This policy is intended to demonstrate the ongoing commitment of Conduit Holdings Limited and its subsidiaries (“Conduit”) to uphold human rights and mitigate the risk of slavery and human trafficking within its organisation and wider supply chains. While the UK’s Modern Slavery Act 2015 (‘the Act’) does not apply to Conduit as a Bermuda-based group, Conduit has chosen to conduct itself as if the Act applied to its operations.

About Conduit

Conduit is the holding company of Conduit Reinsurance Limited which is a Bermuda based multi-line reinsurance business, with a global reach. Conduit has over 60 employees.

Our policy

At Conduit, we recognise that our people are fundamental to our success and the development of a positive and productive corporate culture. Conduit seeks to be a responsible company and to operate for the benefit of all our identified stakeholders. We are dedicated to respecting, supporting, and protecting human and labour rights throughout our organisation and supply chain. Our approach is guided by our values and the principles set out in international standards, including the United Nations Universal Declaration of Human Rights.

It is deeply troubling that people suffer from the impact of slavery, human trafficking and child labour around the world. We recognise our responsibility to be alert to the risks, however small, in our business and supply chain and take all reasonable measures to identify and avoid such risks.

Conduit supports the right to collective bargaining, equal remuneration, and freedom of association. We are committed to ensuring human rights, in accordance with internationally accepted standards, are adhered to within our business and supply chain.

We are an equal opportunities employer and as such, Conduit does not tolerate discrimination, bullying or harassment of any kind in any aspect of employment. Conduit fully supports and celebrates differences, which could include but are not limited to race, age, gender, gender identity, sexual orientation, disability, beliefs, background (except as may be pertinent to the requirements of a role, such as educational qualifications or prior employment experience), socioeconomic group, family or marital status, or nationality.

Our business and supply chains

This policy applies to all employees, contractors, and representatives of Conduit, as well as our interactions with suppliers, business partners, and other stakeholders.

Conduit provides reinsurance solutions to other insurance companies. Our business is conducted in highly developed and regulated markets and leverage a highly skilled workforce and technology. Our suppliers are predominantly other financial services companies (such as brokers) professional service providers (such as accountants and actuaries) and technology firms (such as cloud computing providers and risk modelling companies). Local providers, such as office cleaners, are operating in a regulated Bermuda labour market with strict immigration controls.

Notwithstanding the low risk of exposure to modern slavery or human trafficking, we have policies which aim to reduce the risk of any connection to such activity being identified and reported.

Our applicable policies

Our internal policies, including a Code of Conduct and a set of agreed corporate values, set the tone for how we operate.

Conduit has a comprehensive set of policies and procedures aimed at bolstering governance and compliance. Conduit's code of conduct, whistleblowing policy, and other compliance policies and procedures, including those covering anti-bribery and corruption, anti-money laundering, anti-terrorism financing, anti-trust and anti-competitive practices, confidentiality of information, conflicts of interest, gifts and hospitality, discrimination, environment, health and safety are made available to staff via the Conduit intranet. Regular compliance training is provided. Conduit has contracted with an external independent specialist whistleblowing service provider to enable staff to report whistleblowing incidents, anonymously or otherwise, over the phone or in writing via online submission.

Compliance goals are set for all employees, and disciplinary action will be taken if employees violate the policy or fail to meet performance standards. At a minimum of annually, substantial elements of the Company’s compliance framework are subject to review to ensure they are designed and implemented appropriately, including its policies, adherence to regulatory standards and Codes of Conduct, along with the reporting of any material breaches.

Applicable policy highlights include:

  • Code of Conduct – a cohesive view of Conduit’s core values, commitments and policies to help staff make decisions and exercise behaviours consistent with Conduit’s approach.
  • Whistleblowing – a policy to ensure that all Conduit staff are confident that they can raise any matters of genuine concern without fear of reprisals, in the knowledge that they will be taken seriously and that the matters will be investigated appropriately and regarded as confidential.
  • Recruitment - a policy that sets out the approach adopted by Conduit to the recruitment and selection of employees to ensure fair, equitable and consistent recruitment processes when sourcing talent to add to the Conduit team.
  • Outsourcing and procurement – a policy that ensures every material supplier has an identified owner and is subject to review by the Outsourcing Oversight Committee. Due diligence requirements are in place that are intended to provide a holistic view of the companies we deal with, any risk exposures they may present, the markets they operate in, and the policies and procedures they have in place. Conduit will not collaborate with or support any suppliers if we become aware of slavery or human trafficking within their operations or supply chains, until such time as it is remediated.
  • Financial crime-related policies – various policies in place to address the risks associated with money laundering, terrorist financing, bribery and corruption, and sanctioned activities, companies and regions.
  • Investment guidelines - we seek to avoid certain activities, locations and industries where our view is that, on balance, supporting the activities conflicts with our aim to act responsibly. While our criteria remain under constant review, examples include limitations on for-profit-prisons, tobacco, controversial weapons and approximately 50 countries with an increased risk of human rights violations or poor human rights records.
  • Employee Handbook - the handbook includes policies on the following (where applicable, this applies to all employees, representatives, and contractors when they act on behalf of Conduit): Conduct and Disciplinary Procedures, Discrimination, Harassment and Bullying, Diversity and Inclusion, Flexible Working, Learning and Development, Resignation, Sexual Harassment, Working Hours, Workspace Safety and Health, to name a few.

Conclusion

While the risk is low, we are committed to upholding human rights and taking all reasonable steps to prevent modern slavery and human trafficking in our business and supply chain, in accordance with internationally recognised standards.