Slavery and Human Trafficking Statement 2024
This statement applies to Howden Group Holdings Limited and subsidiary companies (the “Group/we/our/us”) and is made pursuant to section 54(6) of the UK Modern Slavery Act 2015 (the “Act”). It constitutes the Group’s slavery and human trafficking statement for the financial year ended 30 September 2024.
About the Group
Howden Group Holdings is a leading international insurance group with employee ownership at its heart. Founded in 1994, its trading operations comprise of: retail and specialty insurance broking; reinsurance broking; managing general agencies; provision of employee benefit solutions; and digital, data and analytic services for the insurance industry.
We are an international business, headquartered in London, with offices in 60 countries, including over 200 local offices in the UK & Ireland. We operate across Europe, Africa, Asia, the Middle East, Latin America, the USA, Australia and New Zealand, employing more than 20,000 people.
Our structure
The Group has a devolved governance and operating structure with a central shared services function. Each business is managed in-country and in accordance with local governance and regulations. We have policies and procedures in place where relevant and required, and adapt these to best meet local regulation, requirements and practices, and to best manage our businesses and people.
Due to the nature of our business and the size of many of our offices, we operate a decentralised procurement model which utilises local buying and operational team members.
Our staff are engaged on full-time, part-time or flexible working arrangements and are appropriately remunerated and incentivised. Contractors may be employed by the Group from time to time, but these are largely professional workers for specific projects.
Modern slavery
The Group remains committed to being a responsible business and recognising the importance of tackling the risk of modern slavery in our business.
We are committed to the welfare of all our employees, including in terms of pay, working hours, environment, health & safety and wellbeing. We will not tolerate violations of basic human rights or employment practices by or against any employees, or within our supply chain.
As a professional service provider, we believe that insurance is not deemed to be a key risk sector as our employees work in roles that are primarily office based and/or generally require specialist qualifications.
We adhere to the highest standards of human rights and labour rights, ensuring fair and ethical treatment of all our employees and stakeholders. Our commitment is grounded in the principles contained within the Universal Declaration of Human Rights and the International Labour Organization Core Conventions on Labor Standards.
Vendor supply chain
Our vendor supply chain primarily consists of professional, IT, insurance and consulting services, along with property and purchased equipment, and our use of hospitality and travel providers.
Due diligence
We continue to work on programmes and initiatives across our business to embed the evaluation and communication of our modern slavery and human rights requirements into supplier selection and management activities.
Our vendor risk management tool was introduced in 2023 to assess vendors, including ESG risk. In 2024, we continued to bring more vendors onto the tool and we will continue to do so while also working with international entities to support its adoption. Where appropriate, vendors are then subject to third party monitoring and will be required to complete due diligence questionnaires (DDQs). We continuously review our vendor DDQs to ensure that we have the information we need to make informed decisions and minimise risk.
Training
Training is available to staff members to understand the risks of modern slavery and human trafficking in our supply chains and business. This training covers an explanation of: what constitutes modern slavery and high-risk areas; warning signs to be aware of; and what action or steps to take in response. The Group continues to roll out the modern slavery module of this through compliance training for each business and their employees.
Recruitment and selection
All entities in the Group have appropriate controls in place to ensure employees have the right to work and are therefore protected by employment legislation. This includes checking right-to-work documents, visas and passports.
In the UK, we also verify that employees have supplied proof of address/residence to work in the country. The Group is also actively adopting more inclusive hiring practices globally by increasing line manager awareness and accountability of unconscious bias in the hiring process and therefore driving a more objective recruitment process.
We also source candidates through more diverse recruitment channels, aiming to increase the proportion of under-represented groups in the workplace. Likewise, the Group uses only specified, reputable employment agencies to source candidates.
To ensure that the Group complies with Modern Slavery legislation this, we mandate that agencies for both temporary and permanent workers enter into our agreements, which place obligations on those agencies to comply with all applicable laws, and provide us with their modern slavery policy, where applicable.
The Group does not employ individuals who would be considered to be ‘child workers’. Young and inexperienced workers may be employed or given work experience, but they are subject to the rights and protections that we afford all workers.
Basic rights which we expect all employees to have access to include:
- The right to a reasonable wage (e.g. UK Living Wage)
- The right to a safe working environment
- The right to an appropriate level of holiday and cover for a period of sickness
- The freedom to complain directly or via our whistleblowing policy.
The above are monitored by the respective HR Business Partners, Chief Operating Officers and Chief Risk Officers, ensuring that all employees have access to the whistleblowing policy and phone number should they believe that they are not being fairly treated or have any other concerns.
Policies
The Group has a number of policies to mitigate the risk of modern slavery and set out steps to be taken to prevent slavery and human trafficking in its operations. The policies across the Group vary but include: Principles of Business; Whistleblowing; Grievance; Anti-Bribery; and Anti Money Laundering.
Whistleblowing
The Group encourages all of its employees, third parties or counterparties (e.g. customers and other business partners) to report any concerns related to the direct activities or the supply chains of the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
The Group has incident reporting details displayed on its website to allow for third parties, such as clients, suppliers and contractors, to report any cases of wrongdoing.
The Group’s whistleblowing procedure is designed to make it easy for any individual to make disclosures without fear of reprisal. Employees who have concerns can use our confidential helpline through SafeCall. This independent reporting line is widely advertised across all offices and monitored by our Group Chief Risk Officer and Group General Counsel.
Alternatively, disclosures can be reported by employees notifying their line manager or a senior member in HR, who will conduct or arrange for a senior individual to conduct an anonymous investigation. Otherwise, the individual may deem it appropriate to contact a legislative body, in which case, examples of the relevant authorities are listed in the Group Whistleblowing Policy.
Across all disclosure routes, no calls or direct disclosures were made in 2024 in relation to modern slavery and trafficking.
Looking forward
As we grow as a business, the importance, number and scale of relationships in our supply chains grow too. We continue to take steps to assess areas where modern slavery could be a possibility and look at the best and most effective mechanisms to manage these risks.
In 2025, we expect to introduce a Procurement Policy that will set the expectations with Group contract owners when engaging with suppliers. This will include consideration of ethical, social and environmental principles, including human rights and labour practices, in relation to suppliers.
Our modern slavery and human trafficking statement for the financial year ended 30 September 2024 has been approved by the Board, as reflected by the Group CEO’s signature below. Slavery and human trafficking statement as required under s54, Part 6, of the UK Modern Slavery Act 2015 for the financial year ended 30 September 2024.
David Howden, Group CEO
28 March 2025