This policy is intended to demonstrate Conduit Re’s ongoing commitment to mitigating the risk of slavery and human trafficking within its organisation and wider supply chains. While the UK’s Modern Slavery Act 2015 (‘the Act’) only applies to companies in England and Wales, Conduit Re chooses to apply the same standard across its entire operations.
About Conduit Re
Conduit Re is a pure play reinsurance business, based in Bermuda. It has over 50 employees in Bermuda and two, focused primarily on investor relations, in the UK.
Conduit Reinsurance Limited is the main operating company of the Group and is domiciled in Bermuda along with Conduit Holdings Limited and Conduit Services Limited. Conduit Reinsurance Services Limited is domiciled in the UK.
Conduit Re seeks to be a responsible company and to operate for the benefit of all our identified stakeholders. Conduit Re has zero tolerance to slavery and human trafficking and is committed to ensuring our practices combat slavery and human trafficking within our business and supply chain by taking all reasonable steps necessary. We recognise our responsibility to be alert to the risks, however small, in our business and supply chain.
Our business and supply chains
Conduit Re provides reinsurance solutions to other insurance companies. Our operations are 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 highly 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. These are made available to all staff. Applicable highlights include:
- Code of Conduct – a cohesive view of Conduit Re’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 Re 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.
- 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.
Beyond our policies we also provide staff with training in relation to these areas.
While the risk is low, we are committed to taking all reasonable steps to prevent modern slavery and human trafficking in our business and supply chain.