Modern Slavery Statement 2025
This statement provides clarity on our corporate responsibility, focusing on Cincinnati Global Underwriting Agency Ltd’s (CGUAL) compliance with the Modern Slavery Act 2015 and our commitment to prohibiting any form of forced labour or slavery throughout our supply chain.
Cincinnati Global Underwriting Agency Ltd has zero tolerance to slavery and human trafficking and takes its responsibilities very seriously.
This version of the statement is applicable to CGUAL’s 2024 year of account.
Organisation Structure
CGUAL is the Lloyd’s managing agent for Cincinnati Global Syndicate 318. Our ultimate parent company is Cincinnati Financial Corporation. Within Cincinnati Financial Corporation group structure, Cincinnati Global Underwriting Ltd. is an intermediate holding company of Cincinnati Global Underwriting Agency Ltd and the
following, which are also wholly owned subsidiaries:
Cincinnati Global Dedicated No 2 Ltd (a Lloyd’s corporate member and the vehicle through which Cincinnati Global Underwriting Ltd participates on Syndicate 318); and
Cincinnati Global Underwriting Services Ltd (dormant).
Cincinnati Global Underwriting Ltd and all its subsidiary companies are incorporated under the laws of England and Wales and authorised and regulated by the Prudential Regulation Authority, Financial Conduct Authority and Lloyd’s.
Our Business and Supply Chains
Cincinnati Global Syndicate 318 specialises in providing (re)insurance in the following classes of business: Property, International Treaty, Contingency, Specie, Political Violence (Terrorism), Credit & Political Risk, Construction and Marine. This (re)insurance is conducted worldwide through a network of brokers, all of which are also regulated entities. CGUAL enters into written terms of business agreements with all producers, which outline each party’s responsibilities in relation to the provision of insurance services.
CGUAL does not manufacture or distribute any physical goods, meaning our business activity supply-chain is purely service-based. Therefore, as a provider of professional services with skilled employees primarily based in office locations in the UK, we do not believe insurance to be a key risk sector and therefore have assessed our overall risk of modern slavery as low. However, we are still committed to ensuring that all necessary measures are in place in order to mitigate any risk of modern slavery practices within our organisation.
In relation to the Construction class of business, CGUAL recognises that there is a risk of modern slavery and human trafficking due to the nature of this industry. However, CGUAL only offers cover to reputable multinational corporations who are also reasonably expected to ensure that modern slavery does not exist within their business practices, meaning we are satisfied that this risk is mitigated. Any indications to the contrary are flagged to ensure that CGUAL does not provide insurance services to any entity reasonably believed to be complicit with modern slavery or human trafficking.
Our Policies on Slavery and Human Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. This includes detailed oversight of the welfare of all our employees, including pay, environment, working hours, health and safety and wellbeing. The employee Code of Conduct contains a detailed section on modern slavery and how to recognise and mitigate the risks associated with this.
We will not tolerate any violations of basic human rights or employment practices by or against our employees or within our supply chains, and we recognise the need to work with our suppliers to tackle the risk of modern slavery. Accordingly, employees are required to adhere to our Procurement policy and all other policies applicable to suppliers in order to uphold modern slavery commitments across our supply chains.
We also maintain a Whistleblowing policy, which encourages employees to raise concerns around improper practices as and when they become aware of them. This policy outlines confidential channels for raising concerns, such as contacting the Whistleblowing Champion, senior management, or regulatory/supervisory authorities, and reminders to utilise the available channels are provided quarterly via employee newsletters. 1CGUAL also has various other policies relating to bribery and corruption, financial crime, sanctions compliance and conflicts of interest. All employees have access to these policies, and their rights are communicated through our employee handbooks and employment contracts.
Due Diligence Processes for Slavery and Human Trafficking
We understand the necessary requirements to identify and mitigate the risk of slavery and human trafficking and therefore include the following systems in our due diligence processes:
Producer/supply-chain due diligence – all new suppliers are subject to a selection process or other form of due diligence which sufficiently assesses propriety. As part of our contracting processes, we seek assurance that the supplier prohibits the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers (if applicable) will hold their own suppliers to the same high standards.
Whistleblower protection – all employees are fully protected from scrutiny should they decide to report suspected improper practice. In order to enable this, strict confidentiality is enforced around any disclosures made to the Whistleblowing Champion.
We reserve the right to audit our suppliers with the exception of the suppliers of incidentals such as kitchen supplies with whom detailed contracts are not in place.
Risk Assessment and Management
Given the nature of CGUAL’s business operation, the Board and Senior Management is of the view that the risk of complicity or support of human trafficking or slavery within the organisation and its supply-chains is low. In spite of this, we believe our policies and mitigation practices are proportionate to the level of risk associated with our business.
Training
We have provided comprehensive training to all employees on our responsibilities and approach to modern slavery, ensuring awareness of the Modern Slavery Act throughout our business. This includes a specific modern slavery e-learning module, which requires completion on an annual basis. All training has been completed within the required deadlines during 2024, with repeat training scheduled in 2025.
To complement this, employees are also required to complete a detailed e-learning module in relation to the organisation’s Code of Conduct, one aspect of which relates to modern slavery.
Effectiveness of Mitigating Modern Slavery and Human Trafficking
Cincinnati Global group companies are required to have a continuous programme in place to review their policies and processes in an effort to avoid and prevent slavery and human trafficking within their supplier chains. All necessary reviews have been carried out throughout 2024 and will continue to be completed throughout 2025.
To date, no instances of modern slavery or human trafficking within the organisation or its supply-chains have been reported, and we continue to remain alert for any malpractice that may come to our attention in the course of business.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement approved by the Board of Management on __ May 2025 for the financial year ending 2024.
Name: Ross Allibone
Position: Head of Compliance
Date: 19/05/2024
For and on behalf of the Board of Directors of Cincinnati Global Underwriting Agency Ltd.