You are using an outdated browser. Please upgrade your browser to improve your experience.

Modern Slavery and Human Trafficking

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.

About us

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.

Our business

Assets under administration by product and division: £338bn

AUA by division

Heritage: 48%
Open: 52%

AUA by product

Unit Linked: 63%
Annuities: 12%
With-profits: 23%
Shareholder and Protection: 2%

Our strategy

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

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.

Route one

Our due diligence guidelines require any potential supplier with an annual turnover in excess of £36M to have a published Modern Slavery Statement.

Route two

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.

Route three

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
Cityfourinc UK 3871807
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
SunLife Limited UK 5460862
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 Trust Limited Guernsey 45387
Vebnet (Holdings) Limited UK 00792165
Vebnet Limited UK SC207389
Welbrent Property Investment Company Limited* UK 4617102
ReAssure Group plc UK 11597179
ReAssure MidCo Limited UK 02970583
ReAssure Limited UK 754167
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
Andy Briggs Group Chief Executive Phoenix Group signature.

Andy Briggs
Group Chief Executive Officer
14th May 2021