Modern Slavery Act 2015

This statement is made on behalf of the Hampden group of companies (‘Hampden or ‘the business’).

We are publishing this statement in accordance with the Modern Slavery Act 2015 and as a demonstration of our commitment to anti-slavery practices and as an affirmation of the values we hold across our business.

We are committed to ensuring that we always comply with our statutory obligation, operate in an ethical manner and uphold the principles of good corporate citizenship. A significant part of this commitment is that Hampden has zero tolerance to slavery and human trafficking and is committed to these not being a feature of its supply chains.

About us

Hampden is a provider of (re)insurance, investment and financial support services to its clients, which are types of financial services products and services. We do not act as a producer, manufacturer or retailer of physical goods and we have no supply chain in relation to such activities.

Hampden, for the purposes of this policy, includes:

• Hampden Holdings Limited
• Hampden Agencies Limited
• HampdenFX Limited
• Nomina PLC
• Hampden Insurance Partners (Cayman) Limited
• Seymour Taylor Limited and ST Hampden Limited trading as “Seymour Taylor”
• Hampden Private Office Limited
• Hampden Risk Partners

Policies and Procedures

Hampden is committed to ensuring that those in the supply chain do not engage in slavery or human trafficking and regularly reviews it policies and procedures to ensure that they are up to date and reflect the current regulatory environment. We communicate this statement to our staff to ensure that they understand the risks of modern slavery and human trafficking generally but also in respect of our supply chains, where we demonstrate a zero-tolerance approach.
In addition to a periodic review of material outsourced arrangements, there are whistle blowing procedures in place to ensure that employees can raise any concerns that they have including any concerns in relation to modern slavery and human trafficking, operating under a code of practice and standards of business conduct.

Due diligence

Hampden procurement processes ensure that consideration is given to the appropriateness of the supplier against a number of criteria, both quantitative and qualitative. Consideration is given as to whether the provider has adequate risk management processes and procedure, conduct risk controls, measure to combat financial crime (including bribery, money laundering and trade sanctions) and measures to combat slavery and human trafficking where appropriate. Suppliers are expected to adhere to all local laws and regulations.

Supply Chains

As a provider of (re)insurance products and services, we have limited supply chains to distribute and service this business and so we consider the risk of modern slavery or human trafficking to be relatively low. The business operates in diverse geographic locations including the United Kingdom, European Union, Channel Islands and Cayman Islands. Suppliers provide a wide range of predominantly professional products and services to support the Hampden’s business and we believe that this limited supply chain means that risk modern slavery and human trafficking within it to be relatively low.

Hampden expects its suppliers to uphold the same high standards of corporate responsibility as are applied across our business.

This statement is approved by the Executive Committee of Hampden and is reviewed on an annual basis.

Alistair Wood
Chief Executive Officer