Modern Slavery Act
TMK Modern Slavery Act Statement 2021
This Statement is made pursuant to Section 54 (1) of the Modern Slavery Act 2015 and constitutes Tokio Marine Kiln Group Limited’s (TMKGL) Slavery and Human Trafficking Statement for the financial year ended 31 December 2020.
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 and supply chains
This Statement covers 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).
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’s supply chains comprise third party suppliers and subcontractors. We use suppliers and contractors for goods and services required for the maintenance and support of our 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.
The Covid-19 pandemic has not materially affected the risks of slavery and human trafficking to TMK, nor its ability to assess and address the risks. TMK has prioritised the health and well being of its staff and business partners throughout the pandemic and has ensured that local and national guidelines have been followed.
TMK Policies, Initiatives and Procurement Processes
TMK is committed to preventing slavery and human trafficking in its corporate activities and uses its best endeavours to ensure that its supply chains are free from slavery and human trafficking.
TMK operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.
- Whistleblowing Policy TMK encourages all its employees, customers and other business partners to report any concerns related to its activities. The organisation's whistleblowing procedure ensures that concerns can be raised without fear of retaliation.
- Code of Business Conduct & Ethics TMK’s Code makes clear to employees the actions and behaviour expected of them when representing TMK. TMK strives to maintain the highest standards of employee conduct and ethical behaviour. This includes compliance with all laws and regulations; avoiding bribery; the proper and fair treatment of all employees; and fairness throughout the supply chain.
- Financial Crime Policy TMK is committed to preventing all aspects of financial crime in its transactions, 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 which states the standards 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.
TMK has established an Environmental, Social and Governance Committee of the TMKS Board which considers ethical matters and is empowered to commission external and independent reviews of TMK’s approach to ethical matters. Employee-led Ethics sub-groups of the Committee have been formed, one of which is focused on ethical issues within the supply chain.
TMK’s anti-slavery and human trafficking initiatives include:
- Policies: HR and the Company Secretariat take responsibility for ensuring that modern slavery requirements are reflected in TMK’s Code of Business Conduct and Ethics.
- Risk assessments: Risk analysis will be completed 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 at:
TMK undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. An integrated two-stage process is used for considering new suppliers, in a process run by an outsource partner.
As part of the procurement due diligence process, prospective suppliers are asked 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. This information is gathered by the outsource partner on TMK’s behalf and then verified by TMK.
- All suppliers are monitored on an ongoing basis, with the more material suppliers being checked on a quarterly basis. Where there is less perceived risk, the suppliers are monitored every six months. 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.
- 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.
TMK requires all employees to be aware of the Modern Slavery Act Statement. To improve awareness, TMK will make a commitment to deliver important messages relating to modern slavery, including:
- communicating the basic principles of the Modern Slavery Act 2015;
- providing resources on how employers can identify and prevent slavery and human trafficking;
- providing information on where to go to for advice and what external help is available.
Information on the Modern Slavery Act Statement is included in the 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.
Mandatory training is complete 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.
Review and approval of this Statement has been delegated to the TMKGL Board on behalf of the TMK Group by the Boards of TMKI, TMKS and TMKIS. The Statement will be reviewed on an annual basis, updated and re-published as appropriate.
This Statement was approved by the TMKGL Board and the TMUL Board on 22 June 2021.