Our ethics
We have zero tolerance to any form of slavery and human trafficking, and are committed to enforcing effective systems and controls to ensure neither is taking place in any part of our business or in any of our supply chains. Social impact is an important part of our ongoing commitment to ethics and has been since Arthur J. Gallagher was founded in 1927. Our leadership sets the tone for our distinct culture and senior level accountability demonstrates commitment to ensuring we do what is right for our customers and the communities that we operate in. Since 1927, Gallagher has led with integrity, ethics and purpose — consistently recognized by organizations such as JD Powers & Associates, Forbes, Fortune 500, Ethisphere and the Human Rights Campaign.
Group structure
The Organisation is part of the Arthur J. Gallagher & Co's group of companies (the "Group") that provides insurance brokerage and consulting services, and third party claims settlement and administration services to clients globally. The Group has approximately 52,000 employees worldwide and approximately 6,500 employees in the United Kingdom.
Our business
The main services we provide are (re)insurance risk placement, risk consulting, underwriting services and (re)insurance claims management, across a wide spectrum of insurance classes, delivered to commercial and personal lines customers and insurers.
Our supply chain
Being a financial services organisation that does not produce, manufacture or retail goods, we do not operate in an industry where modern slavery is prevalent. We do employ external service providers for maintenance and support of our offices, including cleaning and technical support services for office infrastructure and IT, and for outsourcing certain functions ordinarily performed by the Organisation. Material new suppliers are required to complete a Request for Information (RFI), used to assess capacity against a range of criteria including regulatory and financial; that includes compliance with modern slavery reporting requirements.
In respect of suppliers identified as higher risk (e.g. IT, Consultancy, Facilities and HR), a rotational 'deep dive' of supplier operations is conducted on each category every 6 months.
Common with other financial services organisations, the Organisation utilises offshore business process outsourcing services. A key factor is that the service providers in India and in Sri Lanka are part of the Group rather than third-party business process outsourcers and all their staff are Group employees. They perform various functions that are essential to the delivery of services to our clients. They continue to subscribe to how we manage modern slavery risk and integration of our policies and training is ongoing covering, amongst other things employee well-being and risk management and a process for the reporting of risk events of all types.
Our policies and governance
The Organisation is also committed to adhering to the highest standards of moral, professional, and ethical behaviour, and acting with integrity and transparency in all our business relationships. We therefore expect our supplier network, or those involved in procurement for the Organisation, to comply with the Gallagher Global Standards of Business, which is available to view by accessing https://www.ajg.com/us/about-us/global-standards/.
A Professional Standards Manual (“PSM”) is in place and accessible by all staff. This suite of core policies reflects the shared values of the Gallagher Way, and Gallagher Global Standards of Business, reinforcing the Organisation’s commitment to upholding the highest professional standards, and ethics, both in the workplace and in business dealings with others.
In addition to the Gallagher Global Standards of Business and PSM, the Organisation has various policies and processes in place that aim to minimise the risk of modern slavery and human trafficking, and encourage reporting of any related concerns, including:
- A Modern Slavery Policy, that outlines the behaviours expected of all employees and the reporting procedure and obligations.
- A Procurement Policy that implements a proportionate supplier assessment process and establishes due diligence requirements. The Organisation includes a specific requirement for compliance with modern slavery legislation in its standard terms and conditions and contractual arrangements. In addition, the Organisation utilises its Outsourcing & Critical Supplier Committee (that performs an oversight function) to set the standards for material supplier performance and assessment of suppliers’ approach to social responsibility.
- A Supplier ESG Attestation Questionnaire, which includes Modern Slavery and Labour Standards. Through this, the Organisation gains assurance of third party compliance with applicable regulations and richer insights into the policies and practices applied throughout our critical supply chain.
- A Whistleblowing Policy that ensures all employees know how to raise concerns about how colleagues are being treated or regarding practices within our business or supply chain, without fear of reprisal. There were no reported incidences in connection with suspected Modern Slavery activity since the last statement.
- Recruitment Polices that, amongst other things, mitigate against utilising external agencies that do not adequately safeguard individuals offered for roles or are employed by the agency. Important elements include robust Right to Work checks and background and criminal records checks.
- The ‘Gallagher Way’ a statement of Gallagher shared values, which acts as the foundation that underpins the Group culture.
Training
All new employees receive the training as part of their induction programme. It includes information on who staff should contact should they have any concerns about modern slavery. Staff are also encouraged to report any concerns or suspicions regarding the presence of modern slavery within the supply chain.
In addition, Modern Slavery is included within our global “Leading with Integrity” training module, which is assigned to all new and existing employees on an annual basis.
We are continuing to develop tailored Modern Slavery training for colleagues in procurement, human resources and recruitment to raise awareness of modern slavery, specific risks to identify and the effective reporting of any human trafficking concerns.
Looking ahead, continuous improvement and ambition
To improve the oversight of our modern slavery risk, our Environmental, Social and Governance (ESG) Committee is leading on shaping how we assess and report on the risk of modern slavery. One of our 2022 highlights is having worked with Slave-Free Alliance to review our Modern Slavery Statement and governance processes.
Gallagher embraces a culture of continuous improvement, endeavouring to incorporate best practice. This includes increasing transparency in our operations by embedding modern slavery within our global ESG strategy. We have also embedded modern slavery into the ESG agenda and continue to develop our strategy for implementation and risk monitoring.
In addition, our ambition is to achieve the following:
| When by | What |
| 1-3 years | Perform gap analysis, consultancy, training and site assessment, utilising external risk consultants (i.e. Slave Free Alliance) when required. |
| Next 6-12 months | Fully refresh training strategy (with an eye on global legislation and relevance to ESG training). We are continuing to develop tailored Modern Slavery training for colleagues in procurement, human resources and recruitment to raise awareness of modern slavery, specific risks to identify and the effective reporting of any human trafficking concerns |
| Ongoing | Wider roll-out of any best practice to support global consistency |
| Ongoing | Continue to be vigilant in the monitoring and reporting of any suspected modern slavery instances, and encourage colleagues to report through the appropriate whistleblowing channels. |
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and has been approved by the Board of Arthur J. Gallagher Holdings (UK) Limited on 29 June 2023.
Appendix 1
- Arthur J. Gallagher (UK) Limited
- Arthur J. Gallagher Insurance Brokers Limited
- Alesco Risk Management Services Limited1
- Pen Underwriting Limited
- AJG Services Limited
- Risk Management Partners Limited (each, a UK-regulated insurance firm)
1 Appointed Representative of Arthur J. Gallagher (UK) Limited
