Modern Slavery Statement 2024
the risk of incidents within the organisation and its supply chains. The Group entities required to report under the Act are listed at the end of this Statement.
Other sectors within the Group include broking specialists Markerstudy Distribution and Clegg Gifford. Markerstudy Distribution provides a range of motor, home, SME and pet insurance products in partnership with several of the best-known brands in UK financial services and retail, and through own brands, including Budget Insurance, Dial Direct, Lancaster Insurance and Purely Pets. Clegg Gifford specialises in personal and commercial insurance products and expands the Group’s presence into the Lloyd’s of London Market. Complementary businesses include Auto Windscreens, VisionTrack and Vision Vehicle Solutions. More information on our businesses can be found at www.markerstudygroup.com
* According to the MGAA as at 01.09.23
The Group recognises that modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We take a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. The Group’s Modern Slavery Policy (the “Policy”) applies to all Group companies whether they are regulated by the FCA or not.
Whilst the Group Board has overall responsibility for ensuring the Policy complies with our legal and ethical obligations, and that all those under its control comply with it, Management at all levels are responsible for ensuring that those reporting to them understand and comply with the Policy and are given adequate and regular training on it and the issue of modern slavery in supply chains, proportionate to and in the context of their role.
Additionally, the Group has a Whistleblowing Policy, which actively encourages the reporting of unethical behaviour, and specific reference is made to modern slavery in this Policy.
We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Act. We expect the same high standards from all of our contractors, suppliers and other business partners, and all our suppliers are expected to comply with all applicable laws. As part of our contracting processes, we include specific prohibitions against modern slavery, including the use of fforced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
We continue to review our supply chain protocols and to introduce specific measures to ensure that our obligations under the Act are passed through our supply chain.
- Ensure contractual warranties are included where appropriate in new engagements, which confirm that no slavery is used anywhere in the supplier’s business, by any of the suppliers in its own supply chain, and that all necessary policies and processes have been implemented to ensure that this continues to be the case;
- Obtain a contractual right to request compliance-related information and the right to second party audit of suppliers at our discretion; and
- Where appropriate, add indemnity provisions and rights to terminate engagements in the event of breach of the Policy.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our organisation, we provide online training on Modern Slavery and Whistleblowing (which is mandatory, on an annual basis) to our employees and have made both the Modern Slavery Policy and Whistleblowing Policy available to all employees through the Markerstudy Intranet.
This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31 December 2023 and was approved by the Group Board at its meeting on 27 June 2024.
Kevin Spencer
June 2024
The Group entities required to report under the Act are Markerstudy Group Holdings Limited and its subsidiaries listed below:
- Auto Windscreens Services Limited
- BFSL Limited
- BISL Limited
- Insurance Factory Limited
- Markerstudy Insurance Services Limited