1. Introduction

This statement has been published in accordance with the Modern Slavery Act 2015 (the “Act”) and in line with the UK government Home Office statutory guidance. This statement applies to Resolution Life Group Services Ltd. (“RLGS”). This statement sets out the steps taken by RLGS during the year ending 31 December 2023 to prevent modern slavery and human trafficking occurring in its business and supply chains. The statement will be subject to an annual review each year. We will uphold all laws relevant to countering money laundering and terrorist financing in all the jurisdictions in which we operate.

2. Statement

RLGS is committed to actioning practices that combat modern slavery and human trafficking. We do not tolerate modern slavery or human trafficking within our business or within our supply chain. Our third-party service provider selection and governance policies and processes are designed to help ensure we deal with ethical, credible suppliers who share similar values.

3. Our Business and Organisational Structure

RLGS

RLGS is part of a Bermuda-based life insurance group that acquires, manages and consolidates in-force life insurance companies and portfolios in mature markets globally. Resolution Life seeks to be the global buyer of choice for life insurers who have complex and at-scale restructuring requirements.

History: The Resolution Life Group

Since 2003 to date, Resolution Life and previous vehicles founded by Clive Cowdery under the Resolution brand have deployed c. US$18 billion of equity in the acquisition, reinsurance, consolidation and management of life insurance companies. Together these companies have acquired the proud history of over 180 life insurers, served the needs of c.14 million policyholders while managing over US$377 billion of assets.

Resolution Life has operations in Bermuda, the United States, New Zealand and Australia. Resolution Life provides a safe and reliable partner for insurers as they restructure by:

  • Focusing on existing customers, rather than seeking expansion by new sales
  • Delivering policyholder benefits in a secure, well capitalised environment
  • Returning capital over time to our institutional investors in the form of a steady dividend yield

4. Outsourcing, ‘Supply Chains’ and use of third parties

RLGS operates in a business environment that benefits from the use of expert third parties and outsourcing arrangements (e.g. payroll, IT technical support). We prefer to deal with market leading suppliers and have procurement processes in place to source these services, including control oversight where we have outsourced certain functions and services. We have a zero-tolerance policy on slavery and human trafficking and expect that those in our supply chain comply with RLGS’s principles and core values.

We believe that the nature of our business activities results in a lower risk that a third-party service provider has involved slavery or human trafficking. That is, as an asset manager and insurance firm, the Resolution Life Group does not have extensive or distant ‘supply chains’, nor do we manufacture goods. Our largest acquired third-party services are from professional firms (for example, accounting, legal and actuarial firms); we also buy data, IT and other standard corporate third-party services and deal almost exclusively with large, well established, ‘blue chip’ companies (e.g. Oracle, Bloomberg).

5. Our policies and procedures applicable to slavery and human trafficking

All Resolution Life employees are required to meet the standards set within the Resolution Life Group Code of Conduct; ensuring employees make responsible decisions and achieve results using the highest ethical standards.
Further, we have a Sustainability Policy which reflects our commitment to:

  • Act ethically and with integrity in all our business relationships and,
  • Implement and enforce effective controls to mitigate the risk of slavery and human trafficking taking place anywhere in our supply chains.

The Principles for Responsible Investment is a United Nations-supported initiative which promotes sustainability being incorporated into investment decisions, ownership and asset management. On 22 September 2022, Resolution Life became a signatory to the UNPRI, demonstrating the Resolution Life Group’s commitment to responsible investing.

Employees are advised to report any suspected act of human trafficking or modern slavery, on a confidential basis, to Group General Counsel. A Whistleblowing Policy is in place which protects disclosures.

RLGS also has an Outsourcing and Third-Party Policy which recognises the need to conduct third party management activity in an ethical and socially responsible fashion.

Resolution Life Group further has a Responsible Investment Policy which establishes the principles and minimum standards for responsible investment within the Resolution Life Group and the framework and controls for managing any associated risks. The Responsible Investment Policy lists modern slavery and human rights as a strategic priority when investing.

6. Due diligence processes in relation to slavery and human trafficking

Our third-party procurement process follows a defined due diligence/RFP process for any significant service providers. This process includes assessing the potential financial, legal and regulatory exposures of the business relationship. It also gives insight into the third party’s structure, operations, culture, human resources, supplier and customer relationships, competitive positioning and future outlook. Our processes are intended to:

  • Identify and assess potential risk areas in our ‘critical’ or essential supply chains (those supply chains critical to our day-to-day operations)
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains
  • Monitor potential risk areas in our supply chains and
  • Protect whistle-blowers.

A governance framework is in place for the efficient management of our suppliers and this framework is reviewed on an annual basis.

Our supply chain management process incorporates various departments within the Group including the Transformation/Operations team, the Legal and Compliance team, and HR.

7. Training

Resolution Life Group’s Code of Conduct is based on practicing high ethical, legal and professional standards. Our annual Code of Conduct training is mandatory for all staff and includes content around ethical conduct, including the promotion of basic human rights and respect for others in the workplace. On an annual basis, we provide training on our sustainability activities and Policy which also has a corporate responsibility section.

8. Our effectiveness in combating slavery and human trafficking

On an annual basis, we review the effectiveness of our approach to track modern slavery by evaluating and updating the following:

  • Internal Human Resource policies and processes
  • Internal training and support materials (including our Code of Conduct) and
  • Procurement and governance processes that oversee our supply chain.

Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our business and supply chains, we intend to continue to develop and improve our approach to respecting human rights and preventing modern slavery.

This Statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and has been approved by the Board of RLGS on 12 April 2024.

Megan Beer
RLGS Director and Group Chief Operating Officer

May 2024

This statement applies to the following Resolution Life Group companies in the UK: Resolution Life Group Services Ltd, Resolution Operations LLP, and Resolution Brands Ltd.