This statement is made by Health-On-Line Company UK Limited(the “Company”), pursuant to Section 54 of the UK Modern Slavery Act 2015 (the “MSA”). It sets out the steps that the Company has taken during the 2016 financial year to combat and prevent all forms of modern slavery and human trafficking in their businesses and supply chains. This statement covers the Company’s direct operations and supply chains.
The Company is a member of the AXA Group of companies. The AXA Group has a long history of adhering to and promoting strong professional ethics and is committed to conducting its business according to the highest standards of honesty and fairness. This commitment to observing such ethical standards is designed not only to ensure compliance with applicable laws and regulations in the various jurisdictions where AXA operates but also to earning and keeping the continued trust of its clients, shareholders, personnel and business partners. AXA believes that its success and reputation is not only dependant on the quality of its products and the services provided to its clients, but also on the way it does business. This includes a strong commitment to human rights and therefore, it welcomes the transparency promoted by the MSA.
1. Company structure and business
The Company is part of the AXA Group, a worldwide leader in financial services. AXA UK plc and its subsidiaries (and their associated companies, together “the Companies”) currently employ approximately 8500 employees in the UK. During the financial year 2016, AXA UK plc, through its subsidiaries (and their associated companies), specialised in:
- Insurance – AXA Insurance UK plc and its associated companies provide personal and commercial insurance products for home, motor and travel customers, direct to the customer as well as servicing the SME, mid-market and corporate sectors. They also offer their products via brokers, aggregators and in conjunction with corporate and retail partners.
- Healthcare – AXA PPP Healthcare Limited and its associated companies, including AXA PPP Healthcare Group Limited and Health-On-Line UK Limited, provide private medical insurance cover direct to the customer as well as to the SME, mid-market and large corporate sectors, via agents, brokers, aggregators and in conjunction with corporate partners. They also offer a range of health and well-being services to the corporate sector.
2. Companies’ supply chains
The Companies are major purchasers of products and services for the purpose of their internal operations. Their supply chains are the networks of third party entities directly or indirectly supporting their organisations in the production, distribution and ongoing communication of their products and services to the end customer.
3. Engagements and policies in relation to modern slavery and human trafficking
The AXA Group is committed to respecting internationally recognized human rights principles as defined by the United Nations Universal Declaration of Human Rights, the core standards of the International Labour Organisation and the Guiding Principles for the implementation of the United Nations “Protect, Respect and Remedy” Framework (Ruggie Principles). The AXA Group is also committed to applying international general and sector-specific standards such as the UN Principles for Responsible Investment, the UN Principles for Sustainable Insurance and the UN Global Compact (“UN GC”). Since 2003, AXA adheres to the UN GC and has formally committed to promoting its ten guiding principles, including those on human rights (such as avoiding complicity in human rights abuses and supporting and respecting the protection of internationally proclaimed human rights) and labour standards (such as supporting the elimination of all forms of forced and compulsory labour and the effective abolition of child labour).
In addition, the AXA Group has put in place policies to support its commitment to ethical business practices across the organisation. These include:
- The AXA Group Human Rights Policy, whichaims to ensure that (i) the Group does not cause or contribute to adverse human rights impacts and (ii) such impacts are addressed when they occur. The policy also sets out AXA’s commitment to identify, prevent and/or mitigate adverse indirect human rights impacts that are linked to its operations or services, through its business relationships or projects it has invested in or insured.
- The AXA Group Compliance and Ethics Guide (the “Guide”), which establishes guiding principles and Group-wide policies designed to ensure that all AXA Group companies and their personnel have a common vision of the Group’s ethical standards (including the UN GC principles on human rights, labour standards, environment and anti-corruption) and operate in accordance with those standards. All AXA employees are encouraged to report promptly any practices, actions or conduct that they believe are inappropriate or inconsistent with any of the policies set out in the Guide through their local whistleblowing procedures. Senior officers of AXA entities are asked to submit an annual certification to confirm that they comply with all the provisions set out in the Guide.
The AXA Group Human Rights Policy, the Guide and the principles and standards mentioned above all apply to the Companies. The senior officers of the Companies all complied with the annual certification process in relation to the Guide in 2016 and were asked to ensure their teams were aware of the Guide and its contents. In addition, the Companies also adhere to the AXA UK Whistleblowing Policy, which details how employees can raise concerns where they believe there may be wrong-doing or improper conduct by senior managers, other employees, suppliers or contractors. This policy is overseen by the AXA UK Whistleblowers’ Champion, Peter Hazell, Non-Executive Director of AXA UK.
4. Management of the modern slavery and human trafficking risk in the Companies’ operations
AXA acknowledges its responsibility to respect human rights in its operations and conducts its business in compliance with applicable employment regulations in the jurisdictions in which it operates. The Guide sets out protections for AXA’s employees and their rights, in particular, it emphasises that:
- AXA is committed to upholding the right of freedom of association and collective bargaining, as well as maintaining constructive labour management relations in every country in which it does business, and to doing so with due respect for different national approaches to social dialogue;
- AXA respects the rights of its employees to enjoy just and favourable conditions of work, including health and safety protections, and is committed to providing adequate information and training on health and safety and wellbeing issues.
In addition, AXA promotes diversity and inclusion by prohibiting any form of discrimination between current, past or prospective staff on the basis of age, race, nationality, ethnic origin, gender, sexual orientation, religion, marital status or disability through its Diversity and Equal Opportunities Policy. Within AXA UK, there is a Diversity and Inclusion Board, headed by the Diversity and Inclusion Executive Sponsor and Leader, which is in charge of documenting the Companies’ diversity and inclusion plans. Such plans are to be submitted to the Group Human Resources annually with an assessment of the accomplishments, issues and needs arising.
5. Assessment of the Companies’ largest suppliers and due diligence process in relation to the Companies’ supply chains
The Companies ensure that they work with suppliers that meet the AXA standards with respect to ethics and corporate responsibility through a clearly documented process for supplier selection and contracting.
In accordance with such process, the Companies’ standard contractual terms with suppliers include specific reference to AXA’s corporate responsibility requirements, and suppliers are required to provide a formal commitment to uphold the core standards of the UN GC by signing AXA’s “Corporate Responsibility clause”. Notably, the suppliers agree to refrain from using, or accepting that their own suppliers and sub-contractors make use of, child labour (under 15 years old) or forced labour. The Company receives some goods and services under contracts entered by its affiliates and is itself in the process of including the Corporate Responsibility clause into its direct supply arrangements.
Detection of a direct or indirect violation by the supplier of the AXA corporate responsibility requirements will be discussed directly with the supplier with a view to establishing a mutually agreed and documented corrective action plan. Where any issue is not resolved satisfactorily, the Companies reserve the contractual right to end their relationship with the relevant supplier.
In addition, AXA UK plc’s and AXA Insurance UK plc’s respective procurement teams who may assist the Company in its own direct procurement activity seek to prevent or mitigate adverse human rights impact of certain of their suppliers by the use of an independent third party to assess a number of corporate responsibility topics, including child and forced labour. This process enables AXA UK plc and AXA Insurance UK plc to detect the supply chain corporate responsibility risks in respect of those suppliers.
6. Training and information available to staff
As at the date of this Statement, training has been provided to the AXA UK plc procurement team and one member of the AXA Insurance UK plc procurement team in relation to the process adopted by the independent third party assessor.
In the future, the Companies plan to roll-out an awareness training programme for procurement employees to give them a detailed knowledge of AXA’s corporate responsibility principles. This training programme will highlight the instrumental role of responsible procurement in order to ensure that AXA engages with responsible suppliers.
7. Further steps
We now, in collaboration with the other Companies, the Company intends to:
- Review and update the AXA UK Procurement Policy and Group Outsourcing Risk Policy (GORP) to specifically reference the current practices in operation to detect modern slavery and human trafficking within the Companies’ supply chains;
- Review and update the Guide at a local level to make specific reference to modern slavery and human trafficking, in order to improve awareness on modern slavery issues among the Companies’ employees and to ensure they know how to report any issues they identify.
- Develop specific guidance covering the process that will be deployed to detect modern slavery and human trafficking within the Companies’ supply chains in order to improve awareness on modern slavery issues among employees responsible for engaging and managing third party relationships.
The Company’s Board of Directors approved this statement on 14 June 2017, which constitutes the Companies’ joint slavery and human trafficking statement for the financial year ending 2016.
Managing Director of Health-On-Line Company UK Limited