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 250 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 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 practices, 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 a Risk Management department led by the 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, the internal auditors and the Legal and Compliance department. Furthermore, all members of staff have the option to raise any concerns with the Chair of the Audit Committee or the appointed Whistleblowers' Champions. 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 provide training and 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.
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
- Cathedral Capital Holdings Limited (*UK incorporated)
- Lancashire Syndicates Limited (*UK incorporated)
- Cathedral Capital (1998) Limited (*UK incorporated)
Chairman of Lancashire Holdings Limited
Approved by resolution of the LHL Board on 28 April 2021
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
Purpose and Scope
This Policy sets out the approach of the Board of Directors (the ‘Board’) of Lancashire Holdings Limited (the ‘Company’) to diversity and inclusion. This Policy applies to the Board and, by extension, to the executive management team as regards the goal set out below.
The Board recognises the benefits that diversity can bring, and has brought, across all levels of the Group. As a part of this, the Board understands the importance of appointing directors with a wide range of backgrounds, skills, experience, knowledge, gender, ethnicity and diversity of thought, bringing together different perspectives and the challenge needed to maintain an effective Board and ensure optimal decision-making.
Balanced against the attainment of any stated goal should be the need to identify the best person for the role to best advance the business and interests of the Group and all its stakeholders.
The Board supports the aim of promoting greater diversity in the boardroom, within the executive management team and throughout the business.
In line with the recommendations set out in the Hampton-Alexander Review on gender diversity, the Board has adopted a 33% goal for the representation of women on the Board and Group’s principal executive management team. As at the 30 June 2021, the percentage of female representation on the Board stood at 44.4% and within the executive management team at 50%. In line with the recommendations set out in the Parker Review on ethnic diversity, the Board has adopted the Parker Review goal to have at least one qualifying director on the Board by 2024. The Board is aware that due to its relatively small size, the appointment or departure of a single director or a member of the executive management team may temporarily impact upon the achievement of these goals.
The Board will continue to explore other opportunities to further improve diversity.
Nomination, Corporate Governance and Sustainability Committee Responsibilities (the ‘Committee’)
In accordance with its terms of reference, the Committee discharges its responsibilities relating to Board composition, appointments and succession planning, whilst having regard to its role in applying this Policy.
Specifically, the Committee shall:
· Regularly review and evaluate the structure, size and composition (including the skills, knowledge, experience and diversity) of the Board and make recommendations to the Board with regard to any changes.
· Ensure plans are in place for orderly succession to the Board and regularly review the succession plan and talent development programme in place for senior management positions, which has the objective of developing a diverse workforce and pipeline to meet the needs of the business.
· Identify and recommend suitable candidates for appointment to the Board, based on merit against objective criteria, and with due regard to the right balance of skills, experience, knowledge, independence and diversity required for the Board to operate effectively, as a whole.
· Ensure that any independent external search firm it engages to assist with Board appointments sources candidates from a broad and diverse range of backgrounds and perspectives and has a clear understanding of this Policy.
The Chairman’s and the Executive Directors’ Responsibilities
Peter Clarke, as Chairman of the Board and the Committee, is accountable to the Board for monitoring progress on gender, ethnicity and other forms of diversity. In particular, boardroom diversity is considered annually as part of the Board’s performance evaluation. Furthermore, appropriate performance objectives are set for the Executive Directors, appropriately linking their remuneration to the delivery of a diverse, successful and sustainable business.
Monitoring and Reporting
In compliance with the FRC’s UK Corporate Governance Code, a description of this Policy, its implementation and the process used by the Committee in relation to Board appointments is included in the Company’s Annual Report, together with statistics relevant to the gender balance of the Board, executive management team and their direct reports and overall Group employees.
Review of this Policy
This Policy and its effectiveness are subject to review by the Committee, at least annually, with any recommendations made to the Board for approval.
Approved by the Board of Lancashire Holding Limited on 27 July 2021