AXA Insurance dac - Slavery and Human Trafficking Statement
This statement is made by AXA Insurance dac (the “Company”) pursuant to Section 54 of the UK Modern Slavery Act 2015 (the “MSA”). It sets out the steps that the Company has taken during the 2019 financial year to combat and prevent all forms of modern slavery and human trafficking in its business and supply chains. This statement covers the Company’s direct operations and supply chains.
1. Company’s structure and business
The Company is registered in Ireland, employs 1,200 people and provides non-life insurance products in the Republic of Ireland and Northern Ireland on-line, through a network of branches, over the phone and through brokers.
The Company is authorised and regulated by the Central Bank of Ireland. Deemed authorised by the Prudential Regulation Authority. Subject to regulation by the Financial Conduct Authority and limited regulation by the Prudential Regulation Authority. Details of the Temporary Permissions Regime, which allows EEA-based firms to operate in the UK for a limited period while seeking full authorisation, are available on the Financial Conduct Authority’s website.
The Company is part of the wider AXA Group, headquartered in Paris, which has a long history of adhering to and promoting strong professional ethics and is committed to conducting its business according to the highest standards of honesty and fairness. This commitment to observing such ethical standards is designed not only to ensure compliance with applicable laws and regulations in the various jurisdictions where the AXA Group operates but also to earning and keeping the continued trust of its clients, shareholders, personnel and business partners. The AXA Group believes that its success and reputation is not only dependant on the quality of its products and the services provided to its clients, but also on the way it does business. This includes a strong commitment to human rights and therefore, it welcomes the transparency promoted by the MSA.
2. Company’s supply chains
The Company is a purchaser of products and services for the purpose of its internal office based operations, such as supplying stationary, security and cleaning services for example. The Company also uses a supply chain to handle certain elements of the claims handling process for our customers consisting primarily of motor repairers and builders. The Company is not a producer, manufacturer or retailer of physical goods and has no supply chain in relation to such activities.
The Company therefore views that the supply chain is limited and that it is generally restricted to sectors that are viewed as having a low risk of modern slavery and human trafficking.
3. Our Policies in relation to modern slavery and human trafficking
The AXA Group is committed to respecting internationally recognized human rights principles as defined by the United Nations Universal Declaration of Human Rights, the core standards of the International Labour Organisation and the Guiding Principles for the implementation of the United Nations “Protect, Respect and Remedy” Framework (Ruggie Principles). The AXA Group is also committed to applying international general and sector-specific standards such as the UN Principles for Responsible Investment, the UN Principles for Sustainable Insurance and the UN Global Compact (“UN GC”). Since 2003, AXA adheres to the UN GC and has formally committed to promoting its ten guiding principles, including those on human rights (such as avoiding complicity in human rights abuses and supporting and respecting the protection of internationally proclaimed human rights) and labour standards (such as supporting the elimination of all forms of forced and compulsory labour and the effective abolition of child labour).
In addition, the AXA Group has put in place policies to support its commitment to ethical business practices across the organisation. These include:
- The AXA Group Human Rights Policy, which aims to ensure that (i) the Group does not cause or contribute to adverse human rights impacts and (ii) such impacts are addressed when they occur. The policy also sets out AXA’s commitment to identify, prevent and/or mitigate adverse indirect human rights impacts that are linked to its operations or services, through its business relationships or projects it has invested in or insured.
- The AXA Group Compliance and Ethics Guide (the “Guide”), which establishes guiding principles and Group-wide policies designed to ensure that all AXA Group companies and their personnel have a common vision of the Group’s ethical standards (including the UN GC principles on human rights, labour standards, environment and anti-corruption) and operate in accordance with those standards. All AXA employees are encouraged to report promptly any practices, actions or conduct that they believe are inappropriate or inconsistent with any of the policies set out in the Guide through their local whistleblowing procedures. Seniors officers of AXA entities are asked to submit an annual certification to confirm that they comply with all the provisions set out in the Guide.
The AXA Group Human Rights Policy, the Guide and the principles and standards mentioned above all apply to the Company. The senior officers of the Company all complied with the annual certification process in relation to the Guide for 2019. In addition, the company also adheres to the AXA Ireland Protected Disclosures (Whistleblowing) Policy, which details how employees can raise concerns where they believe there may be wrong-doing or improper conduct by senior managers, other employees, suppliers or contractors.
4. Assessment of Company’s largest suppliers and due diligence process in relation to the Company’s supply chain
The Company ensures they work with suppliers that meet the AXA standards with respect to ethics and corporate responsibility through a clearly documented process for supplier selection and contracting.
In accordance with such process, the Company’s standard contractual terms with suppliers include specific reference to AXA’s corporate responsibility requirements and suppliers are required to provide a formal commitment to uphold the core standards of the UN GC by signing AXA’s “Corporate Responsibility clause”. Notably, the suppliers agree to refrain from using, or accepting that their own suppliers and sub-contractors make use of, child labour (under 15 years old) or forced labour.
Detection of a direct or indirect violation by a supplier of the AXA corporate responsibility requirements would be discussed directly with the supplier with a view to establishing a mutually agreed and documented corrective action plan. Where any issue cannot be resolved satisfactorily, the Company reserve the contractual right to end their relationship with the relevant supplier.
5. Training and information available to staff
The Company will continue to provide information for procurement employees to give them a detailed knowledge of AXA’s corporate responsibility principles. This will highlight the instrumental role of responsible procurement in order to ensure that AXA engages with responsible suppliers.
6. Feedback on our approach
Any feedback on our policy and approach to the MSA should be directed to towards firstname.lastname@example.org.
The Company’s Board of Directors approved this statement on the 18th June 2020, which constitutes the Company’s slavery and human trafficking statement for the financial year ending 2019.
Phil Bradley, Chief Executive Officer, AXA Insurance dac