This policy sets out our commitment to modern slavery and human trafficking relating to section 54 of the Modern Slavery Act 2015 (MSA) and reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere within our business.
Who this policy applies to –
This policy applies to all persons working for or on behalf of Marsh Finance LTD, in any capacity, including employees, directors, officers, agency workers, contractors, consultants and any other third-party representative. Marsh Finance LTD also expects all who have, or seek to have, a business relationship with our organisation to familiarise themselves with this policy and to act in a way that is consistent with its values. Marsh Finance LTD will only do business with organisations who fully comply with this policy, or those who are taking verifiable steps towards compliance.
Defining what Modern Slavery is
Modern slavery can take many forms. The Modern Slavery Act (MSA) 2015 covers four key criminal activities:
1) Slavery: where ownership is exercised over an individual
2) Servitude: involves the obligation to provide service imposed by coercion
3) Forced and compulsory labour: all work or service, not voluntarily performed, which is obtained from an individual under the threat of force or penalty
4) Human trafficking: involves arranging or facilitating the travel of another with a view to exploiting them.
Other forms of modern slavery, which will not be tolerated but are not specifically referenced in the MSA, include, but are not limited to:
Child labour: whilst not always illegal in the jurisdiction in which it takes place, child labour involves the employment of children that is exploitative or is likely to be hazardous to or interfere with a child’s education, health (including mental health), physical wellbeing or social development.
All forms of modern slavery have in common, the deprivation of a person’s liberty by another in order to exploit them for commercial or personal gain and amount to a violation of an individual’s fundamental human rights.
Tackling modern slavery requires colleagues to play an important part and remain vigilant to the risk in all aspect of our business and any business relationships that we have in place.
To underpin the commitments laid out in this policy, our business aims to implement/has implemented the following measures:
- Marsh Finance LTD will conduct/has conducted risk assessments to determine which parts of the business and which supply chains are most at risk from modern slavery. This is to ensure efforts can be focused on the areas that are most ‘ at risk ’.
- Where appropriate and as informed by the risk assessment, Marsh Finance LTD will engage directly with new suppliers in respect of the Anti-Slavery Policy in order to gain a proper understanding of the measures they have in place to ensure that modern slavery is not occurring within their own businesses
- Contractual documentation will/does incorporate specific prohibition against slavery or servitude, the use of forced, compulsory or trafficked labour, and the use of child labour in line with this policy.
- We also make provision for our contracted suppliers to hold their own suppliers to the same standards and reserve the right to terminate any contractual arrangement if there is a breach of this policy.