Modern Slavery & Human Trafficking

This statement, made pursuant to section 54(1) of the Modern Slavery Act 2015, sets out steps Headway Insurance Services Ltd has taken to understand and minimise the potential risk of modern slavery in its business and supply chains.

Headway is a family run business who offer and provide a wide range of insurance products and brokering services to customers and website visitors at highly competitive prices. We are authorised and regulated by the Financial Conduct Authority and work to the highest professional standards, complying with all laws, regulations and rules relevant to our business.

Headway is committed to understanding more about modern slavery and ensuring there is no modern slavery concerns in our business or supply chain.

Equality and Diversity Policy

As an equal opportunities’ employer, we are committed to creating and maintaining a non-discriminatory and respectful working environment for its staff. Our Equality and Diversity company policy, which although not related to slavery and human trafficking issues, does provide guidelines about how to treat protected characteristics and demonstrates our awareness of differences and the value and contribution of all. We believe this allows us think differently and support our valued customers in the best way possible.

Whistleblowing Policy

Our Whistleblowing Policy enables our staff to feel confident to be able to raise any concerns about any wrongdoing or breaches of law without fear of disciplinary action. As a company we encourage the reporting of concerns and the protection of whistle blowers.

Preventing Financial Crime Policy

We recognise that financial crime in all its forms is a threat to our company, the financial services community and our customers. We are committed to the prevention of financial crime such as money laundering, the funding of terrorist activity, bribery and corruption, fraud and market abuse and through risk based internal procedures, policies and systems and controls to ensure that high standards of crime prevention and awareness are maintained by all Directors, employees and suppliers, whether under a contract of employment or a contract of service.

Dignity at Work

Dignity at work is about how we treat our fellow colleagues and customers, and any other people we meet when carrying out our work for us. Our policy details our commitment to providing a working environment free from harassment, discrimination, bullying and victimisation.

Training

All staff have access to training and development opportunities, and we have an in-house academy that provides comprehensive new joiner induction and ongoing training. All calls are recorded for training and compliance purposes. Our managers are responsible for compliance in their respective departments and staff are tested annually to ensure that they remain competent as part of FCA guidelines. Staff are made aware of all company policies and procedures, and this includes having access to information on modern slavery and human trafficking.

Conduct

All staff must be professional in tasks that that they undertake within our company and must always be courteous and respectful to customers and colleagues. We expect the highest standards of integrity and honesty within our business.

Terms and Conditions

Headway is a voluntary living wage employer who ensures that anyone recruited to work for us confirms their identity and has the right to work in the UK. Staff are contracted to work “standard” working hours as set out in our contracts of employment.

Supplier Adherence to our values

We expect all those in our supply chain to comply with our value of zero tolerance to slavery and human trafficking.

Headway Insurance Ltd will not knowingly support or deal with any business involved in slavery or human trafficking.

Supply Chain Risks

Our suppliers are limited and based within the UK which has a developed culture of ethical business practices. Headway assess itself to have a low risk of modern slavery in our business and supply chains. We are proud to have long standing relationships with our suppliers, maintaining contact with them on a regular basis by holding management meetings, telephone calls and site visits to monitor performance. We believe that this sets expectation of business behaviour.

We will however, evaluate the modern slavery and human trafficking risks of any new supplier who provides goods to our business, and will do this by carrying out due diligence checks, including their compliance with applicable laws including their policies regarding slavery and human trafficking.

Our Information Security Manager has overall responsibility for regular internal and external audits to check compliance with all our policies and procedures. We will continue to be alert to the potential for problems.

We will continue to review our Modern Slavery statement on a quarterly basis.