Modern Slavery Statement

EXECUTIVE SUMMARY

Context

The Modern Slavery Act 2015 requires that businesses within the UK which have an annual turnover of £36m or more produce an annual statement setting out the steps they have taken during the preceding financial year to ensure there is no modern slavery in their business or supply chain.

We have worked with key stakeholders throughout the business (including representatives from Legal, Procurement, Investments, Practice Plan, Customer, HR and Risk) to produce the statement for the financial year ending 31 December 2023, and this is now presented for approval.

We are permitted by the Act to produce one statement to cover the whole of Wesleyan Group activity. However, the board of directors of each individual group company must separately approve the Statement.

Questions this paper addresses

  1. Why do we need to produce a Modern Slavery Statement?
  2. What companies does it cover?
  3. What are the main areas of action in the last year, and what are the proposed actions in the coming year?
  4. Who has been involved in putting it together?

Conclusion

The 2023 Modern Slavery Act statement should be approved and signed. It is also being tabled for approval at subsidiary boards and once fully approved will be made available on the group’s websites and also uploaded to the Home Office central registry.

Input Sought

The Board is asked to approve the Modern Slavery Statement for the year ended December 2023.

THE REPORT

Further Context

1.    Why do we need to produce a Modern Slavery Statement?

  • The Modern Slavery Act 2015 requires that businesses within the UK which have an annual turnover of £36m or more produce an annual statement setting out the steps they have taken during the preceding financial year to ensure there is no modern slavery in their business or supply chain.

2.    What companies does it cover?

  • The Statement covers the following companies:
    • Wesleyan Assurance Society
    • Wesleyan Administration Services Ltd
    • Wesleyan Financial Services Ltd
    • Practice Plan Ltd
    • DPAS Ltd
    • Medenta Finance Limited
    • Wesleyan Unit Trust Managers Limited

3.    What are the main areas of activity in the last year, and what is the proposed activity in the coming year?

  • The main areas of activity last year were:
    • Investments and Procurement are working together on an additional due diligence process for companies with substantial operations/ headquarters in ‘higher risk’ countries.
    • Procurement has collated statistics on our country risk and reported this
    • Our Modern Slavery trading has been completed by 98% of
    • We have ensured that our minimum salary level to 8% above the National Living Wage and increased all salaries to within 80% of the market rate for the specific role.
  • The proposed activity for the coming year:
    • Investments and Procurement to conclude their country risk due diligence process for ‘higher risk’
    • HR to continue to develop risk assessment criteria and enhance onboarding checks to respond to any changes in Modern Slavery legislation.
    • Review activities and processes anticipated under the proposed new Modern Slavery
    • Procurement to publish country of origin of sourcing inputs in supply

4.    Who has been involved in putting it together?

  • The following have inputted into the Statement:
  • Legal: Ian Rose
  • Risk: Dan Gamson
  • Investments: Lucas Howarth
  • HR: Louise Beards/David Taylor
  • Procurement: Emma Goodwin
  • WFS: Stuart Brown/Kerri Trinder
  • MLRO: Angela Dunn
  • PPG: Jackie Fletcher
  • Co Sec: Matthew Cooch

SOCIETY IMPACT SUMMARY

Introduction

This is a summary of the impacts on the Society. Further details on these are within the report itself.

Financial impacts on the Society

  • Compliance with the Modern Slavery Act is a legal obligation. Failure to comply would have both a reputational and financial cost to the Society.

Impacts on risk and governance

  • Compliance with the Modern Slavery Act is a legal If a business fails to comply, the Secretary of State may seek an injunction through the High Court requiring it to do so.

Regulatory requirements

  • Compliance with the Modern Slavery Act is a legal

Impact on people and culture

  • Reputationally important for Wesleyan to demonstrate compliance with his

Sponsor: Jon Welsh

Author: Ian Rose

GEC, SOCIETY BOARD AND ALL

APERATING SUBSIDIARY BOARDS

Date of Meeting: Various

Date Written: 13/03/2024