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MODERN SLAVERY STATEMENT
Modern Slavery Statement made on behalf of Tindall Riley & Co Limited, including its trading names, “Wren Managers” and “Griffin Managers” and subsidiaries (together “Tindall Riley”).
STATEMENT BY THE CHAIRMAN OF TRC, ENDORSED BY TRC’S BOARD
Tindall Riley manages three Mutual Insurance Associations. Given the nature of our business, it is considered that there is minimal risk, either within Tindall Riley or its limited supply chains which support our business activities, that we are in any way involved, or complicit, in slavery or human trafficking.
We take pride in the conditions of employment for all our employees within Tindall Riley. We are committed to eliminating discrimination and encouraging diversity. Tindall Riley strive to create a work environment that is free from discrimination, harassment and victimisation; where all employees, job applicants, clients and suppliers are treated equally and fairly regardless of age, race, colour, nationality, national or ethnic origins, disability, sex, pregnancy, gender, sexual orientation, religion, belief, marital status or civil partnership status.
The employment and procurement practices operated by Tindall Riley mean that we are a supportive and ethical employer. We aim to provide a secure and open working environment where we provide a high level of professional service, which in turn helps to build and maintain our business and relationships over the long term.
Furthermore, Tindall Riley expects a high level of conduct from those companies with which we do business. It is our aim to ensure, as far as we can, that any third-party suppliers, correspondents or other third parties with whom we work operate in accordance with the same high standards that we embrace with regard to their own employees and supply chains.
ORGANISATIONAL STRUCTURE
Tindall Riley is a privately owned company.
OUR SUPPLY CHAINS
Tindall Riley’s supply chains are limited. We offer insurance mediation solutions and are accountable to our regulators in the UK (the Financial Conduct Authority), in Luxembourg (the Commissariat Aux Assurances), in Hong Kong (the Insurance Authority), in Singapore (the Monetary Authority of Singapore), in Japan, (the Financial Services Agency) in Denmark (the Danish Financial Supervisory Authority) and in the United States (New York State).
We use routine services for the maintenance and support of our worldwide premises operations, e.g. support staff for office maintenance or communications infrastructure. We do not act as a producer, manufacturer or retailer of physical goods and have no supply chain in relation to such activities.
DUE DILIGENCE AND IMPLEMENTATION PROCESS FOR SLAVERY AND HUMAN TRAFFICKING
Tindall Riley operates a range of policies and procedures to identify and mitigate risks of modern slavery or human trafficking. These include:
- Outsourcing;
- Business Standards;
- Senior Managers;
- Financial Crime; and
- Whistleblowing.
No instances of modern slavery or people trafficking have been reported through our Whistleblowing process.
ANTI-SLAVERY AND ANTI-HUMAN TRAFFICKING MEASURES
Tindall Riley has an HR department led by our Group Director People, a Risk and Compliance Department led by our Group Chief Risk Officer and an internal audit department led by our Group Head of Internal Audit. Each of these departments and individuals also have senior management responsibilities within Tindall Riley.
For a summary of firm-wide and departmental initiatives relevant to this Modern Slavery Statement, please see Appendix A:
TRAINING AND AWARENESS
This Statement is communicated to all employees (at the date of publication and when any new employee joins us) in order to engender an understanding of the risks of modern slavery and human trafficking in our business and associated areas of our business.
All new employees benefit from eLearning on Modern Slavery; with all staff having received similar training since March 2021. The risk from Modern Slavery is also covered in face to face Compliance training of employees.
MODERN SLAVERY STATEMENT – FROM THE CHIEF EXECUTIVE OFFICER OF TINDALL RILEY
“The Company has a zero-tolerance position in respect of slavery and human trafficking, and is committed to ensuring that this does not occur in its supply chain or business. The Company is also committed to acting ethically and with integrity in all its business relationships.”
Our Modern Slavery Statement reflects our commitment to act ethically and with integrity in all our business relationships.
LEGAL AND REGULATORY PURPOSE OF THIS STATEMENT
This Statement is made with specific regard to the obligations arising under section 54(1) of the UK’s Modern Slavery Act 2015. Accordingly, this Statement should be considered to constitute the Modern Slavery Statement for TRC for its financial year,1 January 2022 to 31 December 2022 and until such time as it is modified or amended. Such modifications or amendments will be communicated to all new and existing employees.
Approved by the Board of Directors on 23 June 2023
Signed by Andrew Cutler, CEO of TRC
APPENDIX – A
TRC and Tindall Riley have undertaken the following steps relevant to this Modern Slavery Statement, some of which are well established items whilst a number are enhancements since last year:
Marketing
We require that suppliers of branded goods for Tindall Riley adheres to similar values in relation to their own business and supply chain.
Compliance
Tindall Riley’s Compliance Team, as well as its compliance procedures, have been further strengthened.
Daily checks are run against the WorldCompliance database to ascertain if any suppliers and businesses associated with Tindall Riley have been prosecuted or are known to have been charged with any offences in relation to Modern Slavery and Human Trafficking. No such instances have been detected as at the date of this Statement.
Human Resources (HR)
TRC’s HR department sets out employee rights and responsibilities in contracts of employment, the Employee Handbook and related employment documentation. In addition, this department:
- conducts salary benchmarking activity to identify and address any pay discrepancies;
- ensures that Tindall Riley pays above minimum statutory wage requirements;
- reviews invoices received by agencies to ensure fair payment of contract staff;
- provides firm-wide Modern Slavery training; and
- provides an Employee Assistance Programme to promote physical and mental wellbeing for UK based employees.
Whistleblowing Hotline
Our whistleblowing hotline service has international coverage. Its contact details appear on the home page of Tindall Riley’s intranet for ease of reference for all employees worldwide.
23 June 2023