Modern slavery statement
ARAG UK Holdings Limited and its subsidiaries, ARAG Legal Expenses Insurance Company Limited, ARAG Law Limited and ARAG Services Limited (“ARAG UK”) are committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain. ARAG UK insists that the same standards that it promotes in combatting modern slavery are similarly adopted and enforced by its suppliers in order to adhere to the obligations and the intent of the Modern Slavery Act 2015 (“the Act”).
ARAG UK operates in the legal insurance and legal services markets together with ancillary and complimenting service streams. ARAG UK is a subsidiary of ARAG SE, a specialist insurance company headquartered in Germany.
ARAG UK operates primarily in the UK and employs 900 people with annual turnover of approximately £250m. To find out more about our business, please click www.arag.co.uk or www.araglaw.co.uk.
In order to deliver our services to business partners, clients and policy holders, we work with a range of suppliers from professional service organisations to suppliers of consumables. Irrespective of the services ARAG UK receives from a supplier we insist that their obligations in respect of modern slavery and human trafficking must be to the same high standards as our own.
As part of our commitment to combating modern slavery, we have implemented the following practices:
• Notified and made staff aware of the importance of the Act;
• Identified how modern slavery may manifest itself in the work environment;
• Notified our suppliers of the importance of the Act as well as our stance on modern slavery and communicated our expectation of adherence by them to our standards.
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted due diligence procedures which include:
• Implementing processes which require staff to procure goods and services through the approved supply chain;
• Reviewing and where appropriate consolidating supplier numbers to reduce the overall amount of suppliers which assists in making the supply chain more manageable;
• Where possible, assessing the origin of goods and services delivered through that supply chain specifically around the geographic origin of goods to assess whether these are high risk areas;
• Undertaking risk assessments of suppliers to identify indicators which may raise concerns about the use by ARAG UK of that organisation within the supply chain;
• Carrying out appropriate levels of due diligence prior to entering into a new supplier relationship (i.e. reference checking organisations in order to share knowledge of other client of the supplier);
• Carrying out supplier audits on an ongoing basis to monitor changes which inform the checks set out above on an ongoing basis.
Our procedures are designed to:
• Control the number of suppliers, such that they are assessed and managed so that slavery and forced labour are not used in the supply chain;
• Influence the behaviours of suppliers so that the objective of the Act is achieved;
• Establish and assess areas of potential risk in our business and supply chains;
• Monitor those risk areas in our business and supply chains;
• Empower ARAG UK to take positive and decisive action where breaches of the Act are identified or suspected.
ARAG UK regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain as part of its supplier management procedure. Meetings take place on a regular basis, depending on the supplier, the nature of the goods and services as well as any indicator that greater regularity of review is necessary (i.e. where a supplier is sourcing from a location considered higher risk).
We do not consider that we operate in high risk sectors or locations because the majority of suppliers and business partners provide either professional / insurance services or goods delivered from within the United Kingdom. For the reasons set out in this document, ARAG UK maintains a procurement process which seeks to ensure that reputable organisations are used in our supply chain, contractually commits suppliers to adhere to the standards ARAG UK sets itself as well as affording ARAG UK the right to audit and review the supply chain.
If we find evidence of a failure to comply with our standards in respect of Modern Slavery or a breach of legislation in this area we will immediately seek to terminate our relationship with the relevant supplier. Where there are suspicions of a breach ARAG will take positive action to investigate and either terminate where proven, or work with the supplier to demonstrate with greater certainty that there is no such breach.
We educate our employees to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training, all employees, are encouraged to identify and report any potential breaches of the Act or suspicions of slavery and human trafficking within the ARAG UK supply chain.
Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps to tackle slavery and human trafficking:
• Where appropriate, streamline our supplier base to facilitate more effective management and assessment of their performance.
• At the start of any new supply contract seek to impose contractual obligations to tackle modern slavery and broad rights of termination for any such breach, as well as a right to audit their processes for compliance by them and their supply chain.
• Annually request our suppliers to complete a qualification questionnaire, which includes a mandatory provision for submitting their up-to-date modern slavery statement, provided they meet the specified criteria.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes ARAG UK’s slavery and human trafficking statement for the financial year commencing 2 January 2025 and ending 31 December 2025.
Brynley Case, Chief Customer Officer with responsibility for Outsourcing, Procurement and Supply Chain For and on behalf of ARAG.