CFC is committed to conducting our business responsibly and ethically, including ensuring that our supply chains are free from slavery and human trafficking.
1. OUR ORGANISATION STRUCTURE
CFC Group Limited is a private limited company registered in England and Wales under company number 10666844. This statement covers the activities of CFC Group Limited and its subsidiaries, including CFC Underwriting Limited, CFC Europe S.A, CFC USA Inc, CFC Security Inc and Insane Technologies Pty Ltd (collectively “CFC”). CFC is primarily involved in the provision of services as an underwriting agency and insurance intermediary, and the provision of cyber incident response services. CFC is headquartered in London, with licensed trading entities operating in Brussels, New York, Austin and Brisbane. CFC currently employees over 400 staff globally.
2. OUR SUPPLY CHAINS AND RISK ASSESSMENT
Whilst CFC sells its products and services worldwide, it does not make use of supply chains which are traditionally susceptible to an enhanced risk of slavery or human trafficking, such as factories, other entities involved in manufacturing, or business sectors which are reliant on a high degree of human labour.
Given the nature of CFC’s business, we consider the risk of modern slavery in our supply chains low. However, we remain vigilant to this risk, and have in place several policies and procedures to ensure we do not knowingly do business with a company involved in any form of modern slavery or human trafficking.
3. OUR POLICIES
As part of our commitment to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business, we maintain policies and procedures to support this commitment including:
Outsourcing Policy: setting out our approach to outsourcing, as well as the due diligence which must be undertaken before CFC outsources any aspect of its business to a third party. As part of the due diligence process, CFC checks all potential service providers for financial soundness, sanctions and adverse media, and continually monitors providers on a regular basis.
Whistleblowing Policy: setting out the manner in which our staff and business partners can report any concerns relating to the activities of any CFC Group company or anyone involved in its supply chains, including circumstances which may give rise to a risk of human trafficking or slavery.
Recruitment and Remuneration Policies: setting out the rights in which all our staff enjoy, including fair and reasonable wages, the right to a safe working environment, and appropriate holidays and provisions for sickness.
Risk Management Policy: CFC’s approach to effective risk management is outlined in its Risk Management Policy. Any existing or emerging modern slavery risks will be captured as part of the risk management cycle, with mitigants.
Code of Conduct Policy: outlining the ethical standards that all employees of CFC are expected to adhere to, to ensure CFC operates responsibly and ethically. These include ensuring employees act with integrity, due skill, care and diligence whilst displaying openness and transparency with all stakeholders including customers and suppliers.
4. NEXT STEPS
CFC continuously reviews its risks in relation to modern slavery and human trafficking, both as an employer and as a purchaser of outsourced services, to identify measures we can take as a business to prevent modern slavery occurring in our business and supply chain.
We intend to take the following steps during the 2021/2022 financial year:
CFC recently asked all UK employees to undertake a training module to ensure such employees were aware of, and complied with, the new Senior Managers and Certification conduct rules. This training will be repeated annually and will be a mandatory requirement for UK employees. CFC reviews the outsourcing policy and supplier due diligence process on an annual basis to ensure our processes remain effective as the business grows.
5. ANNUAL REVIEW
The statement has been approved by the Board.
Group Chief Executive Officer
20 April 2021