This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Thomas Miller’s anti-slavery and human trafficking statement for the financial year commencing 1 January 2017 and ending 31 December 2017.

Statement

We take pride in the conditions of employment for all our employees within Thomas Miller.
As an international firm, Thomas Miller always works to the highest professional standards and complies with all laws and regulations applicable to the business.
Given the nature of our business, it is considered that there is a limited supply chain which supports our business activities and there is minimal risk that we are in any way involved, or complicit in slavery or human trafficking.

Our procurement and employment practices ensure that we are a supportive and ethical employer.  We aim to provide a high level of professional service, which in turn helps to build and maintain our business and relationships. In addition, Thomas Miller expects a high level of conduct from those companies with which we do business. 

Our Supply Chains

In relation to the businesses we manage and own, their supply chains are limited. We manage Mutuals who offer insurance solutions through the mutual structure and are accountable to both the Financial Conduct Authority (FCA) and Prudential Regulation Authority (PRA). Thomas Miller has procurement procedures for Professional Services and also for Goods and Services other than professional services, where we make reference to this statement when considering the suitability of our suppliers. We do not act as a producer, manufacturer or retailer of physical goods and have no supply chain in relation to such activities.
We have a number of overseas offices where employment and use of third parties is mirrored to that in the UK, except where local regulations stipulate differently.

Due Diligence

As part of our Risk Management Framework, Thomas Miller operates a range of policies and procedures, including policies in respect of:

  • outsourcing;
  • procurement;
  • whistleblowing;
  • anti-money laundering and
  • Bribery and financial crime.

Thomas Miller sets out employee rights and responsibilities in Contracts of Employment, the Employee Handbook and related employment documentation.

It is our aim to ensure, as far as we can, that any third party suppliers, correspondents etc. that we work with, operate in accordance with the same high standards that we embrace, with regard to their employees.

Training/Understanding

We will communicate this statement to all our existing and new employees to ensure a high level of understanding of Thomas Millers’ position on modern slavery and human trafficking in our business.