SLAVERY AND HUMAN TRAFFICKING STATEMENT for the year ended 31 December 2021
Amended and Restated by the Board: May 5, 2022
This statement is made on behalf of Enstar Group Limited and each of its subsidiary companies including, but not limited to, the companies based or operating in the United Kingdom (“Enstar”, “we” or “our”).
This statement is made pursuant to section 54(1) of the UK’s Modern Slavery Act of 2015 (“the Act”) and constitutes Enstar’s slavery and human trafficking statement for the financial year ended December 31, 2021. It is reviewed annually. This statement sets out the steps Enstar has taken to ensure that Slavery and Human Trafficking (as defined in the Act) are not taking place in our supply chains or in any part of our business.
The Board believes Enstar’s business model and supply chain represents a low risk of exposure to slavery and human trafficking. We embody the highest professional standards and comply with the laws and regulations applicable to our business. We expect the same high standards from those parties with whom we engage.
Enstar is a leading global insurance group that delivers innovative insurance solutions through our network of group companies. Our diversified portfolio of companies is positioned across the world’s major insurance hubs spanning Bermuda, the U.S., the United Kingdom, Continental Europe, and Australia.
The core of Enstar’s ongoing business is the acquisition and management of legacy insurance risk. We assume ceased portfolios and entire companies, allowing our clients to release operating capital, management time, and other resources for better use in their ongoing activities. Our primary focus is property/casualty companies and portfolios in run-off.
Through various subsidiary companies, Enstar lends its expertise in risks and liabilities through third-party consulting. Our services to the re/insurance industry range from full-service, incentive-based run-off management to client-specific solutions such as claims inspection and validation, reinsurance asset collection, syndicate management, and IT consulting.
We endeavour to ensure that there is no slavery or human trafficking, as defined in the Act, in our supply chains or in any part of our business. We aim to implement and enforce effective and proportionate systems and controls to ensure slavery and human trafficking are not accepted anywhere in our supply chains.
The Enstar Group Code of Conduct applies to all Enstar subsidiaries, including all UK-based subsidiaries, and details the business principles and ethics which all employees and the business adhere to. From 2021, material vendors and contracting parties have been expected to comply with a Vendor Code of Conduct, which sets equivalent standards of conduct by our vendors.
Enstar does not accept any breach of human rights including slavery and human trafficking. The Code of Conduct (“the Code”) is board-approved and this statement is aligned with the principles set out in the Code. As a business we raise awareness with our staff to be alert to the risk, however remote, that we might become party to either slavery or human trafficking in our business and in the wider supply chain. Staff are encouraged to report concerns to management, which may be made anonymously through a Whistleblowing facility, which would be evaluated and acted upon appropriately.
CONSIDERING OUR SUPPLY CHAINS
The Enstar Group offers insurance and reinsurance legacy portfolio solutions, focused on the administration and handling of claims for legacy (run-off) underwriting business, which is a regulated financial services activity. The underwriting business managed by Enstar is acquired from other regulated insurance companies, which originally sourced this business through a range of worldwide brokers. We continue to deal with those brokers for the administration of insurance contracts for which Enstar companies are responsible for the payment of claims.
These brokers derive their income from the client (the (re)insured) and as such we do not consider brokers to be a part of our supply chain in this context. That said, we only deal with reputable firms who are regulated by a local insurance regulator. This regulation will typically include an assessment of their fitness and propriety.
Some business, particularly that formerly underwritten by the StarStone sub-group, was underwritten through Coverholders and other third parties located globally (most significantly in the UK, EU, US, Canada and Australia). These firms act as the agents of the insurer. As part of the due diligence performed when taking on a new Coverholder, an assessment was made of the likely exposure to slavery and human trafficking in the countries in which they operate and assurance sought where relevant.
For certain activities we retain outsourced services providers to administer our affairs (e.g. claims handling, loss adjusting, policy processing) or provide outsourced support functions (e.g. investment management). Our Procurement, Outsourcing and Third-Party Management Policy recognises the need for an assessment of the risk of exposure to possible slavery or human trafficking and we require commentary on how this risk is mitigated as part of the due diligence process prior to approval or renewal of the material service provider.
We do use business services suppliers to provide maintenance and support for our office operations, such as office equipment, computer supplies, and travel agents. We do not act as a producer, manufacturer or retailer of physical goods and have no supply chain for possible slavery or human trafficking matters.
A commitment to maintain high standards of compliance with human rights is expected from all employees, contractors and vendors, and form the basis of a Vendor Code of Conduct implemented in 2021. This will clearly articulate that the use of child labour or forced labour by Enstar’s vendors is strictly prohibited. Vendors and other third parties with whom Enstar conducts business are required to agree to follow Enstar’s Vendor Code of Conduct,or attest to operating to at least an equivalent Code of Conduct. Third parties will be held accountable for their commitment to human rights, including the prevention of human trafficking and slavery in their supply chains.
EMPLOYEES
All Directors have been briefed on the subject. A training programme is in place to promote awareness of potential signs of human trafficking and modern slavery. Additional training will be provided to management and staff with direct responsibility for supply chain management. We also ensure staff are aware through the provision of this statement to all staff on joining, and annually thereafter following approval by the Board.
Our Whistleblowing policy is published to all employees with a summary displayed prominently in our offices and on our intranet home page. This encourages employees to raise any genuine concerns about any wrongdoing or breaches of law, including slavery and human trafficking, with the facility to do anonymously.
Our Code of Conduct, which all employees are required to read and acknowledge annually, also contains provisions regarding Enstar’s expectations regarding human rights and non-tolerance of human trafficking and modern slavery.
We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
To date, we have not identified any instances of human trafficking or slavery within Enstar or firms with which we conduct business. We continue to remain vigilant, enhancing our procedures to monitor suppliers and articulate our expectations regarding human rights, as well as providing training to staff.
As Amended and Restated by the Board
May 5, 2022
