Modern Slavery Statement
Who we are and what we do
This statement is made under Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.
This statement applies to Many Group Ltd (referred to in this statement as the ‘Company’) and its subsidiaries (the Company and its subsidiaries referred to collectively in this statement as the ‘Group’ or ‘we’ and individually as a ‘group company’). The information included in this statement refers to the financial year from 1 April 2020 to 31 March 2021.
We are a high growth InsurTech and we deliver high quality pet insurance and pet wellness with award-winning levels of service. We sell through our own websites, aggregator websites and distribution partners.
How we define modern slavery
We consider that modern slavery encompasses any of the following:
- Human trafficking.
- Forced work, through mental or physical threat.
- Being owned or controlled by an employer through mental or physical abuse or the threat of abuse.
- Being dehumanised, treated as a commodity or being bought or sold as property.
- Being physically constrained or having restrictions placed on freedom of movement.
Our policy on and exposure to modern slavery
We do not support or condone modern slavery in any form. It is wrong in every respect and runs completely contrary to the operation of ethical business and specifically contrary to our values, which are:
- Show you care.
- Dare to think big.
- Do the right thing.
- Be tenacious and be fast.
- Work in partnership.
No group company has knowingly entered into business with anyone else, in the United Kingdom or abroad, which to our knowledge supports or has involved itself in slavery, human trafficking, servitude or forced or compulsory labour.
Based on the sectors and jurisdictions that we operate in, the digital nature of our business, our working environment, our recruitment process and our values, we believe that our exposure to modern slavery and human trafficking is limited.
Our group structure
The Company is the holding company of the Group and has a formally constituted Board with a non-executive Chairman, five non-executive directors and three executive directors.
The senior leadership team of the Group is responsible for operational management of the business and the implementation of this policy in their own areas.
Our UK operations are run principally through group company Bought By Many Ltd in Haywards Heath (Sussex), Birmingham and London, regulated by the FCA and trading under the brand Bought By Many for our cat and dog insurance. We also trade in the UK as Exotic Direct for our exotic pets business.
We operate our pet insurance business in Sweden under the brand ManyPets through a branch of Bought By Many Ltd, which is based in Stockholm and is regulated by the Swedish FSA.
We operate our pet insurance and pet wellness business in the United States under the brand ManyPets through US group company ManyPets Inc. which is based in Atlanta and New York. As at the date of this statement, we are regulated to carry out our business of insurance producer and adjuster in 50 States and the District of Columbia.
How we plan to mitigate the risks of and avoid modern slavery in our supply chain
We have recently introduced a Procurement and Third Party Arrangements Policy, which forms part of our compliance procedures, to be followed by all staff, which seeks to ensure that effective due diligence and checks are undertaken on potential counterparties before engaging with them.
We have decided to undertake a contract and supplier review process to assist in understanding both the risk and the measures we need to take to avoid modern slavery. We have broken down our supplier contracts into three categories:
- Material Outsourcing Third-Party Arrangements for services vital to the business which we could conduct internally but have elected to outsource externally.
- Critical Supplier Third-Party Arrangements where an external party provides services which are also vital to the business and which we are not able to provide internally.
- Ancillary Supplier Third-Party Arrangements which do not fall into either of the above categories and are regarded as lower risk.
Future Material Outsourcing and Critical Supplier contracts
Before we enter into future Material Outsourcing or Critical Supplier Third-Party contracts, staff are now instructed to do the following:
carry out a rigid due diligence process which includes confirmation from the proposed supplier that it:
- has not engaged in any modern slavery or human trafficking;
- has not been the subject of any investigation into allegations of modern slavery or human trafficking;
- has implemented modern slavery procedures in its own supply chain; and
- has provided us with copies of the procedures it has in place.
include provisions in each of these contracts:
- requiring the supplier to comply with anti-slavery and human trafficking laws; and
- giving us the right to terminate if a supplier is in breach of these; and
- review each contract at least annually to ensure ongoing compliance, which review shall include an annual attestation to the matters set out above
Existing Material Outsourcing and Critical Supplier contracts
Over the next 12 months we plan to identify existing contracts which fall into either category, send a questionnaire on modern slavery to each relevant supplier and, where appropriate, ask for the inclusion of specific modern slavery provisions and exchange of information about their own procedures.
Over the next two years we plan to look at developing a programme, as a matter of best practice taking into account the resources available, to mitigate and avoid the risks of modern slavery in our supply chain under contracts which are not Material Outsourcing or Critical Supplier arrangements.
We do not plan to review existing supplier contracts which are not Material Outsourcing or Critical Supplier arrangements as we regard these as low risk for the purposes of exposure to modern slavery, taking into account the suppliers we deal with under these contracts and the countries in which they operate.
How we plan to avoid modern slavery in our recruitment
We avoid modern slavery in our direct recruitment by paying a fair, externally benchmarked wage for all roles. Our recruitment process involves a minimum of two stage interviews which are conducted face-to-face using digital technology. In addition, for all roles, the candidate’s previous five years’ work or study history is verified and right to work checks are carried out.
All colleagues are issued with contracts of employment in compliance with applicable laws and industry standards on employee wages, benefits, working hours and minimum age are followed in all countries where we operate, without any unauthorised deductions.
All recruitment suppliers will be made aware of our stance on modern slavery as detailed in this document and will be subject to our enhanced modern slavery checks identified above.
Training for our staff
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide the following training to our staff:
Using our learning platform, we intend to ask all colleagues to complete annually a training course that includes a gap analysis exercise to identify weaknesses in current understanding of modern slavery. The objective of the course is to enable all staff to:
- define modern slavery;
- identify different forms of modern slavery;
- recognise key pieces of legislation and approaches to deal with modern slavery; and
- demonstrate an improved understanding of Modern Slavery - An Introduction.
In addition, it is planned that speakers will be invited to deliver awareness talks to staff on modern slavery and this will be included in our Diversity, Equality and Inclusion calendar.
KPI metrics to measure progress
We use the following key performance indicators (KPIs) to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:
Annual review to confirm that for all our future Material Outsourcing and Critical Supplier Third-Party contracts:
- Due diligence as referred to above has been carried out to satisfy ourselves that from a modern slavery point of view we can continue to engage with the suppliers.
- Appropriate anti-slavery clauses have been included in each contract.
- 100% of colleagues have verified right to work.
- The training course is assessed via questions with a baseline pass rate of 80%. This is reportable via the learning platform.
- CPD records include reflection on training completed by named individuals that will evidence their awareness of and participation in the training.
- We assess and take seriously all incidents of modern slavery which are included in whistleblowing reports we receive from staff.
Policies and procedures
We also operate the following policies and procedures to support our policy on Modern Slavery:
- Whistleblowing Policy: published to encourage employees to report concerns about individual or company practices that could promote or support modern slavery.
- Equal Opportunity and Dignity at Work Policy: a zero tolerance approach to harassment, bullying and discrimination based on protected characteristics.
- Recruitment standards: well-defined selection processes based on job requirements.
- Right to Work verification: carried out prior to point of hire for all employee appointments.
- Employment contracts: fair terms and benefits; no use of zero hours contracts.
- Employment checks: appropriate checks to comply with financial services regulations; employment references for all roles.
- Pay determination: market benchmarking to establish fair pay according to role; all pay is above the minimum legal wage.
It is intended that a committee will carry out a quarterly review of modern slavery compliance and report to the Board.
Approved by the board of Many Group Ltd on 24 September 2021 and by the boards of Bought By Many Ltd and
Brooks Braithwaite (Sussex) Limited on 27 September 2021
Guy Farley, CTO, Co-Founder and Director of each company
Dated 28 September 2021