This statement is published pursuant to section 54(1) of the Modern Slavery Act 2015 and is the first by Vita Group ("Vita"). Our aim is to know more and as much as possible about our supply chains, who is involved in the provision of our goods and services and about the working conditions at all levels of the supply chain.
Subsequent annual statements will outline the steps Vita has taken during 2020 to help ensure that slavery, servitude, forced or compulsory labour and human trafficking is not taking place in its supply chain or any other part of its business or subsidiaries.
Our Business and Supply Chains
We are a leading advice-based Protection Insurance Intermediary based in the UK and employ 20 people. All colleagues are paid at least the Living Wage. We offer our advice services direct to customers and via Introducer Partners both online and by telephone from our UK based offices.
Our supply chain is divided into multiple categories which are built around supporting our core functions and include:
- Protection Insurance Providers
- Wills processing
- Legal services
- IT & Telephony Services - Maintaining Hardware & Software, User support
- Facilities Management & Property
- HR support services
- Recruitment services
- Professional Services
Policies: Vita's Senior Management Team will seek to jointly develop policies by assessing our business activity and supply chain exposure, which will then be reviewed and approved by the Board.
Risk Assessments: These will need to be developed through consideration of our business activity, markets and region that we operate within.
Investigations: Any known, or suspected, instances of slavery or human trafficking are investigated through our Compliance and Risk functions.
Due Diligence: We respect and acknowledge that modern slavery is a global issue and that no economy, industry or sector is exempt. Vita are fully committed to complying with the objectives of the Act, and as a financial services organisation, we consider the risk of modern slavery existing within our business to be very low.
Vita aim to create and operate appropriate measures to help mitigate against any such risks to ensure that we remain vigilant, through activities such as completing due diligence with our partners and suppliers. Responses received from the due diligence process will be reviewed and information of concern is to be investigated further.
We are committed to ensuring that our people throughout the business, particularly those that form our Senior Management Team, have the knowledge and understanding required in order to properly discharge the legal and ethical responsibilities we must comply with.
Training: To better understand and respond to potential slavery and human trafficking risks our employees will be given awareness training, and our suppliers will also made aware of our expectations. We aim to design training and then carry it out in January of each year.
Vita will develop and operate the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.
Whistleblowing Policy: The organisation will encourage all its workers, clients and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, clients or others who have concerns can raise their concerns with their line manager in the first instance. If this channel is not appropriate for any reason, then disclosures should be made to Compliance Director of our Principal firm, Mortgage Advice Bureau. All persons affected have access to Public Concern at Work (an independent whistleblowing charity) via their helpline.
Employee Handbook: Vita's employee handbook makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
Supplier Code of Conduct: We are committed to ensuring that its suppliers adhere to the highest standards of ethics. As of 2021, suppliers will be requested to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Serious violations of Vita's 'Supplier Code of Conduct' could lead to the termination of the business relationship.
Recruitment/Agency Workers Policy: Vita uses only specified, reputable employment agencies to source labour and would always verify the practices of any new agency before accepting workers (although in general we do not use agency staff due to the nature of our regulated business). We use questionnaires and a full employee verification process to ensure that risks of slavery and human trafficking are addressed in relation to agency workers and all new hires.
Moving forward, Vita will undertake due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The aim is to implement the following due diligence and reviews by the end of 2020, ready to operate from 2021:
- Mapping the supply chain broadly to assess product or geographical risks of modern slavery and human trafficking.
- Evaluating the modern slavery and human trafficking risks of each new supplier;
- Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.
- Conducting supplier audits or assessments through the organisation's own staff or third-party auditor, which have a greater degree of focus on slavery and human trafficking where general risks are identified.
- Creating an annual risk profile for each supplier.
- Taking steps to improve substandard suppliers' practices, including providing advice to suppliers, sometimes through a third-party auditor, and requiring them to implement action plans.
- Asking suppliers to confirm their compliance with our standards and requirements in order to provide products or services to our business; and
- Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
As this is Vita's first Modern Slavery Statement, we will raise awareness of modern slavery issues by distributing flyers to staff, putting up posters across the premises and circulating a series of emails to staff.
The booklet, poster and emails explain to staff:
- The basic principles of the Modern Slavery Act 2015.
- How employers can identify and prevent slavery and human trafficking.
- What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation.
- What external help is available, for example through the Modern Slavery Helpline.
This statement has been approved by the Vita Group's Board of Directors on 30th March 2020 and will be reviewed annually, no later than 6 months after our Financial Year-End.
Co-Founder & Director
Financial Year-End: 31st December
Statement Updated: 30th March 220