a number of specialist working groups, one of which is focused on Social Responsibility matters, including responsible supply chains, responsible products and ethical business considerations.
The Sustainability Committee is empowered to commission external and independent reviews of TMK’s approach to ESG matters, including ethical matters, as appropriate.
TMK also has in place appropriate recruitment practices, using reputable employment agencies. Verification checks are completed for all new hires, to confirm individuals’ identities, references, evidence of qualifications, criminal and financial checks, and eligibility to work in the UK, as appropriate.
TMK’s other anti-slavery and human trafficking initiatives include:
- Risk assessments: Risk analysis to highlight any areas where modern slavery risks occur within the group business.
- To Be A Good Company: TMK has adopted the Tokio Marine Group Corporate Philosophy which includes "Acting as a good corporate citizen through fair and responsible management”.
More information can be found here.
Effectiveness in ensuring that modern slavery and human trafficking are not taking place in the business or supply chains
Suppliers are monitored on an ongoing basis, with the more material suppliers being checked on a quarterly basis. This ensures that suppliers continue to meet their
commitment to preventing modern slavery and human trafficking within their own business and supply chains, where appropriate.
TMK’s risk management processes and procedures are monitored by the Risk Management Team. This includes review of internal controls across the various business areas, people and culture considerations, adherence to risk appetites, and ESG matters. Risk reporting is provided to the TMK Group Boards and Committees on a regular basis.
Staff awareness and training
TMK requires all employees to be aware of the Modern Slavery Act Statement. To improve awareness, TMK is committed to delivering important messages to employees in relation to modern slavery, including:
- Communicating the basic principles of the Modern Slavery Act 2015;
- Providing resources on how employees can identify and prevent slavery and human
- Providing information on where to go to for advice and what external help is available.
Mandatory training is completed by all staff every year on whistleblowing and recognising and managing financial crime. Modern Slavery e-learning is also available to all staff on the TMK e-learning portal. Information on modern slavery is also included in TMK’s Code of Business Conduct and Ethics.
As part of the annual declaration process completed by all TMK employees, staff must attest that they have read and understood various TMK policies, including the Code of Business Conduct and Ethics, the Financial Crime Policy and the Whistleblowing Policy.
Review and approval of this Statement has been delegated to the TMKGL Board on behalf of the TMK Group subsidiaries and by the Boards of TMKI, TMKS and TMKIS. This Statement is also reviewed and approved by the TMUL Board.
The Statement is reviewed on an annual basis, updated and re-published as appropriate.
This Statement was approved by the TMKGL Board and the TMUL Board on 21 June 2023 and is signed on their behalf by:
Group Chief Executive Officer