This statement is made pursuant to Section 54, Part 6 of the U.K. Modern Slavery Act 2015 and sets out the steps the Company has taken to ensure that slavery and human trafficking are not taking place in its business and supply chains for the financial year ending 31 December 2025.
Our business and structure
The Company operates as part of a global healthcare and insurance services organisation providing international medical insurance and related services. The Company engages a limited number of third-party suppliers to support its operations.
The Company recognizes its social responsibility in the communities in which it operates. As part of the Company’s Compliance & Ethics program, the Company and its employees receive training on and must adhere to a Code of Conduct. The Code of Conduct, and the various written policies that support it, are designed to create a culture of ethics and integrity and to facilitate compliance with the laws of all jurisdictions in which the Company operates.
The Company opposes and prohibits the use of human trafficking, child labor, slavery and slave labor, and it expects the same from its business partners and suppliers. As a global business, the Company is committed to compliance with all applicable labor laws, including the U.K.’s Modern Slavery Act.
A core tenet of the Company’s Code of Conduct is that the Company “will not tolerate behavior that endangers” its business partners, and the Company’s Combatting Trafficking in Persons policy requires employees and business partners alike to abide by applicable labor laws. The Company also conducts risk-based due diligence on its business partners, depending on the potential risk presented by that relationship.
Risk assessment and management
Given the nature of the Company’s business and the sectors in which it operates, the risk of modern slavery is considered to be low. However, the Company continues to assess potential risks within its operations and business relationships.
The Company’s Compliance & Ethics program provides relevant training and a number of venues through which its employees, contractors and business partners can report concerns regarding potential misconduct without fear of retaliation.
The Company is committed to ensuring that it does not engage with business partners that violate applicable labour laws or the principles of the U.K. Modern Slavery Act.
Effectiveness
The Company monitors the effectiveness of its policies and procedures through its Compliance & Ethics programme, including training completion and internal reporting mechanisms.
The Code of Conduct, and the various written policies that support it, are designed to create a culture of ethics and integrity and to facilitate compliance with the laws of all jurisdictions in which the Company operates.
The Company is operating under the highest ethical business standards and requires its business partners and suppliers to follow the same practices.
Our compliance screening processes, and enhanced due diligence programmes are tailored to challenges posed by a global network of providers and our global supply chain:
- World Check screening of entities and Special Designated Nationals (SDNs)
- Sanctions restrictions monitoring to identify associates of sanctioned entities that could be tied to human rights violations.
- Politically Exposed Persons (PEPs) PEP monitoring connections with individuals in power with opportunity to facilitate or prompt human trafficking activities.
- Beneficial ownership
- Negative media publicity
- Risk-based approach prompting enhanced due diligence.
We have effective systems and controls in place to prevent unauthorised contracting. Upon entering a new contract, our designated Enterprise Sourcing & Procurement and Compliance team conduct risk assessments, preliminary checks and screening to prevent agents and subcontractors at any tier and at any monetary value from engaging in trafficking in persons and to monitor, detect, and terminate any agents, subcontracts, or subcontractor employees that have engaged in such activities.
Company Master Service Agreements include a mandatory Modern Slavery Act clause requiring compliance with the act: “Slavery/Human Trafficking.” At a minimum, the Vendor / Supplier/
The Company requires its business partners to comply with relevant labor laws and, where applicable, the relevant provisions of the U.K. Modern Slavery Act.
Business Partner represents and warrants that (i) to the best of its knowledge, it has not been and is not currently subject to any action, suit, proceeding, or claim formally commenced or pending, or any investigation with respect to slavery or human trafficking; and
(ii) it has not and will not engage in any activity, practice or conduct that would constitute an offence under modern slavery laws.
Our 2026 Modern Slavery Transparency Statement has been updated taking into consideration new regulatory requirements and parameters such as:
- United States’ Bureau of International Labor Affairs (ILAB) List of Goods Produced by Child Labor or Forced Labor
- Global Slavery Index contains national estimates, calculated by the Walk Free Foundation, on the basis of a predictive model that accounts for individual and country-level risk factors.
- United Nations (UN) Guiding Principles on Business and Human Rights
- International Labor Organization’s (ILO’s) Declaration on Fundamental Principles and Rights at Work
The Company reserves the right to terminate business with a vendor, supplier or business partner that fails to comply with our Code of Conduct or with applicable law and regulations.