Modern Slavery Statement

This statement on slavery and human trafficking is published on behalf of the CFC Underwriting Group and its subsidiaries (‘CFC’), this also includes Modus Underwriting Limited “Modus” for the 2017/2018 financial year, pursuant to s54 of the Modern Slavery Act 2015 (‘the Act’).

CFC and Modus are committed to conducting our business responsibly and ethically, including ensuring that our supply chains are free from slavery and human trafficking.

1. Our organisation structure

This statement covers the activities of the CFC Group, which is headquartered in London and has over 250 employees, all based in our London office.

2. Our supply chains and risk assessment

Whilst CFC sells its products and services worldwide, it does not make use of supply chains which are traditionally susceptible to an enhanced risk of slavery or human trafficking, such as factories, other entities involved in manufacturing, or business sectors which are reliant on a high degree of human labour.

Given the nature of CFC’s business, the risk of modern slavery in our supply chains is considered low. However, we remain vigilant to this risk, and have in place a number of policies and procedures to ensure we do not knowingly do business with a company involved in any form of modern slavery or human trafficking.

3. Our Policies

As part of our commitment to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business, we maintain policies and procedures to support this commitment including:

• Outsourcing Policy: setting out our approach to outsourcing, as well as the due diligence which must be undertaken before CFC outsources any aspect of its business to a third party;
• Whistleblowing Policy: setting out the manner in which our staff and business partners can report any concerns relating to the activities of any CFC Group company or anyone involved in its supply chains, including circumstances which may give rise to a risk of human trafficking or slavery;
• Recruitment and Remuneration Policies: setting out the rights in which all our staff enjoy, including fair and reasonable wages, the right to a safe working environment, and appropriate holidays and provisions for sickness.

4. Next steps

CFC continuously reviews its risks in relation to modern slavery and human trafficking, both as an employer and as a purchaser of outsourced services, to identify measures we can take as a business to prevent modern slavery occurring in our business and supply chain.

5. Annual review

The Board of CFC will review this statement annually.