Modern Slavery Policy

Slavery and Human Trafficking statement as required under s54, Part 6,
of the Modern Slavery Act [1] 2015 for the 2015/2016 financial year.

1. Introduction

The DUAL Group and its subsidiaries (“the Company”) is committed to ensuring that its business dealings are carried out in compliance with the relevant laws and, in doing so, we endorse the implementation and promotion of ethical business practices to protect workers from being abused and exploited.

The Company is committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.


2. Organisation Structure

This statement covers the activities of the DUAL Group which is headquartered in the UK and has over 560 employees in entities across the world.


3. Relevant Policies

The Company operates a number policies that mitigate the risk of modern slavery and set out steps to be taken to prevent slavery and human trafficking in its operations.

4.1 Whistleblowing

The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use our confidential helpline.

4.2 Supplier Chain Management

Whilst the Company exercises a vital role in the insurance distribution chain, it does not have a supply chain that is reliant on factories or other entities that would normally be associated with slavery or forced labour. 

As a general rule, contractors and suppliers used by the Group are therefore not likely to be susceptible to this risk. However, we are mindful that others may not always uphold standards to the same level as DUAL.  Consequently, employees responsible for managing suppliers and others involved with the Group are, themselves, responsible for ensuring that our values and ideals are upheld. This continues to be a work in progress and we are strengthening our controls as new contracts are agreed. For example, serious violations by suppliers will lead to the termination of the business relationship.

4.3 Recruitment and Selection

The Company uses only specified, reputable employment agencies to source labour. All entities in the Group ensure appropriate controls are in place to ensure employees have the right to work and are therefore protected by employment legislation. This includes checking right-to-work documents, visas and passports

The Company and its associated subsidiaries do not employ individuals that would be considered to be ‘child workers’. Young and inexperienced workers may be employed or given work experience, but they are subject to the rights and protections that we afford all workers.

Basic rights which we expect all workers to enjoy, include: 

  • The right to a reasonable wage
  • The right to a safe working environment
  • The right to an appropriate level of holiday and cover for period of sickness
  • The freedom to complain directly via our whistleblowing policy free of charge, if they believe that they are not being fairly treated or have any other concerns.


4.4 Corporate social responsibility policy/charitable foundation

Over the last decade DUAL’s charitable activities have supported organisations that strengthen the communities in which we live and work, both in the UK and Internationally. The extent of these endeavours has grown with our business’s expansion. As part of Hyperion, DUAL is involved in charitable activity through the Hyperion Foundation. The Hyperion Foundation was established in 2014 to provide a focus and impetus for the fundraising activities of the groups employees.


5. Right of Audit

All offices in the Group are subject to periodic audits. Core audit work includes an assessment of the basic working conditions of our staff and consideration of our ability to oversee controls discharged by third party suppliers.

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[1] References in this Statement to the “Act” are references to the “Modern Slavery Act 2015”