8th May 2023

Stepping Stone 06 Modern slavery and human rights


A clear commitment within the UN Sustainable Development Goals is to take immediate and effective measures to eradicate forced labour, end modern slavery and human trafficking and secure the prohibition and elimination of the worst forms of child labour.

Upon first review, this goal may feel like it is of limited application to the UK Insurance Industry, however members can benefit from considering what actions are being taken to promote ethical business practices and policies that protect workers from being abused and exploited in their own firm and (sometimes global) supply chains.

Modern Slavery

The Modern Slavery Act 2015 introduced an obligation for certain businesses to publish an annual statement setting out the steps they take to prevent modern slavery in their business and their supply chains.

If your annual turnover is more than £36 million it is likely that you will be required to publish an annual statement. Many businesses who are not legally obligated to issue an annual statement are nevertheless choosing to do so. Doing so can galvanise your commitment to tackling modern slavery and demonstrate this to internal and external stakeholders (see further ).

For further information see the Government guidance on how to publish an annual modern slavery statement. The Home Office has also launched a government-run modern slavery registry for statements serving as a useful reference tool. Some great examples are those issued by Zurich, Royal Sun & Alliance and Marsh.

In focus: Corporate Sustainability Due Diligence (CSDD)

On 23 February 2022, the European Commission adopted a

proposal for a Directive on corporate sustainability due diligence.

Core elements of the due diligence duty include identifying, bringing

to an end, preventing, mitigating and accounting for negative human rights

and environmental impacts in the company’s own operations, their subsidiaries and their value chains.

If the CSDD Directive comes into force, members who are directly impacted

by CSDD or fall within the value chain of an organisation who is,

will be required to demonstrate how they assess and combat human rights

and environmental impacts. Early consideration

and engagement with these requirements is encouraged.

Key KPIs to adopt

  • Percentage of employees trained on modern slavery and human rights issues, policies and organisational procedures
  • Total number of hours per employee devoted to above trainings

Further references:


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