This policy applies to all individuals working at all levels and grades within Williams Pitt International (“WPI”), including directors, senior managers, officers, employees (whether permanent, fixed term or temporary), trainees, seconded staff, homeworkers, casual workers, agency staff, volunteers and interns. However, we also expect that all of our business partners globally conduct their business ethically and that they too comply with this policy.
Introduction
In accordance with the Modern Slavery Act 2015, this statement sets out the actions WPI to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and that of its partners.
As part of the Insurance industry, WPI recognises that it has a responsibility to take a robust approach to slavery and human trafficking and is committed to ensuring that slavery and human trafficking are prevented in the corporate activities of both WPI and its partners.
Relevant policies
WPI operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Whistleblowing Policy – WPI encourages all employees to raise concerns internally and at a high level, and to disclose information which the individual believes shows malpractice or impropriety. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
- Employee Code of Conduct – The organisation’s code makes it clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour throughout its business activities.
Implementation
WPI will ensure the principles are embedded by:
- Providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking;
- Ensuring staff involved in procurement activity are aware of, and follow modern slavery procurement guidance on “gov.uk”;
- Ensuring that consideration of the modern slavery risks and prevention are added to WPI’s policy review process as an employer and procurer of services: and
- Continuing to take action to embed a zero tolerance policy towards modern slavery.
Procedure
Breaches of this Policy are taken extremely seriously and employees should report any breaches to a Director.
This policy has been approved by the WPI Directors for the financial year ending 31st March 2023, and will be reviewed and updated annually.
