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Modern Slavery Act

TMK Modern Slavery Act Statement 2019

Introduction

This statement sets out Tokio Marine Kiln’s (TMK) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring there is no slavery or human trafficking in its own business and its supply chains.

As part of the insurance and financial services sectors, TMK recognises that it has a responsibility to take a robust approach to counter slavery and human trafficking.

Organisational structure and supply chains

This statement applies to the activities of Tokio Marine Kiln Group Limited and its subsidiaries which includes Tokio Marine Kiln Syndicates Limited, Tokio Marine Kiln Insurance Limited and Tokio Marine Kiln Insurance Services Limited and those entities where TMK has a shareholding.

The majority of our core business is sourced through trading relationships with insurance intermediaries including brokers, agents and intermediaries.  TMK products which are distributed to clients through trading relationships with coverholders and brokers are done so with agreements which meet the standards set out by our regulators.

TMK’s supply chains comprise third party suppliers and subcontractors. We use suppliers and contractors for goods and services required for the maintenance and support of our business operations.  As TMK operates mainly in financial and insurance related businesses, we do not act as a producer, manufacturer or retailer of physical goods.

TMK Policy and Action

TMK is committed to preventing slavery and human trafficking in its corporate activities and uses its best endeavours to ensure that its supply chains are free from slavery and human trafficking.

TMK operates the following policies that describe its approach to the identification of modern slavery risk

Relevant policies

  • Whistleblowing policy TMK encourages all its employees, customers and other business partners to report any concerns related to its activities. The organisation's whistleblowing procedure ensures that concerns can be raised without fear of retaliation.

  • Code of business conduct & ethics TMK’s code makes clear to employees the actions and behaviour expected of them when representing TMK. TMK strives to maintain the highest standards of employee conduct and ethical behaviour.

TMK’s anti-slavery and human trafficking initiatives include:- 

  • Policies: HR and Governance functions will take responsibility for ensuring that modern slavery requirements are reflected in our code of business conduct and ethics policy.
  • Risk assessments: Risk analysis will be completed to highlight any areas where modern slavery risks occur within the group business.
  • To Be A Good Company: TMK has adopted the Tokio Marine Group Corporate Philosophy which includes "Acting as a good corporate citizen through fair and responsible management.

More information can be found at: http://www.tokiomarinehd.com/en/company/philosophy.html 

Due diligence

TMK undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. TMK’s due diligence includes:

  • The consideration of working with suppliers who set out their commitment to preventing modern slavery and human trafficking within their own business and their supply chains, where appropriate.
  • Explicit reference to compliance with the Modern Slavery Act in all new contracts as a standard contract term where applicable.
  • If suppliers who are required to comply with the Modern Slavery Act do not have adequate procedures for preventing modern slavery and human trafficking, the relevant third party may not be approved for use.

Should a failing arise during the course of a contract executive management will be advised and all options will be reviewed and appropriate action taken.

Awareness

TMK requires all employees to be aware of the modern slavery statement. To improve awareness, TMK will make a commitment to deliver important messages relating to modern slavery, including:

  • Communicating the basic principles of the Modern Slavery Act 2015;
  • Providing resources on how employers can identify and prevent slavery and human trafficking;
  • Providing information on where to go to for advice and what external help is available.