Lancashire Holdings Limited - Anti-slavery and human trafficking statement made on behalf of all companies within the Lancashire Group further to the provisions of the UK Modern Slavery Act 2015
We are proud of the conditions of employment for all our employees throughout the Lancashire Group. Given the nature of our business, our board and management teams each consider that there is minimal risk that, either within the Lancashire Group or the very limited supply chains which support our business activities, that are in any way involved in or even tangentially supportive of, or complicit in slavery and human trafficking. The employment and procurement practices operated by the businesses within the Lancashire Group ensure that the companies within our Group are rightly viewed as excellent and supportive employers. And to the extent that our Group companies operate as a purchaser of goods or services we expect a high level of ethical conduct from those businesses with which we do business within our very limited supply chain.
Lancashire Holdings Limited (Lancashire) is the holding company for a group of companies providing insurance and reinsurance products and services (together referred to as the Lancashire Group). Lancashire is incorporated in Bermuda with its head office located in London. Lancashire has a premium listing on the London Stock Exchange. The companies within the Lancashire Group are either regulated insurance and/or reinsurance companies and service companies or serve a purpose ancillary to the Lancashire Group’s principal activities in insurance and reinsurance. The Lancashire Group currently operate from two principal offices in London and Bermuda and has just under 200 employees worldwide. The Lancashire Group operates principally in the UK and Bermuda but is licensed to underwrite insurance and reinsurance business in a large number of jurisdictions around the world.
Our supply chains
The Lancashire Group’s supply chains are very limited. The Lancashire Group offers reinsurance and insurance solutions which are a type of financial services product. We do use routine services for the maintenance and support of our office operations in London and Bermuda, such as cleaning and technical support services for such things as air conditioning, IT, telephones and communications infrastructure. We do not act as a producer, manufacturer or retailer of physical goods and have no supply chain in relation to such activities.
Anti-slavery Policy statement:
“The Lancashire Group has zero tolerance to slavery and human trafficking and is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.”
This Anti-Slavery Policy Statement is the principal articulation of the Lancashire Group’s policy on slavery and human trafficking. It is intended to inform and influence all the operational procedures within the Lancashire Group.
Our stated Anti-Slavery Policy Statement 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 (amongst our other priorities) that slavery and human trafficking is not taking place anywhere in our business or related supply chains.
Due diligence and implementation processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk (including in relation to that of human trafficking and slavery) we operate a range of policies and procedures appropriate to the different companies within the Lancashire Group. These include the policies and procedures in the following areas:
Third party provider and outsourcing;
- Anti-money laundering, bribery and financial crime.
The Lancashire Group companies also articulate a series of employee rights and benefits available to employees in the employee handbooks and individual contracts of employment for each member of staff.
The Lancashire Group operates an HR department led by the Group Head of HR, a Legal and Compliance Department led by the Group General Counsel, an internal audit department led by the Group Head of Internal Audit and also employs a Group Chief Risk Officer. Each of the subsidiary operating companies has a Chief Executive Officer or Managing Director who have reviewed and agreed to the terms of this statement. Each of these departments and executives have reporting responsibilities to management and the various boards of companies within the Lancashire Group. The Lancashire Group uses the services of its external auditors and Lancashire’s audit committee receives quarterly update reports from the external auditors and the internal auditors. A combination of these procedures and functions operates to help identify, assess and monitor potential risk areas in our supply chains and mitigate the risk of slavery and human trafficking occurring in our supply chains.
It should be specifically noted that the Lancashire Group subscribes to the London Living Wage scheme in collaboration with the landlords and the other tenants at 20 Fenchurch Street. This helps ensure that cleaning and office support services supplied within London are provided to the Lancashire Group in line with UK living wage standards.
The statement articulates the formal Anti-Slavery Policy Statement for the Lancashire Group. In future we will seek to ensure when entering into material contracts that all those in our supply chain and contractors comply with our stated Anti-Slavery Policy in particular when seeking tenders for service or when auditing our suppliers.
We will communicate this statement to all our staff to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business and in future will include references as part of the Group’s training and information materials.
Legal and regulatory purpose of this statement
This statement is made with regard to the obligations arising under section 54(1) of the UK’s Modern Slavery Act 2015 (the Act). Although Lancashire itself is incorporated in Bermuda and is not formally subject to the requirements of the Act, it recognises the importance of these issues for all its stakeholders. Accordingly this statement should be considered to constitute the slavery and human trafficking statement for Lancashire and all companies within the Lancashire Group for the financial year recently closed, the current financial year and all future financial years until it may in future be modified or amended.
Chairman of Lancashire Holdings Limited
Date: 15 February 2017
The Board of Lancashire Holdings Limited has updated and approved the following statement on the representation of women on the Board of Directors, on executive committees and in senior management:
“In the “Women on Boards” report of February 2011, Lord Davies recommended that FTSE 350 companies should set their own targets for female representation on the board of directors. In his review report issued in April 2013, Lord Davies further recommended that FTSE 350 companies, by the end of September 2013, set out the percentage of women they aim to have on both their executive committees and in senior management levels. In October 2015 Lord Davies recommended that the voluntary target for women’s representation on boards of FTSE 350 companies should be raised to a minimum of 33% to be achieved in the next five years. In the spring of 2016 the UK Treasury published the “Women in Finance Charter” (the “Charter”) inviting financial services firms to become signatories. Subscribers are asked to commit to the adoption of internal targets on gender diversity.
In recent years this subject has been discussed by the Board. Whilst wholly sympathetic to the objective of increasing diversity, the Board remains of the view that the skills and experience needed to take the business of the company forward are of paramount importance in selecting Board members, members of executive committees and senior management and that it is not appropriate to adopt a fixed percentage target for any one feature of diversity, in this case gender, in case doing so compromises the paramount objective. And it is not obvious that gender diversity should be treated differently from other diversity issues. The Board has therefore decided not to subscribe to the Charter but is supportive of its broad objective.
We are actively engaged in expanding and improving the quality of experience and perspective of the Lancashire Board of Directors and have every intention of steering those efforts towards more female Board representation. Within the executive management team and throughout its business, the Lancashire Group has for many years benefitted from a broad gender diversity. Having discussed these issues with a number of the company’s major shareholders (and previously with Lord Davies himself) we have found amongst the company’s shareholders no appetite to compromise the paramount objective of seeking to maintain an effective Board of Directors and management team for the company. Both the company’s shareholders and stakeholders will note that as at July 2016, the percentage of female representation on the Board of Lancashire Holdings Limited stood at 28.6%.
In compliance with the FRC’s UK Corporate Governance Code, since 2012 a description of the LHL Board’s policy on diversity, including gender, has been included in the Company’s Annual Reports, together with statistics relevant to the gender composition of the LHL Board, group management and overall group employees.”