MODERN ANTI-SLAVERY STATEMENT 2024
Chesnara plc, with its subsidiaries (together “Chesnara”), is committed to becoming a sustainable business and a key pillar of this commitment is to ensure that our group is an inclusive environment for all employees, customers and stakeholders. We are signatories to the UN Global Compact and will be required from 2025 to submit an annual Communication on Progress Report setting out specific actions taken with regard to the four designated categories covering human rights, labour, environment and anti-corruption.
Chesnara has zero-tolerance to the abuse of human rights and is committed to the eradication of human trafficking, slavery and other abuses of a person’s freedom and rights, forced labour whether adults or children. We are totally opposed to such abuses in our direct operations, our indirect operations and our supply chain as a whole.
THE MEANING OF SLAVERY AND HUMAN TRAFFICKING
Human rights are basic rights and fundamental freedoms which belong to all human beings regardless of nationality, gender, race, age, religion, language, physical or mental ability or any other political, economic or social status. In addition to the freedom of expression, human rights includes:
- the right to life;
- prohibition on torture;
- the right to a fair trial; and
- the right to fair and just working conditions, including access to safe, sufficient and affordable water, sanitation and hygiene facilities.
Our definition of slavery and human trafficking is aligned to that set out in the Modern Slavery Act 2015 (the “Act”). We recognise that forced labour, whether adults or children, as a form of slavery includes debt bondage, servitude, exploitation, forced- and compulsory- labour or marriage, human trafficking and the restriction of a person’s freedom of movement whether that be physical, non-physical or, for example, by the withholding of a worker’s identity papers. All have in common the deprivation of one person's liberty by another in order to exploit them for personal and/or commercial gain.
As a business operating in Europe, Chesnara also complies with the European Convention on Human Rights (ECHR) treaty which is similarly designed to protect people’s human rights and basic freedoms. Its Dutch and Swedish business units abiding by the ECHR in Europe and Chesnara believes that it meets the requirements of the Act in these territories.
OUR BUSINESS AND SUPPLY CHAINS
Chesnara plc is a holding company engaged in the management of life and pension books in the UK and Western Europe. Chesnara has zero-tolerance to modern slavery and is committed to acting ethically and with integrity in all of its business dealings and relationships and to operating and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in the group or its supply chains. The value of responsibility is at the heart of the Chesnara business model, values and culture and is integral to the way we conduct our business; consideration, awareness of modern anti-slavery is in place across our business units and actions will always be taken where found necessary to address the risk.
We believe in developing mutually respectful and sustainable relationships with our suppliers and business partners. Our preference is to establish long-term relationships where they remain commercially competitive and operationally viable. This is achieved through a structured due diligence process before selection, followed by clear agreement of the business objectives, consistent implementation of regulatory requirements and relevant policies, and effective attention to resolving issues fully. We require our suppliers and business partners to apply high standards of ethical conduct in all their dealings with us and their other stakeholders.
Our operating model in the UK is directed towards maintaining shareholder value by outsourcing many support activities to professional specialists. These activities typically include systems management, accounting services, actuarial services and investment management and, for our UK regulated entity Countrywide Assured plc, policy administration. These services are provided under long-term contracts with our well-established suppliers and the responsibility of oversight has remained with our internal, central governance team.
We are conscious that through our outsourcing arrangements we indirectly utilise the services of a much larger workforce and we seek to ensure that our suppliers are similarly adopting appropriate arrangements for proper engagement with their own workforces. In the UK, our material suppliers are required to adhere to a supplier code of conduct, which extends our principles of ethical conduct to our supply chain. Our supplier code of conduct covers a number of business practices and standards including with regards to human rights and modern anti-slavery, labour rights and working conditions and health and safety.
Although we consider that the greatest risk of slavery and human trafficking would be in our supply chain, where operational and managerial oversight is out of our direct control, we consider its possibility to be low due to the nature of our business and the suppliers that we have contracted with. Irrespective of that view, we require our partners to operate in line with our corporate values and fulfil our oversight of them with this in mind.
RECRUITMENT AND THE REAL LIVING WAGE
Chesnara always aims to attract, promote and retain the best candidates suitable for the roles within all our operations. Our approach is to be open, entrepreneurial, transparent and inclusive in how we select and manage our employees.
We are committed to providing equal opportunities in employment and will continue to treat all applicants and employees fairly regardless of race, age, gender, marital status, ethnic origin, religious beliefs, sexual orientation or disability. Chesnara has policies in place to ensure that no employee suffers discrimination, harassment or intimidation and to effectively address any issues that do come to light.
We have policies and procedures underpinning our recruitment process which ensure that the people that join us have the right to work and their basic rights as workers are protected.
We believe that all our employees deserve fair and just remuneration appropriate for the roles they hold and the work they perform and that all our people should benefit from acceptable living conditions and minimum living wages. In our UK division, our employees and service contractors meet the Real Living Wage pay level set by the Living Wage Foundation and based on a calculation of the cost of living and what employees and their families need to live.
HEALTH AND SAFETY
As a responsible business, at Chesnara we place primary importance on the health, safety and welfare of our employees. We operate a hybrid working model across all of our geographies, taking into account individual circumstances where necessary so that appropriate support can be provided.
Each of our business units ensures that the health and welfare of our staff is supported by employment contract provisions, including access to health insurance for all employees and encouragement and support for flexible working, amongst other benefits such as life cover, occupational pension and parental leave. All staff are made aware of these benefits through contracts of employment, policies and staff briefings. They are also reminded of their duty to act responsibly and do everything possible to prevent injury to themselves and others. Management teams across the group monitor the level of sick leave and absence and, where necessary, they take appropriate action to address any issues identified.
Relevant policies and procedures are reviewed on a regular basis so as to ensure that they meet appropriate standards. Any hazards or material risks are removed or reduced to minimise or, where possible, exclude the possibility of accident or injury to employees or visitors.
INVESTING RESPONSIBLY
We are committed to responsibly investing our money and that of our customers. As long-term stewards, we have a duty to our customers and wider stakeholders to operate responsibly. In all three of our territories, we work with fund managers that are committed to the UN’s Principles of Responsible Investment (UNPRI). Environmental, social and governance matters, including the issues of modern slavery and human rights, are integrated into our investment approach. We actively engage with our material asset managers and identifying and mitigating modern slavery risks is part of that conversation, including screening our investments to manage our risk of investing in entities with human rights controversies.
RELEVANT POLICIES
Chesnara has a Board-approved Group Human Rights and Modern Anti-Slavery policy. The policy is reviewed annually and brought to the attention of all of its UK staff.
Supporting it, we have a number of policies to help identify and mitigate the risks associated with modern slavery. Chesnara has clear, Board-approved policies covering matters that include Human Rights & Modern Anti-Slavery; Whistleblowing; Anti-Bribery; Anti-Fraud; and Workforce Engagement. We actively encourage staff and third parties engaged in our business to report and expose any unethical behaviour of which they become aware. Any matter raised either via the whistleblowing or auditing processes will be diligently investigated and appropriate action will always be taken in every instance.
RISK ASSESSMENT AND DUE DILIGENCE
We believe that the risk of slavery and human trafficking within our organisation is substantially avoided and mitigated as a result of these strict policies and procedures. It is reinforced through the oversight built into our business operations and the detailed knowledge and skills of our staff as well as the annual review and embedding attestation for these polices. We expect the same level of responsibility from our suppliers and, where we do not feel adequately assured of this, would seek confirmation from each supplier. Our procurement process with any future suppliers incorporates the requirement for them to provide their assistance and compliance with the Act to ensure that we continue to have clear knowledge of our business partners.
Each year, the Board considers any matters regarding- or raised under- the whistleblowing process across its business units and our UK material outsourced service providers. No instances of a breach of human rights or modern slavery, or any other incidents of whistleblowing, were reported in 2024 or indeed the period in 2025 leading up to the date of this statement.
TRAINING AND RESPONSIBILITY
The Board and Senior Management have responsibility for implementing this policy statement and ensuring that any employee, in particular those who have direct responsibility for the supply chain, has adequate resources to be vigilant to the risk of human rights abuse, slavery and human trafficking. All our colleagues undertake annual training on topics that relate to modern slavery: Anti-Bribery, Anti-Money Laundering, Fraud Prevention and Whistleblowing
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Chesnara’s slavery and human trafficking statement. Its requirements operated throughout the 2024 financial year and its controls hold true for the current 2025 calendar year.
Steve Murray
Group Chief Executive Officer
Chesnara plc
27th March 2025
