This statement is approved by the boards and made on behalf of Chubb European Group SE (“CEG”), Chubb Services UK Limited (“CSUK”) and Chubb Capital I Limited (together referred to as ‘Chubb’) and constitutes Chubb’s slavery and human trafficking statement for the financial year ending on 31 December 2021.
Chubb provides commercial and personal property and casualty insurance, personal accident and supplemental health insurance, reinsurance and life insurance to a diverse group of clients. We aim to comply with legal and regulatory requirements everywhere we do business and to embed the values in our Code of Conduct in our activities.
CEG is one of Europe’s leading commercial insurance and reinsurance companies and operates a successful underwriting business throughout the UK, Ireland and Continental Europe. Headquartered in Paris it holds cross-border permissions throughout the European Economic Area through its branches and licences and operates under the supervision of the Autorité de Contrôle Prudentiel et de Résolution. CEG is also a ‘white listed’ surplus lines insurance and reinsurance company in the United States, entitling it to write surplus lines in all US states and US territories. Business is accessed by a variety of distribution channels and the company has strong relationships with the broker community, its corporate partners and direct markets.
CSUK acts as the principal employer of staff, jointly with CEG, for Chubb’s UK employees and is a corporate service provider within the Chubb Group companies in the United Kingdom.
Chubb Capital I Limited is a corporate capital vehicle that provides 100% of the underwriting capital of Lloyd’s Syndicate 2488 and is a corporate member of Lloyd’s. It is a wholly owned subsidiary within the Chubb Group.
Our supply chains include vendors that assist Chubb in the fulfilment of insurance claims and suppliers from which we procure goods and services to carry out our business.
The Chubb Code of Conduct affirms our commitment to compliance with equal employment opportunity laws and other applicable civil rights, human rights and labour laws. The Chubb Group has been an active participant of the UN Global Compact since 6 June 2017 and provides an annual statement of practical actions and a measurement of outcomes with regard to the 10 principles of the UN Global Compact which also seeks to eliminate all forms of forced and compulsory labour and abolition of child labour. Chubb expects staff to behave ethically and transparently and to be accountable for their actions. Chubb policies, frameworks and actions, which aim to prevent modern slavery and human trafficking in our business and supply lines include:
- Undertaking employment and identification verification checks as part of our hiring process;
- Requiring agencies who supply workers to carry out employment and identification verification checks, wherever staff are located;
- Procurement questionnaires requiring third party suppliers to state what steps they take to comply with the Modern Slavery Act 2015;
- Procurement agreements requiring third party suppliers to comply with applicable laws and regulations and permit Chubb to terminate relationships where they fail to do so;
- Subjecting key business transactions to both on boarding and periodic regulatory screening;
- Providing regular training for staff on sanctions restrictions, anti-bribery, anti-money laundering, and the Chubb Code of Conduct to which they must attest (the training module on the Chubb Code of Conduct requires staff to be alert to the risks of slavery and human trafficking and to report concerns);
- Providing training and support for all staff on how and where they can raise concerns about wrongdoing and assurances that they will not suffer reprisals for doing so;
- Taking appropriate action where potential violations of the Modern Slavery Act 2015 are identified; and
- Board oversight and risk assessment of modern slavery and human trafficking through Chubb’s Corporate and Social Report published annually.
Chubb’s Procurement, Risk, Compliance, HR and Legal teams work together to apply these standards to our business. We continue to update our policies and procedures to make our commitment to anti-slavery and human trafficking explicit to our customers, employees, suppliers, and business partners.
- The Chubb Code of Conduct was updated in 2021 to explicitly refer to slavery and human trafficking in the context of our human rights protection policy;
- Our Whistleblowing Policy was updated in 2021 amongst other things to: (i) require periodic training for those who are appointed recipients of whistleblowing concerns; and (ii) clarify that only maliciously false reports are not acceptable to Chubb.
- All new starters receive e-learning training on ‘Speaking Out’ as part of their induction programme.
- Guidance for staff and managers on how to raise concerns was also issued in 2021.
Chubb is mindful of the UK’s Independent Anti-Slavery Commissioner’s September 2021 recommendations to financial institutions, including on (i) voluntary reporting on investment and lending portfolios; and, (ii) electronic supply chains. In 2021 we:
- have surveyed external investment managers in respect of their capacity to identify third parties exposed to modern slavery and human trafficking risks; and,
- took steps to consolidate our facilities management supply chain in the UK and Europe, a services category where human resources is a key component.
In 2021 we continued supporting various charitable initiatives and made our first donation to a UK based charity that provides assistance to victims of slavery and human trafficking.
David Furby
Regional President European Group
20 April 2022