Modern Slavery Statement 2019
This statement is published by Assicurazioni Generali S.p.A UK Branch (Generali, we, us, our) in accordance with the Modern Slavery Act 2015. This statement applies to our business practices during the 2019 calendar year, and shall continue to apply thereafter until we update it.
This statement will be reviewed each year as part of our work to continuously improve our efforts to ensure there is no modern slavery or human trafficking in our business or any part of our supply chains.
Introduction from Dario Pieralisi, UK Country Manager
We are committed to contributing to economic and social development based on respect for fundamental human rights - this is enshrined in our Group Code of Conduct. We promote this culture through our spheres of influence, in particular our employees, customers and suppliers.
We strive to manage the relationships with our suppliers in a responsible way - we oppose modern slavery and human trafficking in all of its forms, and we do not tolerate it in our supply chain.
Our structure in the UK
Generali has been operating in the UK for more than 50 years, meeting the insurance needs of clients through the expertise of our (approximately 260) employees.
Generali in the UK provides a full range of general and life insurance solutions for our clients. These include:
- life insurance products for UK employers
- international corporate health insurance for employers of globally mobile people in addition to international health insurance for individuals; and
- a full suite of commercial insurance products for our global clients.
Our supply chains
Our procurement is managed by the UK procurement team in accordance with the requirements of the Generali Group.
There are currently over 650 approved suppliers who provide a variety services and goods to us. The importance of these suppliers (who range in scale from single person organisations to large multi-national businesses) to our UK business is recognised.Generali partner with suppliers who share Generali’s standards with regard to modern slavery and human trafficking.
Contract terms and conditions are reviewed and approved by the UK legal team before the supplier’s details are added onto our UK procurement system (which is necessary before a purchase order can be issued to any supplier).
The UK procurement team continuously works to ensure the needs of the business are well supported by the suppliers we select. Every purchase requirement within the UK is processed by this team before an order is placed with the supplier.
Given the scale of Generali’s UK business and the type of services it purchases (as a financial services organisation) and the fact that most suppliers are EU based, the risk of modern slavery being present within our UK supply chains is regarded as being very low. Steps are still taken, however, to ensure the risk of modern slavery associated with any purchase is identified and the appropriate steps are taken.
Risk assessment of our supply chains
We have identified categories and services that may be of a higher risk of slavery, based on a calculated risk assessment.
Whenever we purchase a type of product which is identified as presenting a risk of involvement with slavery, the procurement team will contact the supplier to establish whether one of the countries identified as also presenting a risk from slavery is concerned with the production of the good or service in question.
Should it be the case that the good or service is of a type from a country identified to be at risk from slavery, appropriate steps will be taken, which will be documented. Such steps may involve (amongst others):
- contacting the supplier to obtain details of their policies and procedures ensuring that modern slavery is not involved in the production of the goods or services sold to Generali;
- sourcing the goods or services from another vendor whose supply does not present a risk of modern slavery; and
- changing the type of good or service purchased to one that does not present a risk of modern slavery.
Our approach to preventing slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or supply chains. We seek to achieve this by:
- maintaining systems and controls through the lifecycle of our dealings with suppliers to ensure that slavery and human trafficking are not taking place in our supply chains - a summary of these controls is provided in the paragraphs “Our supply chains” and “Risk assessment of our supply chains” above;
- stringently following our Group Code of Conduct, which requires us and our employees to act ethically in all business relationships; and
- protecting whistle blowers.
All of our employees are required to undertake training on our Group Code of Conduct, which is designed to embed a culture of ethical behaviour in our organisation.