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. It sets out the steps taken by Resolution Life Group Services Ltd (“RLGS”) to help ensure that our business and supply chains are slavery free. 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.
RLGS is committed to actioning practices that combat slavery and human trafficking. We do not tolerate 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 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. The Resolution Life Group (the “Group”) 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, various Resolution entities have committed over US$15 billion of equity in the acquisition, reinsurance, consolidation and management of 28 life insurance companies. Together these companies have served the needs of over 10 million policyholders while managing over US$320 billion of assets.
The Resolution Life Group has operations in Bermuda, London, 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. fund administration, 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, our 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
In addition to this statement, all Resolution Life employees are required to meet the standards set within the Resolution Life Group Code of Conduct. Further, we have an Environmental Social Governance (ESG) 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.
Employees are advised to report any suspected act of human trafficking or modern slavery, on a confidential basis, to General Counsel. A Whistleblowing Policy is in place which protects disclosures.
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.
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 ESG Policy which also has a corporate responsibility section.
8. Our effectiveness in combating slavery and human trafficking
On an annual basis, we review and update our:
- 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.
This Statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and has been approved by the Board of RLGS.
Resolution Life Services Limited
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.