MODERN SLAVERY STATEMENT
This statement is made pursuant to s.54 of the Modern Slavery Act 2015.
Modern Slavery encompasses slavery, servitude, human trafficking and forced labour. Sirius International Managing Agency (SIMA) Sirius International Insurance Corporation (UK branch) (the UK branch) have a zero tolerance approach to any form of Modern Slavery. We are committed to acting ethically and with integrity and transparency in all business relations and putting effective systems and controls in place to safeguard against any form of Modern Slavery taking place within our business or supply chain.
ABOUT SIMA
We are a Lloyd’s Managing Agency which obtained regulatory approval on 1st July 2014 and are a 100% owned subsidiary of SiriusPoint Ltd. The Managing Agency is responsible for Sirius International’s Syndicate 1945, which has been trading at Lloyd’s since 2011.
ABOUT THE UK BRANCH
The UK branch is authorised and regulated by the Finansinspektionen in Sweden. We are deemed authorised by the Prudential Regulation Authority and subject to regulation by the Financial Conduct Authority and limited regulation by the Prudential Regulation Authority. Details of the Temporary Permissions Regime, which allows EEAbased firms to operate in the UK for a limited period while seeking full authorisation, are available on the Financial Conduct Authority’s website.
OUR SUPPLY CHAINS
As a Lloyd’s Managing Agency, SIMA has a limited supply chain, as does the UK branch as an insurer. We partner with select service providers and third party suppliers as part of our business model, such as IT services, Audit services and Exposure Management. Our business consists of underwriting Insurance and Reinsurance and associated policy management and Claims activities. We do not act as a producer or retailer of physical goods and have no supply chains relating to such activities. However, we remain dedicated to ensuring that slavery and human trafficking is not taking place within our business or supply chains. We have in place due diligence procedures and outsourcing and supplier frameworks that are specifically designed to ensure that our suppliers, agents and partners are both compliant with the Modern Slavery Act and more broadly committed to human rights and ethical corporate practices.
OUR POLICIES
Being part of the SiriusPoint Ltd. (the Group), we recognise our obligations to all those with whom we have dealings – shareholders, employees, customers, clients, regulatory authorities, suppliers, competitors and the wider community. The Group demands and maintains the highest ethical standards in carrying out our business activities. Our reputation and the trust and confidence of those with whom we deal are of fundamental importance to the Group. Our values determine our behaviour and we must support and uphold them so that they are an integral part of day to day life. Our Code of Ethics aims to guide our actions and those of people with whom we work closely, encouraging a way of working which is honest, responsible and respectful, generating trust. The code is incorporated as part of the Employee Handbook and Vision and Values training, thus ensuring the standards in this code are communicated to and understood by our staff. We operate a number of other internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
Whistleblowing Policy
The purpose of this policy is to enable all employees to air genuine concerns they may have about suspected malpractice or wrongdoing within SIMA or the UK branch. Our aim is to develop a culture of openness and for our business to be conducted with the highest standards of integrity and honesty. Any form of malpractice or wrongdoing is taken very seriously. SiriusPoint – The Group Code of Business Conduct This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act. Our aim is to develop a culture of openness and for our business to be conducted with the highest standards of integrity and honesty. Any form of malpractice or wrongdoing is taken very seriously. The code also includes our standards for management of conflicts of interest that may arise.
Remuneration Policy
This policy ensures that we pay employees a salary in line with the local market conditions.
Conduct Risk Policy
This policy ensures that we pay due regard to the interests of our customers and treat them fairly.
Countering Financial Crime Covering Anti-Bribery
This policy outlines the rules and principles that we must adhere to for the prevention and detection of financial crime and ensures that we conduct our business in an honest way and without the use of corrupt practices or acts of bribery to obtain an unfair advantage. These policies, combined with our commitment for our employees to act ethically at all times, enable us to identify
and minimise the risk of Slavery occurring within our organisation and supply chains.
Outsourcing Policy and Procedure
This policy outlines the steps we take to ensure that those we outsource activities to operate in an ethical manner.
Fit and Proper Policy
This policy sets the basic principles for the standards and background controls for determining the fitness and propriety of persons who hold or are being considered for appointment to a Key person position.
Our People
We strive to recruit and treat employees fairly, avoiding modern slavery at all costs. We are committed to:
- Recruiting and hiring employees in a fair, lawful and professional manner
- Treating employees fairly during their employment, ensuing there is a culture of openness and clear guidelines on raising grievances or whistleblowing
- Acting in line with Lloyd’s Diversity and Inclusion Charter
- Managing the exit of an employee from the business in a fair and consistent manner as set out in the employee handbook and other internal documents
- Providing fair working conditions for all employees including terms & conditions of employment, remuneration, defined working hours, health & safety, holiday entitlements and benefits.
Training
We will communicate this statement to our employees and include it as part of the induction materials to all new members of staff, in order to promote awareness of Modern Slavery.