These guidelines apply to all individuals working at all levels and grades within EC3 Marine Ltd. Including directors, senior managers, officers, employees (whether permanent, fixed term or temporary), trainees, seconded staff, homeworkers, casual workers, agency staff, volunteers and interns. However, we also expect that all of our business partners globally conduct their business ethically and that they too comply with these guidelines.
1. Introduction and Purpose
This statement is made in relation to section 54 of the Modern Slavery Act 2015 (the “Act”) and constitutes the EC3 Marine’s continued commitment to adherence to the Act. This statement sets out the actions taken by the EC3 Marine Ltd to understand potential modern slavery risks related to its business and to put in place measures aimed at ensuring that its business and supply chain are free from modern slavery and human trafficking.
2. Structure of EC3 Marine Ltd
EC3 Marine Ltd is a Marine Claims Service company and as such is a regulated entity subject to regular audits by our TPA clients as authorised by the Prudential Regulation Authority (PRA) and regulated by the Financial Conduct Authority (FCA) and the PRA. EC3 Marine Ltd is an insurance intermediary but we are not involved in the procurement of business (i.e., we are not an insurance agent or an insurance broker).
3. Modern Slavery Policy
EC3 Marine Ltd recognises its obligations to all those with whom it has dealings – shareholders, employees, customers, clients, professional and regulatory authorities, suppliers, competitors and the wider community – and as such demands and maintains the highest ethical standards in carrying out its business activities and promulgate a zero-tolerance approach to modern slavery. We are committed to ensuring that there is no modern slavery and human trafficking in any part of our business or supply chains.
4. Our Supply Chains
We believe that there is minimal risk of EC3 Marine Ltd becoming involved in the support or encouragement of slavery, human trafficking or forced labour due to our limited supply chains. EC3 Marine Ltd outsources some functions to reputable professional firms, including but not limited to IT/Telephonic service providers, surveyors and indirectly utilises the services of third parties for office management (accounting purposes). Our suppliers are expected to operate to the highest professional and ethical standards and to comply with all local and national laws and regulations.
We have continued to identify and minimise the risk of slavery and human trafficking occurring within our business and supply chain, as part of this initiative, we:
• Identify and assess potential risk areas in our supply chains;
• Mitigate the risk of slavery and human trafficking occurring in our supply chains;
• Monitor potential risk areas in our supply chains;
• Make our suppliers aware of our standards and zero tolerance of human rights abuse;
• Annually review our existing policies and procedures, as detailed below, both for engaging new suppliers and monitoring existing suppliers in order to make every effort to ensure that they meet the requirements of the Act and the ethical values expected of them by EC3 Marine Ltd.
5. Employees
Our working practices respect and uphold all human rights for our partners, employees and contractors. To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have a range of policies that are published to all staff. These include:
• Modern Slavery Policy;
• Whistleblowing Policy;
• Ethics Policy;
• Financial Crime Policy;
• Anti-Bribery Policy;
• Outsourcing (please refer to 4.0 Our Supply Chains);
• Sanctions Policy;
• Employee Code of Conduct which forms part of the Company Handbook;
which set out a developed set of values which are embedded in our business.
We provide mandatory training to our staff, who adhere to the standards outlined in these policies. Furthermore, as part of our performance management process, staff are assessed against meeting these values, which include treating people fairly and with respect.
Staff reporting any concerns or breaches of any policy are protected by the EC3 Marine Whistleblowing Policy.