SunLife is a part of the Phoenix Group. The following statement has been approved by the Phoenix Group Holdings plc Board of Directors (the ‘Board’) on 14 May 2021. It is in response to Section 54, Part 6 of the Modern Slavery Act and sets out the steps that Phoenix Group took, in the financial year ended 31 December 2020, to ensure slavery and human trafficking has not taken place in our supply chain.
“At Phoenix Group, we have zero tolerance towards slavery, human trafficking and labour abuses of any kind. We recognise the challenges of tackling these critical issues and are continuously working with our suppliers to improve practises, offer training and raise awareness.” – Tony Kassimiotis, Chief Operating Officer Phoenix Group
The Full Modern Slavery and Human Rights Statement can be downloaded here.
Phoenix Group at a glance
Phoenix is the UK's largest long-term savings and retirement business with £338 billion of assets under administration and c.14 million customers.
We are a constituent of the FTSE 100 with c 7,500 employees and offer a broad range of products to support people across all stages of the savings life cycle.
We are a growing and sustainable business with a clear purpose-
Helping people secure a life of possibilities.
Assets under administration by product and division: £338bn
AUA by division
AUA by product
Unit Linked: 63%
Shareholder and Protection: 2%
Optimise in-force business - We manage our in-force business to deliver resilient cash generation and management actions, including cost and capital synergies.
Deepen customer relationship - By engaging with our customers and meeting their broader needs, we will retain our customers and they will consolidate towards us as they journey to and through retirement.
Customer acquisition - We are a growing and sustainable business with a clear purpose- helping people secure a life of possibilities.
Helping people secure a life of possibilities
is the bedrock of our business and we are the market leader
has strong foundations and unique advantages from operating alongside Heritage
M&A & INTEGRATION
is a differentiated capability underpinned by our specialist skills and scalable operating model
• c. £7bn market capitalisation
• £338bn AUA
• c.14m customers
• FTSE 100 and FTSE All World
• c.7,500 employees
• £17.7bn long-term cash
Scope and KPIs
Scope of our review
2020 was a year of growth and change for Phoenix Group including the acquisition of ReAssure. As a result, in 2021, we are in the process of harmonising our human resources and supplier management processes.
Tackling modern slavery and human rights violations is a continuous journey and our approach needs to adapt to better understand how to support suppliers to influence behaviour throughout the supply chain via education and targeted activity.
In 2020, our analysis determined that the majority of our supplier base operate in sectors with a low risk of modern slavery, human rights, and other social issues. We continue to monitor the risk level of our supply chain based on what we procure and where we procure from. Regardless of the level of risk, we are committed to tackling these critical issues in part through raising awareness and accountability throughout our business and supply chain.
In 2021, a risk based approach is to be developed and rolled out across our supply chain to assess our supply chain and provide a baselined position.
A list of entities included in this statement can be found in Appendix 1.
* Key suppliers include: Strategic (those that we work with due to the strategic nature of the services they provide), Critical (suppliers where the goods or services provided is limited in the market and barriers to change are complex) and Financially Important with spend > £1m (suppliers which are numerous but where value to Phoenix Group is significant).
Key Performance Indicators (KPIs)
Staff trained to identify & address modern slavery & human rights issues & violations
• Group Procurement Supplier Management colleagues and those colleagues managing key supplier relationships will be undergoing modern slavery and human rights specialist training throughout 2021.
• All colleagues will receive high level training throughout our Code of Conduct training.
Cases of modern slavery & human rights violations discovered internally or in our supply chain
• To date, no instances of modern slavery or human rights violations have been identified.
Our suppliers’ Modern Slavery Statements
• 95% of our key suppliers* published their own Modern Slavery Statements
• Direct engagement has been undertaken with those suppliers that do not have a Modern Slavery Statement and guidance has been offered on establishing a programme to manage the issues and develop a Statement.
• Areas for improvement have been identified and communicated to specific suppliers' disclosures to ensure they improve their approaches to tackling modern slavery and human rights violations.
Policies, controls & external commitments
We have a set of policies in place that are relevant to managing the risk of modern slavery, human rights and promotion of wider decent working practices. These policies are reviewed on an annual basis and adapted as requested by our business.
The scope and content of these policies are informed by the context in which we operate; our sector is a relatively low risk one for human rights risks in the supply chain. Despite this, we are committed to tackling these important issues and understand that education is key both in our business and in our supply chain.
Our employees are subject to, and benefit from, a wide range of progressive policies including: disciplinary, grievance, non-discrimination and remuneration and compliance policies. The policies and frameworks that we have in place limit the risk of modern slavery and human trafficking in the workplace and encourage all staff to work and act ethically at all times.
Our policies also reflect our commitments to pay employees fairly and properly for their work, act with integrity and ethically in all of our relationships and to corroborate the same level of commitment within our supply base.
We are a Living Wage Employer- the purpose of which is to work to ensure and promote a UK wage which meets everyday needs.
Supplier Management Model
Our Supplier Management Model sets out the high standards and principles we require our suppliers to follow and that we expect them to demand from their own supply chains.
The Model covers in part: requirements set out in the Sourcing and Procurement Policy and Framework, outsourced arrangements covering several supplier categories and oversight of our business processes.
Code of Business Ethics
One of the most valuable assets a company can have is its reputation for integrity. In all our communications, we will not only stick to the truth, but will also avoid exaggeration and overstatement.
Employees shall not undertake activities that produce, or give the impression of producing conflict between the personal interests of an employee and the interests of the Group or its customers.
The ethical performance of the Group is created by the performance of those who work here and so we are all expected to adhere to high standards of personal and professional integrity.
Sustainability Risk Policy
The Sustainability Risk Policy sets the minimum operating standards relating to the management of sustainability risk throughout the Phoenix Group.
It is one of the key risk policies designed to provide a clear framework and a system of minimum control standards, for the management of risk across the Group. The policy addresses:
• Corporate sustainability governance
• Workplace issues
• Identification of external stakeholder issues
• Identification and management of environmental and sustainable supply chain risks and
• Integration and interaction with the local community.
Code of Conduct
Defines how colleagues should act on a day-to-day basis, outlines core values, overall culture and whistleblowing.
Sourcing & Procurement Policy
Requires that all colleagues understand potential risks related to any sourcing activity and supplier management, including modern slavery and human rights.
Diversity & Inclusion Policy
Describes how we build meaningful, enduring and respectful relationships across different cultures in part through our strong commitment to equality, diversity and inclusion.
Supplier code of conduct - extract
All suppliers are expected to meet the Supplier Code of Conduct. They must m eet and evidence the standards and obligations in the Modern Slavery Act 2015.
All suppliers must:
Respect the human rights of their employees and comply with all relevant legislation, regulations and directives in the countries and communities in which they operate.
Uphold as a minimum, commitments relating to the four core International Labour Organisation (ILO) standards as detailed below and ensure that their own supply chain also meets these minimum standards.
Freedom of association & the effective rights of collective bargaining
Suppliers must not interfere with the right of employees to legally organise and join associations such as labour unions, employee consultation committees or employee associations.
The elimination of all forms of bonded labour & compulsory labour including modern slavery
Suppliers must prohibit the use of forced labour or bonded labour and give their employees, whether local or migrant, the right and the ability to leave employment when they choose.
Suppliers must meet their obligations in accordance to the UK Modern Slavery Act 2015 and take steps to address modern slavery in all their operations and supply chains by ensuring that any contracts with subcontractors have similar obligations.
The effective abolition of child labour
Suppliers must ensure that child labour is not used and that the employment of young workers adheres to local regulations
The elimination of discrimination with respect to employment & occupation
Suppliers should provide a work environment in which employees do not suffer from harassment, verbal, visual, physical abuse or any conduct that creates an intimidating, offensive or hostile workplace.
It is the responsibility of our suppliers to ensure they only employ people with a legal right to work in that geography and that their employees are protected from discrimination on the grounds of; age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex or sexual orientation.
Where employing staff in the UK, suppliers must confirm they adhere to the Equality Act 2010.
Sustainable supply chain strategy & risk assessment
Sustainable supply chain standards
In 2020, Phoenix Group developed a sustainable supply chain strategy which includes:
• The development of a new modern slavery and human rights training module for colleagues to be rolled out throughout 2021
• Publishing of the supplier code of conduct and
• Developing sustainability standards for our suppliers which include modern slavery and human rights.
The sustainable supply chain standards have been designed to take suppliers on a journey to sustainability best practice, tailored to the criticality to our business and/or the risk assessment of our sector and region for sustainability.
The standards focus in part on modern slavery and human rights. We have asked our strategic, critical, and financially important suppliers (with spend over £1m) to meet our highest standard.
These suppliers are required to develop a gap analysis against the standard by the end of 2021 and provide a detailed action plan by the end of 2022 that addresses the gaps identified in their current activity.
Key supplier sustainable supply chain standards extract:
• Active management of human rights and modern slavery risks in their own organisation and in their supply chain.
• Provide training for both internal colleagues and high risk suppliers on human rights and modern slavery.
• Zero tolerance for child labour throughout the supply chain and employment of young workers adheres to UK regulations regardless of location.
• Comply with the UK Modern Slavery Act 2005 (applicable if turnover is over £36m) or meet the local equivalent standard/Act, International Labour Organisation (ILO) standards, UK Human Rights Act 1998 and Equality Act 2010 or local equivalents.
• Support freedom of association and the effective recognition of the right to collective bargaining.
Selection of new suppliers
In 2021 we will enhance our new supplier assessment and onboarding processes. Suppliers will be informed of their requirement to meet our Supplier Code of Conduct.
The risk assessment of their sector and criticality to our business will determine the requirement to meet the Sustainable Supply Chain Standards.
Due diligence and ongoing risk assessments
The Group operates a highly outsourced operating model and the risks of modern slavery in our supply chain are considered relatively low compared to other sectors. However, this assessment does not give rise to complacency. The Group employs three routes to assess the risk of Modern Slavery within our supply chain.
In 2021, a risk based approach is being developed to assess the risk of modern slavery and human rights violations in our supply chain. We will be rolling out our sustainable supply chain standards to suppliers included in the Group’s Supplier Management Model (SMM). The rest of the supplier base must continue to meet our Supplier Code of Conduct and will be risk assessed based on the sector and region we procure from. The highest risk suppliers, those deemed to have elevated risk of modern slavery, will be required to demonstrate that they meet our Sustainable Supply Chain standards.
We will continually assess the risk of modern slavery and look to improve our approach to tackling this critical issue including finding cross industry collaboration.
Our due diligence guidelines require any potential supplier with an annual turnover in excess of £36M to have a published Modern Slavery Statement.
Strategic and critical suppliers with an annual turnover below £36M are required to provide a copy of their modern slavery policy or statement for review prior to their appointment.
Once on board they must, at a minimum, meet the Supplier Code of Conduct.
Additional reviews are conducted when material changes increase the risk profile.
If there are any indications that modern slavery is taking place within our supply chain, we will take appropriate steps to eliminate risk.
Appendix 1: Phoenix Group Entities
|Company Name||Country||Company number|
|3 St Andrew Square Apartments Limited||UK||SC108543|
|Abbey Life Assurance Company Limited||UK||00710383|
|Abbey Life Trust Securities Limited||UK||00843568|
|Abbey Life Trustee Services Limited||UK||01451364|
|Aberdeen Standard Capital Limited*||UK||SC317950|
|Alba LAS Pensions Management Limited||UK||SC060928|
|Alba Life Trustees Limited||UK||SC31475|
|Axial Fundamental Strategies (US Investments) LLC||United States|
|BA (FURBS) Limited||UK||3365953|
|Britannic Finance Limited||UK||3588089|
|Britannic Group Services Limited||UK||2090476|
|Britannic Money Investment Services Limited||UK||2171236|
|Century Trustee Services Limited||UK||1905318|
|Challenger Limited (Australia)||Australia|
|G Park Management Company Limited||UK||06878047|
|Gallions Reach Shopping Park (Nominee) Limited*||UK||5777118|
|Helium Miracle 264 Limited||UK||11379674|
|Iceni Nominees (No. 2) Limited*||UK||4266393|
|IH (JERSEY) LIMITED||Jersey||109362|
|Impala Holdings Limited||UK||06306909|
|Impala Loan Company 1 Limited||UK||SC212709|
|Inesia SA||Luxembourg||B66 931|
|Inhoco 3107 Limited*||UK||5188136|
|Lake Meadows Management Company Limited*||UK||2467063|
|London Life Limited||UK||01179800|
|London Life Trustees Limited||UK||00934044|
|National Provident Institution||UK||ZC000065|
|National Provident Life Limited||UK||03641947|
|NP Life Holdings Limited||UK||03725026|
|NPI (Printworks) Limited||UK||3950816|
|NPI (Westgate) Limited||UK||3939272|
|PA (GI) Limited||UK||71805|
|Pearl (Covent Garden) Limited||UK||04152541|
|Pearl (Martineau Phase 1) Limited||UK||3775168|
|Pearl (Martineau Phase 2) Limited||UK||3775171|
|Pearl (Moor House) Limited||UK||4209012|
|Pearl (WP) Investments, LLC||United States|
|Pearl AL Limited||UK||SC4348|
|Pearl Assurance Group Holdings Limited||UK||03245996|
|Pearl Customer Care Limited||UK||3947540|
|Pearl Group Holdings (No. 1) Limited||UK||3524909|
|Pearl Group Holdings (No.2) Limited||UK||05282342|
|Pearl Group Management Services Limited||UK||3588063|
|Pearl Group Management Services Limited - BRANCH||Ireland||905628|
|Pearl Group Secretariat Services Limited||UK||3588041|
|Pearl Group Services Limited||UK||5549998|
|Pearl Life Holdings Limited||UK||4560778|
|Pearl MG Birmingham Limited||UK||4002195|
|Pearl MP Birmingham Limited||UK||4002164|
|Pearl RLG Limited||UK||4560770|
|Pearl Trustees Limited||UK||02665203|
|PG Dormant (No 4) Limited||UK||1565099|
|PG Dormant (No 5) Limited||UK||1621367|
|PG Dormant (No 6) Limited||UK||165018|
|PGH (Cayman) UK Branch||UK||BR020363|
|PGH (LC1) Limited||UK||6308404|
|PGH (LC2) Limited||UK||06308409|
|PGH (LCA) Limited||UK||5257400|
|PGH (LCB) Limited||UK||5282338|
|PGH (MC1) Limited||UK||6386849|
|PGH (MC2) Limited||UK||06386851|
|PGH (TC1) Limited||UK||06386847|
|PGH (TC2) Limited||UK||06386846|
|PGH Capital PLC||Ireland||537912|
|PGMS (Glasgow) Limited||UK||SC159852|
|PGMS (Glasgow) Limited - BRANCH||Ireland||904026|
|PGMS (Ireland) Holdings Unlimited Company||Ireland||341950|
|PGMS (Ireland) Limited||Ireland||342705|
|PGS 2 Limited||UK||03725038|
|Phoenix & London Assurance Limited||UK||894616|
|Phoenix (Barwell 2) Limited||UK||3943463|
|Phoenix (Chiswick House) Limited||UK||3943490|
|Phoenix (Moor House 1) Limited||UK||3950821|
|Phoenix (Moor House 2) Limited||UK||3943371|
|Phoenix (Printworks) Limited||UK||3693948|
|Phoenix (Stockley Park) Limited||UK||3938357|
|Phoenix Advisers Limited||UK||4339390|
|Phoenix AW Limited||UK||1225468|
|Phoenix Customer Care Limited||UK||3315193|
|Phoenix ER1 Limited||UK||10196658|
|Phoenix ER2 Limited||UK||10196579|
|Phoenix ER3 Limited||UK||10844152|
|Phoenix ER4 Limited||UK||11121610|
|Phoenix ER5 LIMITED||UK||11720413|
|Phoenix ER6 LIMITED||UK||12139423|
|Phoenix Group Capital Limited||UK||5447500|
|Phoenix Group Holdings||Cayman Islands||202172|
|Phoenix Group Holdings plc||UK||11606773|
|Phoenix Group Management Services Ltd||UK||10691596|
|Phoenix Life Assurance Limited||UK||00001419|
|Phoenix Life Holdings Limited||UK||6977344|
|Phoenix Life Limited||UK||1016269|
|Phoenix Life Litd- Hong Kong Branch||Hong Kong||F14409|
|Phoenix Life Limited - Irish Branch||Ireland||906073|
|Phoenix Life Pension Trust Limited||UK||558944|
|Phoenix Pension Scheme (Trustees) Ltd||UK||1912908|
|Phoenix Pensions Trustee Services Ltd||UK||1967589|
|Phoenix SCP Limited||UK||4013361|
|Phoenix SCP Pensions Trustees Ltd||UK||2404622|
|Phoenix SCP Trustees Limited||UK||SC108046|
|Phoenix SL Direct Limited||UK||586343|
|Phoenix SPV1 Limited||UK||11418551|
|Phoenix SPV2 Limited||UK||11418573|
|Phoenix SPV3 Limited||UK||11418612|
|Phoenix SPV4 Limited||UK||11418621|
|Phoenix ULA Limited||UK||928046|
|Phoenix Unit Trust Managers Limited||UK||3588031|
|Phoenix Wealth Holdings Limited||UK||3223752|
|Phoenix Wealth Services Limited||UK||2238458|
|Phoenix Wealth Trustee Services Limited||UK||2155360|
|ReAssure Group plc||UK||11597179|
|ReAssure Jersey One Limited||UK||108672|
|Scottish Mutual Assurance Limited||UK||SC133846|
|Scottish Mutual Nominees Limited||UK||SC78057|
|Scottish Mutual Pension Funds Investment Limited||UK||SC61343|
|SL (NEWCO) Limited||UK||SC297006|
|SL Liverpool Limited||UK||2529609|
|SLA Belgium No.1 SA||Belgium||BE0638.954.836|
|SLA Netherlands No.1 B.V.||Netherlands||60700793|
|SLACOM (No. 10) Limited||UK||SC271362|
|SLACOM (No. 8) Limited||UK||SC271358|
|SLACOM (No. 9) Limited||UK||SC271360|
|SLIF Property Investment GP Limited*||UK||SC388872|
|Standard Life Agency Services Limited||UK||SC170047|
|Standard Life Assets and Employee Services Ltd||UK||SC593510|
|Standard Life Assurance Limited||UK||SC286833|
|Standard Life International dac||Ireland||408507|
|Standard Life Investment Funds Limited||UK||SC068442|
|Standard Life Lifetime Mortgages Limited||UK||SC193441|
|Standard Life Master Trust Co. Ltd||UK||09497864|
|Standard Life Pension Funds Limited||UK||SC046447|
|Standard Life Private Equity Trust plc*||UK||SC216638|
|Standard Life Property Company Limited||UK||SC101362|
|Standard Life Trustee Company Limited||UK||SC076046|
|The Heritable Securities and Mortgage Investment Association Ltd.||UK||SC000668|
|The London Life Association Limited||UK||00041503|
|The Pearl Martineau Galleries Limited Partnership||UK||LP006989|
|The Pearl Martineau Limited Partnership||UK||LP006988|
|The Phoenix Life SCP Institution||UK||SZ000005|
|The Scottish Mutual Assurance Society||UK||SZ000015|
|The Standard Life Assurance Company of Europe B.V.||Netherlands||33.272.024|
|UK Commercial Property Estates Limited||Guernsey||53361|
|UK COMMERCIAL PROPERTY GP LIMITED||Guernsey||45385|
|UK COMMERCIAL PROPERTY HOLDINGS LIMITED||Guernsey||45386|
|UK COMMERCIAL PROPERTY NOMINEE LIMITED||Guernsey||45400|
|UK Commercial Property Trust Limited||Guernsey||45387|
|Vebnet (Holdings) Limited||UK||00792165|
|Welbrent Property Investment Company Limited*||UK||4617102|
|ReAssure Group plc||UK||11597179|
|ReAssure MidCo Limited||UK||02970583|
|ReAssure Two Limited||UK||00777895|
|103 Wardour Street Retail Investment Company Ltd||UK||09291187|
|Ark Life Assurance Company dac||Ireland||158762|
|ReAssure UK Life Assurance Company Ltd||UK||00676139|
|BL Telford Limited||UK||00151731|
|ReAssure LL Limited||UK||01397655|
|NM Pensions Limited||UK||04240147|
|Namulas Pension Trustees Limited||UK||00980864|
|ReAssure Pension Trustees Limited||UK||01800078|
|ReAssure PM Limited||UK||00985480|
|NM Life Trustees Limited||UK||01860464|
|ReAssure UK Services Limited||UK||7860886|
|ReAssure Trustees Limited||UK||1767383|
|G Life H Limited||UK||960516|
|G Assurance & Pension Services Limited||UK||2150733|
|G Financial Services Limited||UK||1035097|
|G Trustees Limited||UK||2030135|
|The Gresham Life Assurance Society Limited||UK||39345|
|ERIP General Partner Limited||UK||6416546|
|ERIP Limited Partnership||UK||LP012555|
|ReAssure Companies Services Limited||UK||6705828|
|ReAssure FSH UK Limited||UK||7717278|
|ReAssure Nominees Limited||UK||489153|
|ReAssure FS Limited||UK||116551|
|ReAssure Life Limited||UK||1363932|
|ReAssure Life Pension Trustees Limited||UK||1538109|
|Phoenix Life Assurance Europe dac||UK||684882|
|The Pathe Building Management Company Ltd||UK||09267935|
|Northampton General Partner Limited||UK||05607362|
Group Chief Executive Officer
14th May 2021