Modern Slavery Statement Policy
1. Introduction
We at Agria Pet Insurance Limited (Agria or the Company) will not tolerate slavery or human trafficking in our business or supply chains. We are committed to continually improving our policies and practices to play our part in fighting against slavery and human trafficking and protecting human rights. We value people as individuals with diverse opinions, cultures, lifestyles, circumstances and promote a respectful workplace.
2. The organisation
This statement applies to Agria Pet Insurance Limited (Agria or the Company) referred to in this statement as ‘the Organisation’. The information included in the statement refers to the financial year ending 31st December 2023.
2.1. Organisational structure
Agria Pet Insurance Limited ‘the Organisation’ is an insurance intermediary and a limited company registered in England with the company registration number 04258783 and registered address 1st Floor, The Blue Leanie, Walton Street, Aylesbury, England, HP21 7QW. The Organisations’ parent company is Försäkringsaktiebolaget Agria (Publ of Tegeluddsvägen 11, 115 41 Stockholm, Sweden. The Organisation has been providing animals with insurance since 1890. Since then, the Organisation has continued to grow across Europe and established in the UK since 2009.
Agria Försäkring is the insurance underwriter and is the UK branch of Försäkringsaktiebolaget Agria (Publ). Other Agria trading names in the UK are as follows:
- The Kennel Club Pet Insurance
- The Governing Council of The Cat Fancy (GCCF) Insurance
The organisation is led by a board of directors from Sweden and the United Kingdom. The Organisation offers flexible working allowing most employees to work from home on agreed days. There is a centralised office location, First Floor, Blue Leanie, Walton Street, Aylesbury, Buckinghamshire, HP21 7QW, with some employees being full-time at home or field based.
The Organisation are pet insurance specialists. As pet insurance specialists, we work closely with animal welfare organisations, vets, and breeders to ensure pets are provided with the best healthcare.
Agria's mission is to provide the best of care for pets and peace of mind for their owners.
The labour supplied to the Organisation in pursuance of its operation is carried out primarily in the United Kingdom from one centralised office location First Floor, Blue Leanie, Walton Street, Aylesbury, Buckinghamshire, HP21 7QW.
2.2. Supply chains
In order to fulfil its activities, the main supply chains of the Organisation include those related to the provision of financial goods and services.
The Organisation buys a wide range of goods and services and engage directly with circa. 200 suppliers. Over 90% of our direct suppliers are registered in the UK but many of their operations and supply chains are global. Some suppliers have complex supply chains with multiple tiers of sub-suppliers; we currently have little visibility over the lowest tiers of our supply chain but does proactively work with the suppliers it contracts directly with to achieve compliance.
3. Modern slavery act commitment
The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and its supply chains.
The Organisation will not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in The United Kingdom.
3.1. Modern slavery definitions
The Organisation considers that modern slavery encompasses:
- human trafficking.
- forced work, through mental or physical threat.
- being owned or controlled by an employer through mental or physical abuse or the threat of abuse.
- being dehumanised, treated as a commodity, or being bought or sold as property.
- being physically constrained or to have restriction placed on freedom of movement.
4. Risk assessment and management
Due to the nature of our business, the Organisation considers the risk of modern slavery and human trafficking occurring in our business to be low. Nonetheless we have put steps in place to ensure slavery and human trafficking does not take place within the Organisation or its supply chains.
The following is the process by which the Organisation assesses whether or not particular activities are high risk in relation to slavery or human trafficking:
- maintain a risk register of supplier engagement activities.
- quarterly review of risk register and people related activity.
- regular recruitment process review.
The processes the organisation has in place are to ensure that we follow fair, transparent, and ethical ways of attracting and recruiting staff. We also have a robust Right to work in the UK process in place, and as a regulated business conduct background checks as standard.
We have a robust onboarding process with supplier partners, and we continue to analyse and review risks if, and when, they occur. This is to ensure that any activities employees are undertaking are reasonable and legally compliant in line with UK law and legislation.
5. Due diligence processes
The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery. The Organisation to the best of its abilities carries out due diligence processes in relation to ensuring slavery and human trafficking does not take place in the Organisation or its supply chains.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation will take steps to ensure that modern slavery is not taking place. These steps include:
- conducting a review of the controls of its suppliers reviewing our supplier contracts to include termination powers in the event that the supplier is (or is suspected) to be involved in modern slavery.
- conducting supplier audits or assessments through the organisation's own staff auditor, moving forward this will 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 against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
- putting measures in place to identify and assess the potential risks.
- promoting a zero-tolerance policy towards modern slavery.
- reviewing the requirement for any training for staff on modern slavery.
6. Key performance indicators
The Organisation will set key performance indicators to measure its effectiveness in ensuring modern slavery or human trafficking is not taking place in the Organisation or its supply chains.
The Organisation are:
- requiring all staff to have completed training on modern slavery on an annual basis.
- developing a system for supply chain verification expected to be in place December 2024, whereby we evaluate potential suppliers before they enter the supply chain; and
- reviewing its existing supply chains, whereby we evaluate all existing suppliers.
7. Policies
The Organisation has the following policies in place for its employees and suppliers (where applicable) which further define its stance on modern slavery.
- Grievance Policy & Procedure
- Whistleblowing Policy
- Code of Conduct
- Supplier Code of Conduct
- Recruitment & Selection Policy
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.
8. Training
We require all employees within our Organisation to complete training on modern slavery. Our modern slavery training is broken into three areas:
- Modern Slavery
This pathway is designed to give learners the ability to prevent modern slavery in all its forms. It describes the seriousness of modern slavery, legislation intended to protect victims, how such criminal activity can be identified and how to stop it. - Modern Slavery, a call to action in financial services
This activity will introduce learners to the different types of modern slavery and exploitation and the possible indicators of modern slavery. Individuals also learn about the criminal offences covered by the act, the requirements placed on organisations to prevent modern slavery in their organisation and supply chains, and how to report suspicious activity. - Modern slavery, hidden in plain sight
Modern slavery is commonplace in today's world, and the consequences for its victims are severe. This video will give learners an awareness of the scale of the problem and emphasise the role of the financial services industry in preventing this type of criminal activity.