Anti-Slavery and Human Trafficking Statement
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
Statement by the Chairman of Lancashire Holdings Limited
We are proud of the conditions of employment for all our employees throughout the Lancashire Group. Given the nature of our business, our boards 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, the Lancashire Group is involved in, supportive of, or complicit in slavery and human trafficking. The employment and procurement practices operated by the companies within the Lancashire Group ensure that those companies 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 suppliers with which we do business within our very limited supply chains.
About us and organisational structure
Lancashire Holdings Limited (Lancashire) is the holding company for a group of companies providing global specialty insurance and reinsurance products and services (together referred to as the Lancashire Group). Lancashire is incorporated and domiciled in Bermuda and has a premium listing on the London Stock Exchange. The companies within the Lancashire Group (which include UK incorporated companies including, but not limited to, those detailed in Schedule 1 to this statement) 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 operates from two main offices located in London and Bermuda and has over 200 employees worldwide. The Lancashire Group conducts the majority of its business 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 insurance and reinsurance solutions which are a type of financial services product and so we consider the risk of modern slavery or human trafficking existing within our business or our supply chains to be relatively low. We have a limited supply chain, predominantly comprised of professional services firms and firms providing 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. It also 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.
The Lancashire Group is committed to operating a responsible business to the benefit of all its stakeholders and respects, supports and complies with all relevant local Bermudian and UK legal requirements to which it is subject.
Due diligence and implementation processes to mitigate the risk of slavery and human trafficking
As part of our initiative to identify and mitigate risk (including in relation to that of slavery and human trafficking) we operate a range of controls and 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;
- Whistleblowing; and
- Anti-money laundering, bribery and financial crime.
The Lancashire Group also articulates a series of employee rights and benefits available to employees in the employee handbook and individual contracts of employment for each member of staff.
The Lancashire Group is an equal opportunity employer and does not tolerate discrimination of any kind in any area of employment or corporate life. We value and seek to promote human rights through integration in our business practice, for example, in our activities as an employer, in our underwriting and (re)insurance activities, in the management of our investment portfolio, in our procurement practices, in our wide ranging programmes of compliance, ethics and risk management and in our corporate responsibility activities, in particular the work of the Lancashire Foundation.
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. The board of each of the principal subsidiary operating companies is required to note and agree 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 operates in the UK as an accredited Living Wage employer by the Living Wage Foundation. This helps ensure that our employees and third-party contracted staff are paid in line with London Living Wage standards.
We 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 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 to demonstrate our zero-tolerance approach. References to this statement are included as part of the Lancashire 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 Modern Slavery Act 2015. Although Lancashire itself is incorporated in Bermuda, it recognises the importance of these issues for all the Lancashire Group companies and the Group’s stakeholders. Accordingly, this statement should be considered to constitute the anti-slavery and human trafficking statement for Lancashire and all companies within the Lancashire Group (in particular those listed at the end of this statement in Schedule 1) for the financial year recently closed, the current financial year and all future financial years until it may be modified or amended.
Lancashire Group companies to which this statement applies:
- Lancashire Holdings Limited
- Lancashire Insurance Company Limited
- Lancashire Insurance Holdings (UK) Limited (*UK incorporated)
- Lancashire Insurance Services Limited (*UK incorporated)
- Lancashire Insurance Company (UK) Limited (*UK incorporated)
- Lancashire Capital Management Limited
- Lancashire Syndicates Limited (*UK incorporated)
Chairman of Lancashire Holdings Limited
Date: 28 July 2020
The Lancashire Group's Policy on Diversity
Lancashire Holdings Limited’s Chairman’s statement on diversity policy and on the representation of women on the board of directors and within executive and senior management and in relation to ethnic diversity
The Board of Lancashire Holdings Limited (“LHL”) (the “Board”) has updated and approved the following statement on the representation of women on the board of directors, on executive committees and in senior management and in relation to ethnic diversity:
“The Hampton-Alexander Review (the “Review”), chaired by Sir Philip Hampton, Chair of GlaxoSmithKline, published its first report in November 2016. The Review builds on the work of the voluntary business-led approach of the Davies Review and reiterates the recommendation that listed companies adopt a 33% minimum target for women on boards and executive committees (and direct reports) by 2020. In the spring of 2016 the UK Treasury published the “Women in Finance Charter” (the “Charter”) inviting financial services firms to become signatories. Signatories to the Charter are asked to commit to the adoption of internal targets on gender diversity, as well as other steps for the monitoring, advancement and reporting of gender diversity.
In October 2017, the Parker Review Committee published its final report into the ethnic diversity of UK boards and recommended that each FTSE 250 board should have at least one director of colour by 2024 and that, led by board chairs, existing board directors of FTSE 350 companies should mentor and/or sponsor people of colour within their own companies to ensure their readiness to assume senior managerial or executive positions internally or non-executive board positions externally.
In recent years the importance of diversity has been extensively discussed by the Board. Whilst wholly sympathetic to the objective of increasing the range of useful diversity within the business, until February 2018 the Board had previously decided not to adopt a fixed percentage target for gender diversity (or any other one feature of diversity), in case doing so might compromise the paramount objective of identifying the person with the skills and experience best suited to any particular role.
Further to debate during 2017, the Board decided for LHL to adopt a 33% goal for the representation of women on the Board and the Group’s principal executive committee by 2020. The Board has not adopted any formal goal with regard to ethnic diversity on the Board but will keep this matter under review. In particular, the Board will ensure that the processes for the selection of LHL Directors address the need to consider and appoint candidates with a diverse range of backgrounds, experience and perspectives to the ultimate benefit of the business and its stakeholders.
Both on the Board, within the executive management team and throughout its business, the Lancashire Group has for many years benefitted from gender and other forms of diversity. As at 30th June 2020, the percentage of female representation on the Board stood at 37.5%, within the executive management team (excluding LHL Non-Executive Directors) the percentage stood at 40.9% and the percentage of female employees (excluding contractors) within the Lancashire Group stood at 38.5%.
The business does not currently formally monitor the composition of the business by reference to aspects of ethnicity and, on balance, considers this to be the right approach. The Board still believes that the skills and experience needed to take the business of the Group forward are of paramount importance in selecting Board members and employees. Accordingly, the gender diversity goal should not be treated as a “black line” but rather a flexible target against which the business should periodically measure its performance and strategy. Balanced against the attainment of the stated gender diversity goal should be the need to identify “the best person for the job” to best advance the business and interests of the Group and its stakeholders. Given the importance of this and the desirability of ensuring that the stated goals are to be applied flexibly, whilst sympathetic to the objectives of the Charter, the Board remains of the view that LHL is not able to become a formal signatory to the Charter.
Peter Clarke, as Chairman of the Board and the Nomination and Corporate Governance Committee, will be accountable to the Board for monitoring progress on gender diversity and other diversities, and in ensuring that appropriate performance objectives are set for Executive Directors, appropriately linking the pay of the senior executive team to the delivery of the gender diversity goals and ensuring the benefits of a broad diversity and the strategic objectives of the business.
In compliance with the FRC’s UK Corporate Governance Code, since 2012 a description of the Board’s policy on diversity, including gender, has been included in LHL’s Annual Reports, together with statistics relevant to the gender composition of the Board, Group management and overall Group employees.”