About Smart Cover Insurance Services
Smart Cover Insurance Services is a trading name of Smart-Cover Direct Limited, a company registered in England and Wales. Smart Cover, Smart Cover Insurance Services, and Smart Cover 247 are all trading names of Smart-Cover Direct Limited.
Smart-Cover Direct Limited is an Appointed Representative of City and Commercial Limited (FRN 314346), authorised and regulated by the Financial Conduct Authority. Smart-Cover Direct Limited holds FCA reference number FRN 600428.
Smart Cover is a UK-based insurance intermediary that arranges and administers personal lines insurance products including home emergency cover, appliance insurance, boiler breakdown cover, plumbing and drainage cover, landlord home emergency insurance, and motor breakdown cover. The business was founded in 2013 by a team of insurance professionals with over 20 years of collective industry experience.
Smart Cover operates predominantly as a digital and telephone-based business, serving UK residential and landlord customers. Its principal place of business is Citibase, 42–44 Clarendon Road, Watford, WD17 1JJ, and its registered address is Ashley Court, 32 Main Street, Ashley, Leicestershire, LE16 8HF.
Our Policies on Modern Slavery & Human Trafficking
Smart-Cover Direct Limited operates a zero-tolerance policy towards modern slavery and human trafficking in all its forms. This commitment is embedded in our business culture and reflected in the policies and procedures that govern how we hire, procure, and conduct business.
The policies and frameworks that support our anti-slavery commitment include:
- Anti-Slavery and Human Trafficking Policy - a standalone internal policy that sets out our zero-tolerance position, defines modern slavery in all its forms, and establishes responsibilities for compliance across the business.
- Recruitment and Employment Policy - ensures all recruitment is conducted lawfully under UK employment legislation, including the right to work in the UK for all employees, compliance with the National Living Wage, and prohibition of any form of forced or involuntary labour.
- Supplier Code of Conduct - a set of ethical standards that all suppliers, contractors, and service providers must agree to as a condition of doing business with Smart-Cover Direct Limited. The Code expressly prohibits the use of forced labour, child labour, debt bondage, and human trafficking.
- Whistleblowing Policy - provides a confidential channel for employees, contractors, and third parties to report suspected modern slavery concerns or any other ethical violations without fear of retaliation.
- FCA Consumer Duty and Conduct Risk Framework - as an FCA-regulated intermediary, Smart Cover's governance framework includes robust conduct risk controls that extend to all business relationships, including supply chain partners.
Our Commitment to Eliminating Modern Slavery
Smart Cover recognises that modern slavery is a serious crime and a grave violation of fundamental human rights. It takes many forms, including forced labour, bonded labour, domestic servitude, sexual exploitation, forced marriage, organ harvesting, child labour, and human trafficking. We are committed to ensuring that neither Smart Cover's own operations nor any part of our supply chain contributes in any way to any form of modern slavery or exploitation.
Our commitment encompasses the following forms of exploitation, all of which we expressly prohibit:
Forced & Compulsory Labour
No person shall be required to work through the use of force, threat, debt bondage, retention of identity documents, or any other form of coercion.
Child Labour
Smart Cover will not engage, directly or indirectly, with any supplier or organisation that employs workers below the minimum legal working age applicable in their jurisdiction.
Domestic Servitude
All workers engaged in or connected to Smart Cover's operations must be free to leave their employment without penalty and must receive fair remuneration for their work.
Human Trafficking
Smart Cover has zero tolerance for the recruitment, transportation, transfer, harbouring, or receipt of persons through coercion or deception for the purpose of exploitation.
Debt Bondage
No worker shall be required to pay recruitment fees, make deposits, or take on debt as a condition of employment or engagement with Smart Cover or any of its supply chain partners.
Document Retention
No employer, contractor, or agency connected to Smart Cover's supply chain shall retain workers' identity documents, passports, or travel papers as a means of control.
Our Supply Chains
Smart Cover operates as a digital-first insurance intermediary. Its supply chains are primarily composed of professional service providers, technology businesses, and individuals rather than manufacturers or large-scale physical goods producers. The main categories of supplier and partner that form Smart Cover's supply chain include:
- Insurance underwriters and capacity providers - the insurance companies and underwriters that provide the underlying insurance capacity for Smart Cover's products. These are regulated financial services businesses subject to their own regulatory and governance frameworks.
- UK-based home engineers and tradespeople - the network of engineers, plumbers, electricians, gas engineers, and appliance repair technicians who are dispatched to policyholders' homes. These are typically self-employed individuals or small businesses operating within the UK.
- Technology and software providers - CRM platforms, policy administration systems, customer communication tools, and web infrastructure providers, primarily based in the UK, EU, and USA.
- Marketing and affiliate partners - digital marketing agencies, price comparison websites, affiliate networks (including AWIN), and SEO and content service providers, predominantly UK-based.
- Professional services - legal advisers, accountants, compliance consultants, and insurance regulatory advisers, all operating within regulated professional frameworks in the UK.
- Telecommunications and office services - telephony providers, office facility management, and business support services.
Risk Assessment & Identification
Smart Cover has assessed the modern slavery risk profile of its business operations and supply chains. Given the nature of the business - a UK-regulated insurance intermediary serving UK residential customers - the overall risk of modern slavery within Smart Cover's own operations is assessed as low. However, we recognise that modern slavery can occur in unexpected places, and we maintain vigilance across all supplier relationships.
The following risk assessment reflects our assessment of modern slavery risks by supply chain area:
| Supply Chain Area | Risk Level | Key Risk Factors | Mitigating Controls |
|---|---|---|---|
| Own Workforce (UK employees) | Low | Direct UK employment; FCA regulated; right-to-work checks; National Living Wage compliance | Employment contracts; payroll oversight; HR policies; whistleblowing channel |
| UK Home Engineers & Tradespeople | Medium | Self-employed individuals; potential for labour exploitation in trades; agency worker risks | Engineer vetting; fair payment terms; contractor agreements; anti-slavery clauses |
| UK Technology & Software Providers | Low | Predominantly UK/EU regulated businesses; professional service standards | Supplier due diligence; contractual anti-slavery requirements |
| Marketing & Affiliate Partners | Low | Digital services sector; some use of freelance platforms with global workforces | Platform compliance standards; AWIN affiliate agreement requirements |
| Professional Services (Legal, Finance) | Low | All UK regulated professionals; bound by professional conduct codes | Regulation by SRA, ICAEW, FCA as applicable; professional indemnity |
| Insurance Underwriters & Capacity | Low | UK/EU regulated financial services businesses with their own MSA compliance | FCA/PRA regulation of counterparties; contractual representations |
Due Diligence Processes
Smart Cover takes a proactive approach to due diligence to identify and mitigate modern slavery risks across its supply chains and business operations. Our due diligence processes include the following steps:
Supplier Onboarding & Screening
All new suppliers, contractors, and service providers undergo an onboarding review before engagement begins. This includes confirmation of their legal status, UK right to operate, and - for relevant categories - their own modern slavery policies and compliance frameworks.
Contractual Anti-Slavery Requirements
Smart Cover's standard supplier and contractor agreements include express anti-slavery and anti-trafficking clauses. These require all suppliers to confirm that neither they nor their own supply chains use forced labour, child labour, or human trafficking, and to notify Smart Cover immediately of any known or suspected modern slavery incidents.
Engineer Vetting & Registration
All home engineers and tradespeople who respond to Smart Cover policyholders' claims are vetted and registered. The vetting process includes identity verification, right-to-work checks, trade qualification verification, and professional accreditation checks(e.g., Gas Safe registration for gas engineers). Engineers are required to confirm their status as independent contractors or employees of registered businesses.
Recruitment Right-to-Work Checks
All Smart Cover employees undergo right-to-work verification before commencing employment, in compliance with the Immigration, Asylum and Nationality Act 2006 and related legislation. Smart Cover does not engage labour-only agencies for the sourcing of its direct employees.
Fair Pay Verification
Smart Cover confirms that all direct employees are paid at or above the National Living Wage applicable at the relevant time. Payroll processes are reviewed by the Finance function to ensure compliance with pay legislation, including the requirement to pay wages directly to employees without unlawful deductions.
Whistleblowing & Incident Reporting
Smart Cover maintains a confidential whistleblowing channel through which employees, contractors, and third parties can report suspected modern slavery or ethical violations. All reports are investigated promptly and treated in strict confidence. Employees are protected against retaliation for good-faith disclosures under the Public Interest Disclosure Act 1998.
Training & Awareness
Smart Cover is committed to building awareness of modern slavery across its workforce so that every employee and manager is equipped to recognise potential indicators of exploitation and knows how to report concerns. Our training and awareness programme includes:
Induction Training
All new employees receive modern slavery awareness training as part of their induction programme, covering what modern slavery is, how to recognise warning signs, and how to report concerns.
Annual Refresher
Existing employees receive annual refresher training to maintain awareness of modern slavery risks and to stay current with evolving guidance from the Home Office and other authorities.
Management Training
Managers and senior staff with supply chain or procurement responsibility receive enhanced training on supplier due diligence and how to identify and escalate modern slavery risks in business relationships.
Policy Communication
Smart Cover's Anti-Slavery Policy and Supplier Code of Conduct are communicated to all staff and are available to suppliers on request, ensuring all parties understand our expectations and commitments.
Reporting Protocols
All staff are provided with clear information on how to report modern slavery concerns, including the Modern Slavery Helpline number (0800 0121 700) and internal reporting channels.
Effectiveness Review
Training effectiveness is reviewed annually as part of the Modern Slavery Statement review process. Training completion rates and whistleblowing reports are tracked to assess the programme's reach and impact.
Key Performance Indicators & Progress
Smart Cover uses the following key performance indicators (KPIs) to measure and evaluate the effectiveness of its modern slavery prevention measures. These indicators are reviewed annually by senior management as part of the statement review process.
- Anti-slavery training completion rate - percentage of employees who have completed the induction and annual modern slavery awareness training.
- Supplier due diligence coverage - percentage of new suppliers who have completed Smart Cover's onboarding process, including acceptance of anti-slavery contractual clauses, before engagement begins.
- Whistleblowing reports - number of modern slavery-related concerns reported through internal or external channels, and the proportion investigated and resolved within target timescales.
- Engineer vetting compliance - percentage of newly registered engineers who have undergone the full vetting process, including identity and right-to-work checks, before attending a policyholder's property.
- Payroll compliance - confirmation that all direct employees are paid at or above the National Living Wage, verified through payroll audit.
- Statement publication - annual publication of this Modern Slavery Statement, reviewed and approved by the board of Smart-Cover Direct Limited before publication.
Reporting Modern Slavery Concerns
Smart Cover encourages anyone - employees, contractors, suppliers, policyholders, or members of the public - to report concerns about potential modern slavery or human trafficking connected to Smart Cover's business or supply chain. All reports will be treated in strict confidence and investigated promptly.
Report a Modern Slavery Concern
If you suspect modern slavery or human trafficking in connection with Smart Cover's operations or supply chain, please contact us immediately. You can also report directly to the national Modern Slavery Helpline or the police.
In the case of an immediate emergency involving a person who may be a victim of modern slavery or trafficking, dial 999 immediately. Victims of modern slavery can also be referred through the National Referral Mechanism (NRM), which can be accessed by contacting the Modern Slavery Helpline on 0800 0121 700.
Further information and resources on modern slavery are available from:
- Modern Slavery Helpline - 0800 0121 700 (free, available 24/7 in 200+ languages)
- UK Government Modern Slavery Resources - Home Office guidance for businesses and individuals
- Independent Anti-Slavery Commissioner - oversight and guidance on the Modern Slavery Act 2015
- Unseen UK - charity supporting survivors of modern slavery and operating the National Modern Slavery Helpline
Board Sign-Off & Annual Review
This Modern Slavery Statement has been reviewed and approved by the board of directors of Smart-Cover Direct Limited for the financial year 2025 to 2026. It is published in accordance with Section 54 of the Modern Slavery Act 2015 and will be reviewed and updated on an annual basis to reflect any changes in Smart Cover's business operations, supply chains, or the evolving modern slavery risk landscape.
Statement of Approval
We, the directors of Smart-Cover Direct Limited, confirm that this Modern Slavery Statement accurately reflects our organisation's position on modern slavery and human trafficking for the financial year 2025/2026. We are committed to reviewing and improving our policies, due diligence processes, and training programme on an ongoing basis to strengthen our ability to identify and prevent modern slavery across our business and supply chains.