Statement on slavery and human trafficking

This statement by Hastings Group (Consolidated) Limited (“HGC”), as the UK parent company of the Hastings Group (the “Group”), is made pursuant to section 54(6) of the Modern Slavery Act 2015. It constitutes the Group’s slavery and human trafficking statement in respect of the financial year ended 31 December 2022.

This statement has been approved by the HGC Board, on behalf of the Group, on 22 February 2023.

Ricard Wennerklint, Director
on behalf of Hastings Group (Consolidated) Limited and its subsidiary entities.

Our commitment

We will not tolerate slavery and human trafficking within our business and supply chain. We are committed to acting responsibly in business relationships and ensuring that slavery and human trafficking does not occur anywhere in our business operations. We also require our suppliers and business partners to take necessary and appropriate steps to avoid and/or tackle slavery and human trafficking.

We will continue to enforce the Group’s polices, processes and procedures throughout the coming year in support of our commitment.

Structure, business and supply chain

We are a provider of financial service products to the UK retail market, specifically for car, van, motorbike and home insurance and also unsecured personal lending. We have three trading businesses: Hastings Insurance Services Limited (“HISL”), trading as Hastings Direct, an insurance intermediary and service provider which operates from three locations in the UK (Bexhill-on-Sea, Leicester, and London); Advantage Insurance Company Limited (“AICL”), an insurance underwriter based and regulated in Gibraltar; and Hastings Financial Services Limited (“HFSL”), an FCA regulated lending business. HGC is the ultimate UK parent company of the Group, and via Hastings Group Holdings Limited, a wholly owned intermediate holding company, is responsible for oversight of the Group’s operations; its head office is located in Bexhill-on-Sea, East Sussex.

Our business model focuses on providing general insurance and other financial services products to customers in the UK only, via price comparison websites, over the telephone, and via digital platforms. The Group operates UK call centre operations for retail sales, customer service and claims handling functions, and has outsourced arrangements to supplement these operations in the UK and in South Africa.

We support, and are committed to, the welfare of all of our colleagues in terms of pay, working hours, environment, health and safety, and wellbeing. We do not expect, and will not tolerate, violations of basic human rights or UK employment practices by any colleague, or within our supply chain. The number of colleagues directly employed by the Group as at 31 December 2022 was over 3,200. Our colleagues are engaged on a variety of full-time, part-time, and flexible working arrangements and are appropriately remunerated and incentivised; the Group does not operate zero-hour contracts. Contractors are also employed by the Group from time to time, but these are generally professional workers for specific projects.

We have a transparent and inclusive culture based on our 4Cs cultural framework ensuring the needs of Colleagues, Customers, Community, and Company are taken into account. We listen and respond to issues and concerns our colleagues raise, either through formal surveys, colleague forums (including the Hastings Colleague Forum which we recognise for the purposes of statutory collective consultation), leadership escalation or, if necessary, via ad-hoc, open communication directly with Chief Executive Officer. We do not formally recognise a trade union, but all colleagues have the right to be represented by a trade union member should they chose to do so.

HISL’s primary suppliers include price comparison websites, technology providers, outsourced call centre service providers, vehicle repair centres, car hire providers, and law firms. All of these suppliers, with the exception of a South African call centre operation, are based in the UK, the European Union, or the United States.

AICL’s external supply relationships include reinsurance brokers, actuarial service providers, and reinsurers which, with the exception of some reinsurers, are all based in the UK.

HFSL’s primary suppliers include price comparison websites and outsourced technology platforms, all based in the UK. No other Group company has any supplier relationships other than corporate, accounting and legal, professional, or advisory services from UK based organisations.

Policies in relation to slavery and human trafficking

We have a responsibility to conduct business in an ethical and transparent way. Accordingly, we adhere to a set of business principles which include a commitment to human rights principles. Policies and procedures underpin our overall control and governance structure, as well as supporting our 4Cs culture, including policies covering conduct, whistleblowing, recruitment, anti-bullying and harassment, health and safety, anti-bribery and corruption, diversity and equality, compassionate leave, disciplinary, and religious holidays. These policies are reviewed and updated as appropriate in line with changes to best practice and/or legislation.

We have a procurement and supplier relationship management policy that supports our procurement and supplier management framework. This is designed to attract the best suppliers and secure best value from them, to manage risks, and to ensure that relevant regulatory and legal obligations are met.

Our policies and frameworks reflect our commitment to minimise the risk of modern slavery or human trafficking occurring anywhere in our business operations and supply chains.

Due diligence processes, risk assessment and management

We include appropriate measures in our due diligence processes to engage suppliers and business partners on a risk assessed basis. As part of the procurement and supplier performance management policy, we ensure that all suppliers undergo a stringent due diligence process before engagement, and continued oversight and performance management following engagement. Compliance with human rights, fair treatment and reasonable remuneration for employees, as well as safe working conditions, are all reviewed.

As part of the pre-employment and recruitment process, we ensure that all colleagues are legally permitted to work within the UK and that they are joining us of their own free will and have not been coerced. HISL, AICL and HFSL are all regulated financial services firms, and background and financial checks are undertaken on all of our colleagues. We also require our suppliers to operate in a similar manner, where it is appropriate, in the context of the services they provide to the Group.

Training

We raise awareness of conduct, human rights and diversity and inclusion amongst our colleagues through annual mandatory training via an online platform. Completion rates for all mandatory training are monitored and business leaders are informed when these rates are not satisfactory.

We also ensure all of our colleagues are aware of our whistleblowing policy, via our intranet and training modules, and all colleagues are given guidance on how to report potential or actual incidents confidentially. We encourage colleagues to report all potential or actual incidents that relate to wrongdoing or actual or suspected illegal or serious inappropriate activity, whether related to modern slavery or not. A confidential, externally facilitated portal is provided for colleagues to report their concerns, anonymously if they so choose.

Effectiveness

We monitor any incidents of actual or suspected illegal or serious inappropriate activity and take action as appropriate.

During the year ended 31 December 2022 there were no incidents relating to modern slavery or violations of human rights identified and no incidents were reported by colleagues, whether internally via management, or via the whistleblowing portal. There were also no incidents reported relating to our supply chain, either by internal supplier relationship managers or our suppliers themselves.

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