The London P&I Club’s Modern Slavery Statement
This Statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes The London P&I Club’s Modern Slavery Statement and is for the financial year end 20 February 2018.
Organisational structure, the Club’s business and supply chains
The Club is a mutual P&I Club providing P&I, War Risks and FD&D cover to ship-owners and charterers worldwide. The Club provides claims handling and advisory services to its policyholders from its London, Piraeus and Hong Kong Offices, through the Managers (A Bilbrough & Co. Ltd) and a global network of correspondents.
The Club’s supply chains include the supply of services, which encompass dealings with professional services providers such as the Managers, correspondents, auditors, lawyers, loss adjustors, and surveyors.
The Club’s policies in relation to modern slavery and human trafficking
The Club has a zero tolerance policy in respect of slavery and human trafficking and is committed to ensuring that there is no modern slavery or human trafficking in any part of its business, and where possible, in the Club or its Managers’ suppliers.
The Club mitigates its modern slavery or human trafficking risks through its policies and procedures relating to:
• Employment of staff and directors • Prevention of bribery and corruption
• Compliance • Whistleblowing
• Outsourcing • Claims handling
• Risk management
The Club only deals with professional firms, does not act as a manufacturer or retailer of physical goods and has no supply chain in relation to such activities. Non-professional services such as facilities management, in-house catering and cleaning services are provided to the Club’s Managers in their UK, Greece and Hong Kong offices. The Managers are required to comply with the policies above. There is therefore minimal risk that the Club, or the professional firms which support its business activities are involved in, or complicit in, slavery and human trafficking.
The Club’s due diligence and risk management processes in relation to slavery and human trafficking
The Club’s Outsourcing Policy provides guidance on the assessment of new third party service providers and details the due diligence processes to be performed prior to appointment and the requirement for a written agreement to be in place. Where a risk has been identified, the written agreement will be enhanced to include explicit terms to cover zero tolerance of modern slavery and human trafficking.
Training provided to Directors and staff
To maintain awareness and understanding of the Club’s obligations in accordance with the Modern Slavery Act, all staff and Directors of the Club’s Managers have been made aware of this Statement. Additionally, the Club’s Whistleblowing Policy enables them to report any concerns they might have with the Club’s compliance with applicable laws and ethical standards. Directors and staff of the Club’s Managers are periodically required to undertake on-line training modules in respect of its policies. Further training is planned for 2019 which will include modern slavery and human trafficking. The Club’s Directors review and approve this Statement annually providing them with an opportunity to challenge the Managers on its compliance with the zero tolerance policy above.
Signed by Anthony Jones, Director
8 November 2018.