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Modern Slavery and Human Trafficking Statement

Financial Year 2024–2025

1. Introduction

This statement is made on behalf of Smart Cover ("the Company") pursuant to section 54 of the Modern Slavery Act 2015. It sets out the steps we have taken, and continue to take, to ensure that modern slavery and human trafficking are not taking place within our business or supply chains.

Smart Cover is committed to acting ethically and with integrity in all its business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not occurring anywhere in our business or supply chains.

2. About Our Business

Smart Cover operates as an online provider of home emergency cover and insurance products, serving residential customers across the United Kingdom. Our services include boiler cover, home emergency protection, and related insurance products delivered through our digital platform at www.smart-cover.co.uk.

As a primarily digital business, our operations involve:

  • Direct online sales and customer service operations
  • Partnerships with insurance underwriters and financial service providers
  • Third-party technology and software suppliers
  • Marketing, communications, and professional service providers

3. Our Policies on Modern Slavery

Smart Cover has a zero-tolerance approach to modern slavery. We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or in our supply chains. Our commitment is reflected in the following policies and frameworks:

3.1 Recruitment and Employment

We ensure that all employees have the right to work in the United Kingdom, are employed on fair and transparent terms, receive at minimum the National Living Wage, and are free to leave employment at will. We do not engage in or condone forced labour, child labour, or any form of exploitative employment practice.

3.2 Supplier Code of Conduct

We expect all suppliers and business partners to uphold the same high standards we set for ourselves. Our Supplier Code of Conduct requires that all partners:

  • Comply with all applicable laws relating to labour rights and human rights
  • Do not use forced, bonded, compulsory, or trafficked labour
  • Do not employ children below the applicable minimum working age
  • Provide workers with fair wages, reasonable working hours, and safe conditions
  • Respect workers’ rights to freedom of association

4. Due Diligence Processes

We undertake due diligence when considering new suppliers and regularly review existing supplier relationships. Our due diligence processes include:

  • Evaluating the nature and geographic scope of supplier operations
  • Requesting completion of supplier self-assessment questionnaires covering labour practices and ethical standards
  • Reviewing publicly available information on supplier compliance and any reported issues
  • Incorporating modern slavery and ethical trading obligations into supplier contracts
  • Monitoring supplier performance and compliance on an ongoing basis

Where we identify actual or potential risks of modern slavery in our supply chain, we will take appropriate remedial action, which may include working with suppliers to address identified shortcomings or, where necessary, terminating supplier relationships.

5. Risk Assessment

We assess the risk of modern slavery in our operations and supply chains as relatively low, given the nature of our business as a digital insurance intermediary. However, we recognise that no business is entirely without risk and we remain vigilant.

The areas we consider to carry a higher relative risk include:

  • Third-party IT and software development suppliers, particularly those with operations in higher-risk jurisdictions
  • Facilities management and cleaning service contractors
  • Marketing agencies and outsourced call centre operations

We prioritise our due diligence and monitoring activities in these areas accordingly.

6. Training and Awareness

We are committed to ensuring that all staff are aware of the risks of modern slavery and know how to identify warning signs. Our approach to training and awareness includes:

  • Providing guidance to all employees on recognising and reporting signs of modern slavery
  • Including modern slavery awareness in our onboarding process for new employees
  • Ensuring that staff involved in procurement and supplier management receive appropriate training on ethical sourcing
  • Communicating our zero-tolerance approach to modern slavery to all employees and relevant third parties

7. Reporting Concerns

We encourage anyone who has concerns about modern slavery or human trafficking — whether in our business or in our supply chain — to report them. Concerns can be raised through the following channels:

  • Directly with a line manager or senior member of staff
  • Via our internal whistleblowing policy, which allows for confidential and anonymous reporting
  • By contacting the Modern Slavery Helpline on 0800 0121 700

We will take all concerns raised seriously and investigate appropriately. We will not tolerate any retaliation against individuals who raise genuine concerns in good faith.

8. Measuring Our Effectiveness

We will monitor and review the effectiveness of our actions to address the risk of modern slavery through the following key performance indicators:

  • Completion of supplier self-assessments for all new and renewing high-risk suppliers
  • Percentage of employees who have received modern slavery awareness training
  • Number of concerns raised and outcomes of any investigations
  • Annual review and update of this statement and related policies

9. Approval and Review

This statement has been approved by the senior management of Smart Cover and will be reviewed and updated annually.

This statement covers the financial year 2024–2025 and was approved for publication on behalf of Smart Cover.