Modern Slavery Statement

Introduction

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year. This statement applies to Bought By Many Limited and its subsidiaries (referred to in this statement as ‘the Company’). The information included in this statement refers to the financial year from April 2020 to March 2021.

In order to fulfil its activities, the main supply chains of the Company include those related to marketing, insurance product distribution and outsourced services.

The Company considers its exposure to modern slavery and human trafficking to be limited.

Company structure

The Company has a formally constituted Board with a non-executive Chairman, 4 Non-Executive Directors and 3 Executive Directors. The Senior Leadership Team is responsible for operational management of the business and the implementation of this policy in their own area.

UK operations: Haywards Heath (Sussex), Birmingham and London. Sweden operations: Stockholm (registered as Bought By Many Filial Sweden). US operations: New York and Atlanta.

The Company is a provider of pet insurance, sold via its own website, distribution partners, and aggregator websites. Outsourced arrangements are in place for the provision of claims handling services and software development projects. It has customer support centres in the UK and Sweden. The US is a start-up operation and not currently trading.

Definitions

The Company considers that modern slavery encompasses:

  • human trafficking
  • forced work, through mental or physical threat
  • being owned or controlled by an employer through mental or physical abuse or the threat of abuse
  • being dehumanised, treated as a commodity or being bought or sold as property
  • being physically constrained or having restrictions placed on freedom of movement.

Commitment

The Company acknowledges its responsibilities in relation to tackling modern slavery and human trafficking and commits to complying with the provisions in the Modern Slavery Act 2015. The Company understands that this requires an ongoing review of both its internal practices in relation to its labour force and its supply chains.

The Company does not enter into business with any other Company, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, human trafficking, servitude and forced or compulsory labour.

The Company has not, to its knowledge, conducted any business with another Company that has been found to have involved itself with modern slavery or human trafficking.

The Company seeks to purchase and source all products and services used in its business operations from suppliers who share the same commitment to eliminate modern slavery and human trafficking in their Company and associated supply chains.

No labour provided to the Company in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the countries where it operates.

Action

In accordance with section 54(4) of the Modern Slavery Act 2015, the Company will take the following steps:

  • Review existing suppliers and contracts to ensure alignment with this statement
  • Include termination powers in contracts in the event that the supplier is, or is suspected, to be involved in modern slavery and human trafficking
  • Implement due diligence processes for potential future suppliers
  • Embed a zero-tolerance policy towards modern slavery and human trafficking through communication to employees.

Policies and procedures

The Company operates the following policies and procedures to support its commitment:

  • Whistleblowing Policy: published to encourage employees to report concerns about individual or company practices that could promote or support modern slavery
  • Equal Opportunity and Dignity at Work Policy: a zero-tolerance approach to harassment, bullying and discrimination based on protected characteristics
  • Recruitment standards: well-defined selection processes based on job requirements
  • Right to Work verification: carried out prior to point of hire for all employee appointments
  • Employment contracts: fair terms and benefits; no use of zero hours contracts
  • Employment checks: appropriate checks to comply with financial services regulations; employment references for all roles
  • Pay determination: market benchmarking to establish fair pay according to role; all pay is above the minimum legal wage
  • Bonus schemes: based on achieving documented and agreed company goals
  • Contractual standards: all contracts are reviewed by the Legal department
  • Competitive tendering for supply of services: tenderers are required to confirm their commitment to the principles of this statement.

Responsibilities

All concerns regarding modern slavery should be addressed to the Chief Executive Officer, who will then undertake relevant action with regard to the Company’s obligations.

The CEO is responsible for:

a) ensuring efforts are made to investigate and remediate the risk of modern slavery in the business and/or supply chains, and

b) ensuring that basic labour standards are met, and whether leaders are financially incentivised and resourced to do so.

These responsibilities are delegated operationally to relevant functional Senior Managers.

Change control

Effective date: 1st October 2020

Review date: 1st September 2021

Owner: CEO