Modern slavery is a morally reprehensible act and a violation of fundamental human rights. Modern slavery can take various forms and is imposed on one person for another person's gain. Chubb Insurance Australia Limited (ABN 23 001 642 020; AFSL 239687) (Chubb) is fully committed to playing its part to eradicate modern slavery in all of its forms (including slavery, servitude, forced labour, exploitation and human trafficking) in our operations and our supply chains. Chubb has taken steps to address modern slavery as outlined in this statement.
This statement is published in accordance with, and addresses the reporting requirements under, Australia’s Modern Slavery Act 2018 (Cth) as may be amended from time-to-time and any replacement, successor or functionally similar or delegated legislation of the Commonwealth of Australia (MS Act). It sets out the steps taken by Chubb to identify, manage and reduce modern slavery risks and impacts across our operations and supply chains. Approved by Chubb’s Board, it constitutes Chubb's Modern Slavery Statement (MSS) for the financial year ending on 31 December 2020.
Chubb is the world's largest publicly traded property and casualty insurance company. Chubb, via acquisitions by its predecessor companies, has been present in Australia for 100 years. Its operation in Australia provides specialised and customised coverages, including Business Package, Marine, Property, Liability, Energy, Professional Indemnity, Directors & Officers, Financial Lines, Utilities, as well as Accident & Health insurance, to a broad client base, including many of the country’s largest companies. Chubb also serves successful individuals with substantial assets to protect and individuals purchasing travel and personal accident insurance. With five branches and more than 800 staff in Australia, it has a wealth of local expertise backed by its global reach and breadth of resources.
Chubb aims to comply with legal and regulatory requirements everywhere we do business and to embed the values in our Code of Conduct in our activities. The global Chubb Code of Conduct affirms our commitment to compliance with equal employment opportunity laws and other applicable civil rights, human rights and labour laws. Chubb UK also publishes its own MSS in accordance with the Modern Slavery Act 2015.
Chubb policies, frameworks and actions, which aim to prevent modern slavery and human trafficking in our business and supply lines include the following.
Chubb’s supply chain includes global and local insurance brokers, underwriting agencies, claims administrators, reinsurers, information technology providers, consultancy and professional services firms, and a wide variety of legal, marketing, travel, catering, cleaning, stationery and courier businesses, which are located primarily in Australia.
Based on the insurance sector in which Chubb operates and its supply chain profile, the risk of modern slavery practices has been assessed as relatively limited. However, Chubb acknowledges the potential for indirect exposure to the risk of modern slavery in our business operations and supply chains and has attempted to identify these and address any risk of modern slavery.
Chubb has developed and will implement a policy and process to conduct a risk assessment for each of our third-party providers within our supply chain by adopting a methodology of supplier due diligence and analysis by size of supplier, by sector and by geography. This review and risk assessment includes but is not limited to:
The greatest risk of modern slavery within Chubb’s business is in relation to our suppliers. Our employees are employed by Chubb or entities within the broader Chubb corporate group, which minimises the risk of modern slavery within our workforce. Similar to the risk assessments performed on suppliers, Chubb will consider its operational aspects such as its recruitment processes, agency contracts and arrangements with any independent contractors to identify any modern slavery risks.
These supply chain and operational assessments determine our response and the risk controls we implement to address any modern slavery risks we identify.
Chubb establishes a relationship of trust and integrity with each of our suppliers. Our supplier selection and onboarding procedure includes due diligence of the supplier's reputation including any misconduct risk and respect for the law.
Chubb conducts due diligence on all new suppliers and for existing suppliers ongoing monitoring is undertaken to ensure the standards we expect from our suppliers has been maintained. This includes assessing risks in the provision of services via a questionnaire as part of the onboarding process for prospective suppliers and requiring regular attestations from our existing suppliers that:
Chubb will provide mandatory e-learning in the form of a modern slavery course to all staff. The training highlights:
Chubb strives to maintain high ethical standards in our business practices and currently has the following policies for identifying and preventing slavery and human trafficking in our operations.
Chubb has introduced anti-modern slavery requirements in all of our new or renewed suppliers’ agreements to acknowledge, represent and warrant that they effectively comply with the MS Act.
Chubb has defined a set of key performance indicators and controls to combat modern slavery in our organisation and supply chain. These include:
Chubb's Procurement, Risk, Compliance, HR and Legal teams work together and in close consultation with the business to apply these standards to our business.
We will make our commitment to doing our part to eradicate modern slavery explicit to our customers, employees, suppliers, and business partners through this statement and by continuing to update our policies, procedures and agreements.