SLAVERY & HUMAN TRAFFICKING
SLAVERY AND HUMAN TRAFFICKING STATEMENT for the year ended 31 December 2020
Approved by the Board on June 9, 2021
Published June 2021
This statement is made on behalf of Enstar Group Limited and all its majority-owned subsidiary companies including, but not limited to, the companies based or operating in the United Kingdom (“Enstar”, “we” or “our”).
This statement is made pursuant to section 54(1) of the UK’s Modern Slavery Act of 2015 (“the Act”) and constitutes Enstar’s slavery and human trafficking statement for the financial year ended December 31, 2020. It is reviewed annually. This statement sets out the steps Enstar has taken to ensure that Slavery and Human Trafficking (as defined in the Act) is not taking place in our supply chains or in any part of our business.
The Board believes Enstar’s business model and supply chain represents a low risk of exposure to slavery and human trafficking. We embody the highest professional standards and comply with the laws and regulations applicable to our business. We expect the same high standards from those parties with whom we engage.
Nature of our Business
Enstar is a leading global insurance group that delivers innovative insurance solutions through our network of group companies. Our diversified portfolio of companies is positioned across the world’s major insurance hubs spanning Bermuda, the U.S., the United Kingdom, Continental Europe, and Australia.
The core of Enstar’s ongoing business is the acquisition and management of legacy insurance risk. We assume ceased portfolios and entire companies, allowing our clients to release operating capital, management time, and other resources for better use in their ongoing activities. Our primary focus is property/casualty companies and portfolios in run-off.
Through various subsidiary companies, Enstar lends its expertise in risks and liabilities through third-party consulting. Our services to the re/insurance industry range from full-service, incentive-based run-off management to client-specific solutions such as claims inspection and validation, reinsurance asset collection, syndicate management, and IT consulting.
Our Policy on Slavery and Human Trafficking
We endeavour to ensure that there is no slavery or human trafficking, as defined in the Act, in our supply chains or in any part of our business. We aim to implement and enforce effective and proportionate systems and controls to ensure slavery and human trafficking is not accepted anywhere in our supply chains.
The Enstar Group Code of Conduct applies to all Enstar subsidiaries, including all UK-based subsidiaries, and details the business principles and ethics which all employees and the business adheres to. From 2021, material vendors and contracting parties will also be expected to comply with a Supplier Code of Conduct, which sets equivalent standards of conduct by our vendors.
Enstar does not accept any breach of human rights including slavery and human trafficking. The Code of Conduct is board-approved and this statement is aligned with the principles set out in the Code. As a business we raise awareness with our staff to be alert to the risk, however remote, that we might become party to either slavery or human trafficking in our business and in the wider supply chain. Staff are encouraged to report concerns to management, which may be made anonymously through a Whistleblowing facility, which would be evaluated and acted upon appropriately.
CONSIDERING OUR SUPPLY CHAINS
The Enstar Group offers insurance and reinsurance legacy portfolio solutions, focussed on the administration and handling of claims for legacy (run-off) underwriting business, which is a regulated financial services activity.
The underwriting business managed by Enstar is acquired from other regulated insurance companies, which originally sourced this business through a range of worldwide brokers. We continue to deal with those brokers for the administration of insurance contracts for which Enstar companies are responsible for the payment of claims.
These brokers derive their income from the client (the (re)insured) and as such we do not consider brokers to be a part of our supply chain in this context. That said, we only deal with reputable firms who are regulated by a local insurance regulator. This regulation will typically include an assessment of their fitness and propriety.
Some business, particularly that formerly underwritten by StarStone, was underwritten through Coverholders and other third parties located globally (most significantly in the UK, EU, US, Canada and Australia). These firms act as the agents of the insurer. As part of the due diligence performed when taking on a new Coverholder, an assessment was made of the likely exposure to slavery and human trafficking in the countries in which they operate and assurance sought where relevant.
For certain activities we retain outsourced services providers to administer our affairs (e.g. claims handling, loss adjusting, policy processing) or provide outsourced support functions (e.g. investment management). Our Procurement Policy recognises the need for an assessment of the risk of exposure to possible slavery or human trafficking and we require commentary on how this risk is mitigated as part of the due diligence process prior to approval or renewal of the material service provider.
We do use business services suppliers to provide maintenance and support for our office operations, such as office equipment, computer supplies, and travel agents. We do not act as a producer, manufacturer or retailer of physical goods and have no supply chain for possible slavery or human trafficking matters.
A commitment to maintain high standards of compliance with human rights is expected from all employees, contractors and vendors, and form the basis of a Vendor Code of Conduct being implemented in 2021. This will clearly articulate that the use of child labour or forced labour by Enstar’s vendors is strictly prohibited. Vendors and other third parties with whom Enstar conducts business will be required to agree to follow Enstar’s Code of Conduct, or attest to operating to at least an equivalent Code of Conduct. Third parties will be held accountable for their commitment to human rights, including the prevention of human trafficking and slavery in their supply chains.
All Directors have been briefed on the subject. A training programme is being implemented in 2021 to all staff to promote awareness of potential signs of human trafficking and modern slavery. Additional training will be provided to management and staff with direct responsibility for supply chain management. We also ensure staff are aware through the provision of this statement to all staff on joining, and annually thereafter following approval by the Board.
Our Whistleblowing policy is published to all employees with a summary displayed prominently in our offices and on our intranet home page. This encourages employees to raise any genuine concerns about any wrongdoing or breaches of law, including slavery and human trafficking, with the facility to do anonymously.
Our Code of Conduct, which all employees are required to read and acknowledge annually, also contains provisions regarding Enstar’s expectations regarding human rights and non-tolerance of human trafficking and modern slavery.
Measuring our Effectiveness in Combating Slavery and Human Trafficking
We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
- Policy approved by the Board annually; published on website and provided to staff through direct communication channels.
- Completion of training by staff.
- Due diligence performed at the time a contract is established on material outsource providers and suppliers giving consideration of the risk.
- Due diligence on existing providers through questionnaires and on-site visits regarding their compliance with human rights provisions including prevention of modern slavery and human trafficking.
- Monitoring of the whistleblowing facility which enables anonymous reporting by employees and external parties who wish to raise points of concern but do not feel able to do so through line management. This would enable escalation of any concerns about slavery and human trafficking.
- Reporting by exception of any issues of possible slavery and human trafficking to the Board by the Compliance Officer.
- The Compliance Officer will report annually to the Board regarding compliance with this Policy.
To date, we have not identified any instances of human trafficking or slavery within Enstar or firms with which we conduct business. We continue to remain vigilant, enhancing our procedures to monitor suppliers and articulate our expectations regarding human rights, as well as providing training to staff.
Approved by the Board of Directors
Enstar Group Limited
June 9, 2021
BOARD DIVERSITY POLICY
StarStone Underwriting Limited (“StarStone”) recognises diversity as any dimension that can be used to differentiate groups and people from one another. Encouraging diversity in our business is about empowering people by respecting and appreciating our staff and our policyholders and clients by embracing their diversity, whether that is in terms of age, gender, ethnicity, religion, disability, sexual orientation, education, or national origin.
StarStone recognises and values the importance of having a diverse workforce, and that it is essential as part of our corporate culture to promote and encourage diversity throughout the business in line with our wider principles and values. We believe that this should be reflected in all areas of the business, including that of the Board of Directors, who set the tone from the top for how we conduct ourselves both internally and in the market.
StarStone is therefore committed to composing boards that reflect the diversity that we aim to have across the business. We aim to appoint talented and skilled directors with a mix of expertise, experience, skills, perspectives, and backgrounds. We believe this is currently reflected in the Board of Directors we have at present and are committed to ensuring that this develops further in the future.
Diversity is embedded into the director appointment process. When assessing Board composition or identifying suitable candidates for appointment or re-election to the Board, StarStone will consider candidates on merit while ensuring that due regard to the benefits of diversity and the needs of the Board are also considered.
The annual Board performance review will take a holistic view of how the Board is performing, while also considering whether it reflects an appropriate level of diversity of skills and capabilities to function effectively.
This policy statement and approach is reviewed annually in conjunction with the Board performance review.