1. Introduction
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 for Ariel Re Services Holdings (No 1355) Limited and its subsidiaries and affiliates (collectively ‘Ariel Re’) and sets out the steps taken by Ariel Re to seek to ensure that slavery and human trafficking does not take place within any part of our business.
This statement has been approved by the Board of directors of Ariel Re on May 3, 2022 and is reviewed on an annual basis.
2. Scope
This policy statement applies to all Ariel Re group companies including but not limited to: Ariel Re Services Holdings (No 1355) Limited, Ariel Re Management Services Limited, Ariel Re Managing Agent Limited, Ariel Re UK Limited, Ariel Re Bda Limited, Ariel Re (Hong Kong) Limited.
3. Our Commitment
We are committed to ensure that we comply with the Modern Slavery Act 2015 and have a zero-tolerance approach to slavery and human trafficking. We always work to ensure that the highest professional standards are met and comply with all laws and regulations applicable to our business. We expect our staff to behave ethically and are held accountable for their actions, and we demand the same high standards from those parties with whom we partner with.
4. Risk Management
We have embedded a robust risk management framework to manage risks within our business and, whilst we believe that there is a low risk of slavery and human trafficking being directly connected with our business, our processes include analysing the risk of inadvertently working with suppliers who do not share our zero-tolerance approach to anti-slavery and human trafficking.
5. Our Policies
We have a number of policies and procedures that mitigate the risk of Modern Slavery and human trafficking occurring within our business including:
· HR policies and procedures including Recruitment, Onboarding, Code of Conduct and Business Ethics
· Compliance policies including Anti-Bribery, Corruption, Anti- Money Laundering and Whistleblowing
· Outsourcing Policy
· Fitness and Propriety Policy
6. Suppliers
As a specialist provider of reinsurance, our supply chains are not ones that would usually be associated with slavery or human trafficking. However, although the risk is low, Ariel Re still carry out appropriate due diligence reviews so-as-to ensure that all of our business partners comply with local laws and regulations.
7. Our Employment
Ariel Re ensure that all equal employment opportunity laws are followed. Part of our recruitment framework is to have processes in place to ensure contracts are provided, ‘right to work’ documents are checked and that all employees have passed background checks before they commence their employment with Ariel Re.
8. Whistleblowing
We encourage employees and external parties to report any concerns about malpractice at the earliest possible stage. Any reportable concerns can be made directly to the Ariel Re Whistleblowing Hotline at (+44) 0800-048-5475 or online.
9. Training
Part of the onboarding process is to provide all new joiners with training on Anti-Bribery and Corruption, Anti-Money Laundering and Whistleblowing policies.
Additional training is provided annually to all staff which also includes Code of Conduct and more in-depth Conduct Rules training which is required under the FCA’s Senior Managers and Certification Regime.