Legal & General Group – Modern Slavery Statement 2016.
As a business with over £36m turnover we wanted to explain our approach and processes to ensuring that Legal & General Group Plc and its supply chains are slavery free. This statement is made in accordance with the provisions of the UK Modern Slavery Act. We already incorporate and report on a yearly basis our commitment to the UN Global Compact.
We strive to ensure that slavery and human trafficking is not taking place within any part of Legal & General Group or our supply chains. On the positive side this is also about providing decent jobs of a good standard as a direct employer and within our suppliers who made products and deliver services.
We are a $1.2 trillion fund management, insurance and savings business with responsibility for financial safety nets for over 10,000 million retail customer and over 3,500 institutional investors. In running our businesses in the UK, USA and Holland we employ approximately 10,000 people to provide service to our customers and procure around £500m worth of products and services per annum to deliver our promises to these customers at their point of need.
Whilst due to the nature of our business we consider that Legal & General remains low risk from a modern slavery perspective we are still remain vigilant and are paying particular attention to the following parts of our business in our assessment of Modern Slavery Risk.
- Our direct supply chain which is 100% UK procured but does result in services such as IT support and Software development being delivered from overseas locations.
- In our Home Insurance business due to the increased use of third parties when putting our customers’ homes back together through the building trade.
- We are also a major commercial property landlord via Legal & General Real Assets who are responsible for approximately £21bn of commercial property. We are often responsible for those buildings and how they are run for services such as security, cleaning and catering.
- Legal & General Homes – We are now directly running a modular home factory near Leeds designed to build affordable homes across the UK.
- In our own offices, where we bring in expert firms such as security, catering and cleaning to keep our business running.
- And finally we are increasingly using employment agencies to bring in employees as our business grows on a full time and temporary basis.
What we expect from suppliers
We have taken the stance to focus upon all suppliers irrespective of whether they are over £36m turnover or not. The following controls are therefore applied to all suppliers, and are designed to ensure that Legal & General’s supply chains are slavery free.
Directors and Principles of our suppliers are required to sign up to our sustainable procurement policy which guarantees that their businesses supplying product and service to Legal & General are slavery free.
For new and existing suppliers we are using NGO monitoring tools giving us risk scores as early warning systems to see how suppliers are doing against International Labour Organisation (ILO) principles as an indicator of non-compliance to our stance on Modern Slavery.
If evidence of higher social risk occurs around the ILO’s indicators of forced labour we will escalate this through the supplier manager to understand whether this is indicative of breaching our Modern Slavery standards.
Delivery in 2016
During 2016 we have delivered the following initiatives in order to ensure that our business continues to be slavery free.
We have reviewed our processes and approach with the www.responsible100.com network to get feedback on our policy and approach from a number of leading experts on this area.
We have also received feedback from the Business and Human Rights Centre on how our reporting benchmarks against other FTSE 100 companies. In the first year of operation we have scored in the middle of the pack with work to do.
As a result we have organised a number of workshops with Key Suppliers, Supplier Relationship Managers and HR professionals across the Group in conjunction with Anti-Slavery International to ensure that everyone understands specific UK modern slavery risks. We think that it is important that both our own people and our suppliers should have access to the latest thinking from NGOs in this way.
We have provided a communication awareness campaign to all employees to help them understand the signs of modern slavery.
We continue to use a number of monitoring tools such as Reprisk and Sigwatch to provide early signs of lowering social standards in our suppliers which may provide an indication that modern slavery is more likely. If any risks are identified, we engage in supplier to supplier manager discussions to try to establish whether risks around modern slavery exist. To date, we have not identified any breaches of our Suppliers Code of Conduct.
There are a few areas of focus for us in 2017
As we move more into being a manufacturing and a services business with Legal & General Homes and Legal & General Communities we will be looking to adopt and adapt our policies to ensure that Legal & General continues to monitor and control the risk of modern slavery within its business.
Following workshops with our major suppliers and NGO Anti-Slavery International we will agree new data points and key questions to establish whether decent high standard jobs are being in our Tier 1 and 2 suppliers.
We have also seen increased questioning from our own clients such as Local Authority Pension Funds and financial institutions on our own Modern Slavery approach which shows that the regulation is working and will continue to refine our response to these requests.
Feedback on our approach
Any feedback on our policy and approach to Modern Slavery should be directed towards firstname.lastname@example.org
If you have concerns regarding our activities or those of a supplier please contact our Whistleblowing Service
Hotline: 0800 072 5281
This policy is owned and overseen by Dr Nigel Wilson, Group CEO of Legal & General Group Plc on behalf of the Group Board.