DPAS Modern Slavery Statement

EXECUTIVE SUMMARY

Context

The Modern Slavery Act 2015 requires that businesses within the UK which have an annual turnover of £36m or more produce an annual statement setting out the steps they have taken during the preceding financial year to ensure there is no modern slavery in their business or supply chain.

We have worked with key stakeholders throughout the business (including representatives from Legal, Procurement, Investments, Practice Plan, Customer, HR and Risk) to produce the statement for the financial year ending 31 December 2023, and this is now presented for approval.

We are permitted by the Act to produce one statement to cover the whole of Wesleyan Group activity. However, the board of directors of each individual group company must separately approve the Statement.

Questions this paper addresses

Why do we need to produce a Modern Slavery Statement?

What companies does it cover?

What are the main areas of action in the last year, and what are the proposed actions in the coming year?

Who has been involved in putting it together?

Conclusion

The 2023 Modern Slavery Act statement should be approved and signed. It is also being tabled for approval at subsidiary boards and once fully approved will be made available on the group’s websites and also uploaded to the Home Office central registry.

Input Sought

The Board is asked to approve the Modern Slavery Statement for the year ended December 2023.

THE REPORT

Further Context

1. Why do we need to produce a Modern Slavery Statement?

The Modern Slavery Act 2015 requires that businesses within the UK which have an annual turnover of £36m or more produce an annual statement setting out the steps they have taken during the preceding financial year to ensure there is no modern slavery in their business or supply chain.

2. What companies does it cover?

The Statement covers the following companies:

Wesleyan Assurance Society

Wesleyan Administration Services Ltd

Wesleyan Financial Services Ltd

Practice Plan Ltd

DPAS Ltd

Medenta Finance Limited

Wesleyan Unit Trust Managers Limited

3. What are the main areas of activity in the last year, and what is the proposed activity in the coming year?

The main areas of activity last year were:

Investments and Procurement are working together on an additional due diligence process for companies with substantial operations/ headquarters in ‘higher risk’ countries.

Procurement has collated statistics on our country risk and reported this

Our Modern Slavery trading has been completed by 98% of

We have ensured that our minimum salary level to 8% above the National Living Wage and increased all salaries to within 80% of the market rate for the specific role.

The proposed activity for the coming year:

Investments and Procurement to conclude their country risk due diligence process for ‘higher risk’

HR to continue to develop risk assessment criteria and enhance onboarding checks to respond to any changes in Modern Slavery legislation.

Review activities and processes anticipated under the proposed new Modern Slavery

Procurement to publish country of origin of sourcing inputs in supply

4. Who has been involved in putting it together?

The following have inputted into the Statement:

Legal: Ian Rose

Risk: Dan Gamson

Investments: Lucas Howarth

HR: Louise Beards/David Taylor

Procurement: Emma Goodwin

WFS: Stuart Brown/Kerri Trinder

MLRO: Angela Dunn

PPG: Jackie Fletcher

Co Sec: Matthew Cooch

SOCIETY IMPACT SUMMARY

Introduction

This is a summary of the impacts on the Society. Further details on these are within the report itself.

Financial impacts on the Society

Compliance with the Modern Slavery Act is a legal obligation. Failure to comply would have both a reputational and financial cost to the Society.

Impacts on risk and governance

Compliance with the Modern Slavery Act is a legal If a business fails to comply, the Secretary of State may seek an injunction through the High Court requiring it to do so.

Regulatory requirements

Compliance with the Modern Slavery Act is a legal obligation.

Impact on people and culture

Reputationally important for Wesleyan to demonstrate compliance with his obligation.

Sponsor: Jon Welsh

Author: Ian Rose

GEC, SOCIETY BOARD AND ALL

APERATING SUBSIDIARY BOARDS

Date of Meeting: Various

Date Written: 13/03/2024