Modern Slavery Statement | PayingTooMuch
We understand that modern slavery is a global problem and defined as the serious exploitation of people through threats, coercion, or deception, which undermines or deprives them of their freedom. It is our purpose to help create a world whereby people and communities thrive not survive. We endeavour to create a balanced, sustainable society in which everyone can take part and build a better life – this includes our people, suppliers, customers, and communities.
We are committed to act, responding to this problem in line with our purpose. We understand that there are some areas within our operations whereby we may be exposed to potential modern slavery risks. Our commitment remains the same to continuously seek to improve our approach to identify, assess, and manage modern slavery-related risks.
We recognise that as organisations grows there could be an increased risk of contributing to modern slavery within our Group. However, our Executive Team, are committed to working with our overseas operations to ensure we utilise insights and data, working with our Risk and Compliance team to investigate modern slavery practices with the support of our People team including where appropriate, external legal support.
Our code of conduct, policies and due diligence procedures help to guide how we treat our people regardless of contract (permanent, fixed-term, casual) and work with our customers, suppliers and other business partners and communities in which we operate. These documents govern and influence our approach to respecting human rights, our ethics and values, and guide our decision making – across the group.
Our response to modern slavery this year was informed by our Executive Team; guided by our own experience and supported by our external legal team. To identify the risks across our operations and supply chain we reviewed risk factors including country, sector, type of work and vulnerable groups (migrant workers, women and children). Our risk assessment indicated the risk of modern slavery as higher through our overseas operation, lower risk for our employees, and moderate to low risk for our supply chains. To address these risks, we identified three areas to focus on across our operations and supply chain in 2021 and into 2022 which are detailed throughout this statement.
This statement sets out Staysure Group’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2021 to 31 March 2022.
We recognise that we are publishing this statement later than expected. This is because of increased difficulty in gathering the required information from our suppliers during the coronavirus pandemic.
As part of the Insurance industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking and we continue to take our responsibility very seriously during the coronavirus pandemic. Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Organisational structure and supply chains
This statement covers the activities of Staysure Group:
- We are predominantly a Travel Insurance Company that has historically offered medical travel insurance to the over 50s. Established in 2004 with the brand Staysure we have acquired a majority share of the additional brands Avanti and PTM.
- In 2021 Staysure Group purchased Travel brand Rock and completed full due diligence prior to its purchase to ensure there were no modern slavery risks.
- Also in 2021, Staysure Group launched their own pet insurance brand ‘Petsure’ and has gone through the same robust assessments as the core brands.
Countries of operation and supply
We currently operate in the following countries:
- UK- our Head Office is based in Northampton and offers after-sales and customer service support.
- The Group has a direct relationship with our supply chains, which includes some outplacement support for IT services and call centre operations.
- Gibraltar – TICORP is a part of the Staysure Group and ERGO our underwriter is contracted to TICORP.
- The following is the process by which the company assesses whether activities or countries are high risk in relation to slavery or human trafficking:
- We scrutinise supplier contracts to ensure that they a) have a modern slavery statement (if applicable) and b) have a code of conduct that matches our beliefs on how our suppliers should conduct themselves for the purpose of reducing the risk of slavery and human trafficking.
The following activities are considered to be at low risk of slavery or human trafficking:
- TICORP and Wapp abide by UK and Gibraltar law this means that their reward strategies are based on local benchmarked data and their hiring practices are based on the discretion of the senior leadership team within the country.
Responsibility for our anti-slavery initiatives is as follows:
- Policies: Our Chief People Officer is responsible for our Anti-Slavery policy and related policies. These policies are reviewed annually or in the event of any new legislation being published. The policies are created via the People Team, reviewed by the Board and once agreed, published.
- Risk assessments: Are conducted annually by the Executive Team led by the Group Risk and Compliance Director.
- Investigations/due diligence: Any required investigations / due diligence are mutually carried out by Risk and Compliance and the People Team, with external legal support if required.
- Training: To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, we conduct in-house training with annual refresher training which is verified by an assessment. For our supply chains and with our business partners, we ensure that they offer comprehensive training to their colleagues. Under their Supplier Code of Conduct we require our business partners to provide regular and relevant training to their staff, suppliers and providers and to provide us with their Modern Slavery statements annually (if applicable).
We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Whistleblowing policy
We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for our people to make disclosures, without fear of retaliation. Our people, customers or others who have concerns can contact HR confidentially via email, Microsoft Teams or phone.
- People code of conduct
Our code makes clear to our People the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of conduct and ethical behaviour when operating abroad and managing its supply chain.
- Supplier code of conduct
We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their workers’ working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship.
- Recruitment policy
We use only specified, reputable employment agencies to source candidates and always verify the practices of any new agency it is using before accepting candidates from that agency.
- Diversity and Inclusion
We recognise the importance of diversity and inclusion and the responsibility we own to improve social mobility. We ensure that all our recruitment policies and practices enable equality and are supported by our commitment to develop all our people regardless of background.
We undertake due diligence when considering taking on new suppliers, and regularly review our existing suppliers. Our due diligence and reviews include:
- mapping the supply chain broadly to assess product or geographical risks of modern slavery and human trafficking.
- evaluating the modern slavery and human trafficking risks of each new supplier
- conducting supplier audits or assessments through our Risk and Compliance department, which have a greater degree of focus on slavery and human trafficking where general risks are identified.
- creating an annual risk profile for each supplier.
- invoking sanctions, including the termination of the business relationship against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct.
We require all our people across the organisation to complete training on modern slavery as a module within our wider human rights/ethics/ethical trade training programme.
We require all our people to annually refresh their knowledge via our online Learning Management System by April the following fiscal year.
Our modern slavery training covers:
- An introduction explaining what modern slavery is including definitions, how they differ between adults and children and the role we play in combating modern slavery.
- General indicators explain how you might be able to identify possible threats/cases of modern slavery through examples and what to do if you suspect someone is at risk.
- The role sexual exploitation plays in modern slavery and how to identify possible indicators of sexual exploitation. An example given of indicators via a case study.
- Definitions of forced labour and how to identify possible indicators of forced labour. Utilisation of a case study to explain what forced labour looks like with a thought-provoking exercise to try and promote awareness.
- Domestic servitude and the differences between this form of slavery and the above. A case study is used to highlight indicators.
- The indicators to be aware of with regards to enforced criminality, again portrayed in a case study. The case study demonstrates how forced criminality differs from the above forms of modern slavery.
- The role of the border force and how we can support their efforts in stamping out modern slavery
As well as training our people, we have raised awareness of modern slavery issues by circulating a series of communications to our people.
These communications explain to our people:
- the basic principles of the Modern Slavery Act 2015
- how our people can identify and prevent slavery and human trafficking
- what our people can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation and,
- what external help is available, for example through the Modern Slavery Helpline.