Anti-Slavery and
Human Trafficking Statement
ERGO Travel Insurance Services Anti-Slavery and Human Trafficking Statement
1: Statement from senior management
2: Structure of the organisation
ETI operate in the Travel Insurance Market as a Managing General Agent, having links with many Agents in the UK. ETI is a subsidiary of ERGO Reiseversicherung AG, a wholly owned subsidiary of ERGO Versicherungsgruppe AG which is in turn a wholly owned subsidiary of the Munich Re Group.
ETI operates in the UK and employs 39 people with annual turnover in excess of £2m.
As a small company we have a limited number of suppliers which we use to deliver our services to our business partners and clients. We work with a range of suppliers from professional services organisations to suppliers of consumables. Regardless of the services ETI received from a supplier we expect that their obligations in respect of modern slavery and human trafficking to be the same high standards as our own.
3: Practices
- Making staff aware of the importance of the Act;
- Establishing how modern slavery may manifest itself in the work environment;
- Ensure our partners and suppliers are aware of the importance of the Act as well as our stance on modern slavery and advise our expectation of adherence by them to the Act standards;
- Review our partners Modern Slavery Policies (where required)
4: Due diligence and Supply Chain Strategy
- Requiring staff to procure goods and services from the approved suppliers list;
- As part of our ongoing due diligence we have reviewed and consolidated supplier numbers to reduce the overall number, which helps in making the supply chain more manageable;
- Where possible, assessing the origin of goods and services delivered through that supply chain specifically around the geographic origin of goods to assess whether these are high risk areas;
- Undertaking risk assessments of suppliers to identify indicators which may raise concerns about the use by ETI of that organisation within the supply chain;
- Carrying out appropriate levels of due diligence prior to entering into a new supplier relationship (i.e reference checking organisations, reviewing their Slavery Policy (where appropriate);
- Carrying out supplier checks on an ongoing basis to monitor changes which may raise concerns about future use by ETI.
- Control the number of suppliers, such that they are reviewed and managed so that slavery and forced labour are not used in the supply chain;
- Influence the behaviours of suppliers so that the objective of the Act is achieved;
- Establish and assess areas of potential risk in our business and supply chains;
- Monitor those risk areas in our business and supply chains;
- Empower ETI to take positive and decisive action where breaches of the Act are identified or suspected.
5: Risk and compliance
ETI review the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain as part of its ongoing due diligence review. These reviews will be completed biennially depending on the supplier, the nature of the goods and services as well as any indicator that greater regularity of review is necessary (i.e. where a supplier is sourcing from a location considered higher risk).
We do not consider that we operate in high risk sectors or locations because many suppliers and business partners provide either professional / insurance services or goods delivered from within the United Kingdom.
For the reasons set out in this document, ETI maintains an approved suppliers list which seeks to ensure that reputable organisations are used in our supply chain.
If we find evidence of a failure to comply with Modern Slavery or a breach of legislation in this area we will immediately seek to terminate our relationship with the relevant supplier.
Where there are suspicions of a breach ETI will take positive action to investigate and either terminate where proven, or work with the supplier to demonstrate with greater certainty that there is no such breach.
6: Training
All staff complete an E-learning Unit about Modern Slavery and are trained to recognise the risks of modern slavery and human trafficking in our business. This part of our ongoing training and competence programme.
Through our training, employees are encouraged to identify and report any potential breaches of the Act or suspicions of slavery and human trafficking within the ETI supply chain.
7: Further actions and sign-off
Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps to tackle slavery and human trafficking:
- review the approved supplier list;
- at the start of any new supply contract seek to impose contractual obligations to tackle modern slavery and broad rights of termination for any such breach;
- undertake a due diligence review for all suppliers based on risk and size.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes
ETI’s slavery and human trafficking statement for the financial year beginning January 2022.
1: Statement from senior management
ERGO Travel Insurance Services Ltd (ETI) are committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain. ETI require (expect) the same standards that it promotes in combating modern slavery are adopted and enforced by its suppliers in order to adhere to the obligations and the intent of the Modern Slavery Act 2015 (“the Act”).
2: Structure of the organisation
ETI operate in the Travel Insurance Market as a Managing General Agent, having links with many Agents in the UK. ETI is a subsidiary of ERGO Reiseversicherung AG, a wholly owned subsidiary of ERGO Versicherungsgruppe AG which is in turn a wholly owned subsidiary of the Munich Re Group.
As a small company we have a limited number of suppliers which we use to deliver our services to our business partners and clients. We work with a range of suppliers from professional services organisations to suppliers of consumables. Regardless of the services ETI received from a supplier we expect that their obligations in respect of modern slavery and human trafficking to be the same high standards as our own.
3: Practices
As part of our responsibility to help combat modern slavery, we have put in place the following practices:
- Making staff aware of the importance of the Act;
- Establishing how modern slavery may manifest itself in the work environment;
- Ensure our partners and suppliers are aware of the importance of the Act as well as our stance on modern slavery and advise our expectation of adherence by them to the Act standards;
- Review our partners Modern Slavery Policies (where required)
4: Due diligence and Supply Chain Strategy
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted some due diligence checks:
- Requiring staff to procure goods and services from the approved suppliers list;
- As part of our ongoing due diligence we have reviewed and consolidated supplier numbers to reduce the overall number, which helps in making the supply chain more manageable;
- Where possible, assessing the origin of goods and services delivered through that supply chain specifically around the geographic origin of goods to assess whether these are high risk areas;
- Undertaking risk assessments of suppliers to identify indicators which may raise concerns about the use by ETI of that organisation within the supply chain;
- Carrying out appropriate levels of due diligence prior to entering into a new supplier relationship (i.e reference checking organisations, reviewing their Slavery Policy (where appropriate);
- Carrying out supplier checks on an ongoing basis to monitor changes which may raise concerns about future use by ETI.
Our checks are designed to:
- Control the number of suppliers, such that they are reviewed and managed so that slavery and forced labour are not used in the supply chain;
- Influence the behaviours of suppliers so that the objective of the Act is achieved;
- Establish and assess areas of potential risk in our business and supply chains;
- Monitor those risk areas in our business and supply chains;
- Empower ETI to take positive and decisive action where breaches of the Act are identified or suspected.
5: Risk and compliance
ETI review the nature and extent of its exposure to the risk of modern slavery occurring in
its supply chain as part of its ongoing due diligence review. These reviews will be completed biennially depending on the supplier, the nature of the goods and services as well as any indicator that greater regularity of review is necessary (i.e. where a supplier is sourcing from a location considered higher risk).
We do not consider that we operate in high risk sectors or locations because many suppliers and business partners provide either professional / insurance services or goods delivered from within the United Kingdom.
For the reasons set out in this document, ETI maintains an approved suppliers list which seeks to ensure that reputable organisations are used in our supply chain.
If we find evidence of a failure to comply with Modern Slavery or a breach of legislation in this area we will immediately seek to terminate our relationship with the relevant supplier.
Where there are suspicions of a breach ETI will take positive action to investigate and either terminate where proven, or work with the supplier to demonstrate with greater certainty that there is no such breach.
6: Training
All staff complete an E-learning Unit about Modern Slavery and are trained to recognise the risks of modern slavery and human trafficking in our business. This part of our ongoing training and competence programme.
Through our training, employees are encouraged to identify and report any potential breaches of the Act or suspicions of slavery and human trafficking within the ETI supply chain.
7: Further actions and sign-off
Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps to tackle slavery and human trafficking:
- review the approved supplier list;
- at the start of any new supply contract seek to impose contractual obligations to tackle modern slavery and broad rights of termination for any such breach;
- undertake a due diligence review for all suppliers based on risk and size.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes
ETI’s slavery and human trafficking statement for the financial year beginning January 2023.
