Anti-slavery statement

This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It applies to the operating companies of Aventum Group Limited and their operations in the United Kingdom and to all persons who work for or on behalf of Aventum in respect of such operations.

We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

The statement covers the period for the financial year ending 30 June 2022 and describes Aventum’s present and ongoing commitment to prevent modern slavery and human trafficking from taking place in Aventum supply chains and business.

Background

Aventum is a (re)insurance group that operates across both the underwriting and broking sectors. Aventum is registered in the United Kingdom and employs over 350 people the majority of whom are based in the United Kingdom and it transacts with customers on a worldwide basis. 

Aventum does not operate in a sector where modern slavery is prevalent and has not identified any modern slavery concerns.

Our policies on slavery and human trafficking

We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies.

Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due diligence processes for slavery and human trafficking

We have in place systems to:

·        Identify and assess potential risk areas in our supply chains.

·        Mitigate the risk of slavery and human trafficking occurring in our supply chains.

·        Monitor potential risk areas in our supply chains.

·        Protect whistle blowers. 

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking and expect our suppliers to manage their business and supply chain in a manner that respects human rights as set out in the International Bill of Human Rights and the UN Guiding Principles on Business and Human Rights

To ensure all those in our supply chain and contractors comply with our values we have in place a due diligence  supply chain  programme to assess our potential suppliers.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.

Approval

This statement has been approved by the Board on 31st January 2023. This statement is  reviewed and updated annually.

1. Policy statement

1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms,

such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have

in common the deprivation of a person's liberty by another in order to exploit them for personal or

commercial gain.

1.2 We have a zero-tolerance approach to modern slavery and we are committed to acting ethically

and with integrity in all our business dealings and relationships and to implementing and enforcing

effective systems and controls to ensure modern slavery is not taking place anywhere in our own

business or in any of our supply chains.

1.3 We are also committed to ensuring there is transparency in our own business and in our approach

to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations

under the Modern Slavery Act 2015.

1.4 We expect the same high standards from all of our contractors, suppliers and other business

partners and, as part of our contracting processes, we include specific prohibitions against the use

of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults

or children, and we expect that our suppliers will hold their own suppliers to the same high

standards.

2. About this policy

2.1 The purpose of this policy is to:

(a) set out our responsibilities, and of those working for and on our behalf, in observing and

upholding our position on modern slavery and human trafficking; and

(b) provide information to those working for and on our behalf on how to identify and report

concerns regarding modern slavery and human trafficking.

2.2 This policy applies to the operating companies of Aventum Group Limited ('Aventum') and their

operations in the United Kingdom and to all persons who work for or on behalf of Aventum in

respect of such operations, including employees at all levels, directors, officers, agency workers,

seconded workers, volunteers, interns, agents, contractors, external consultants, third-party

representatives and business partners.

2.3 This policy does not form part of any employee's contract of employment and we may amend it at

any time.

3. Responsibility for the policy

3.1 The Board of Directors has overall responsibility for ensuring this policy complies with our legal

and ethical obligations, and that all those under our control comply with it.

3.2 The Compliance team has primary and day-to-day responsibility for implementing this policy,

monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control

systems and procedures to ensure they are effective in countering modern slavery.

3.3 Management at all levels are responsible for ensuring those reporting to them understand and

comply with this policy and are given adequate and regular training on it and the issue of modern

slavery in supply chains.

4. Your responsibilities and how to raise a concern

4.1 You must ensure that you read, understand and comply with this policy.

4.2 The prevention, detection and reporting of modern slavery in any part of our business or supply

chains is the responsibility of all those working for us or under our control. You are required to

avoid any activity that might lead to, or suggest, a breach of this policy.

4.3 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts

of our business or supply chains of any supplier tier at the earliest possible stage. All concerns

must be reported using our Whistleblowing procedure.

4.4

If you are unsure about whether a particular act, the treatment of workers more generally, or their

working conditions within any tier of our supply chains constitutes any of the various forms of

modern slavery, the matter should be referred to Compliance.

4.5 We aim to encourage openness and will support anyone who raises genuine concerns in good

faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one

suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern

slavery of whatever form is or may be taking place in any part of our own business or in any of our

supply chains.

5. Training and communication

5.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains,

forms part of the induction process for all individuals who work for us, and regular training will be

provided as necessary.

5.2 Our zero-tolerance approach to addressing the issue of modern slavery in our business and supply

chains must be communicated to all suppliers, contractors and business partners at the outset of

our business relationship with them and reinforced as appropriate on an ongoing basis.

6. Breaches of this policy

6.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal

for misconduct or gross misconduct.

6.2 We may terminate our relationship with other individuals and organisations working on our behalf

if they breach this policy.