For the year ended 31 December 2023
The Modern Slavery Act 2015 is an Act of the Parliament of the United Kingdom, designed to combat modern slavery and consolidates previous offences relating to trafficking and slavery.
This statement is made on behalf Catalina Holdings Bermuda Limited (“CHBL”) and each of its subsidiaries, including, but not limited to, the companies based or operating in the United Kingdom (collectively, “Catalina” or the “Catalina Group”). It covers the activities of the Catalina Group and all Catalina Group employees.
This statement sets out the steps we have taken to obtain assurance that slavery and human trafficking are not taking place anywhere in our business and supply chains and is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Slavery and Human Trafficking statement for the financial year ended 31 December 2023.
Business Structure
Since inception, CHBL has primarily been a specialist consolidator of non-life general insurance and reinsurance companies and portfolios in run-off. In 2023, CHBL took the strategic decision to commence underwriting life reinsurance within certain narrowly defined and carefully chosen business lines.
The Catalina Group is incorporated in Bermuda and currently has offices and employees in Bermuda, United Kingdom, United States of America and Asia. The Catalina Group is subject to a group supervision framework where the Bermuda Monetary Authority (“BMA”) acts as Group Supervisor.
Catalina is committed to preventing slavery and human trafficking occurring in any of its corporate activities. Our services are delivered to our policyholders, other Catalina Group companies and third parties and our commitment is to ensure that those organisations with whom we contract to receive goods and services are aware of our policies in order to comply with this statement.
Supply Chains
The business of the Catalina Group is primarily focused on the administration and handling of claims for run-off underwriting business, which is a regulated financial services activity. Accordingly, our supply chains are limited, and our key vendors include professional services firms (such legal, accounting and other consulting firms), software and information technology services and banking services. We outsource some functions relating specifically to the support of claims activities to reputable professional firms, many of whom are regulated by a local insurance regulator.
No business is pursued or conducted with any organisation, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour. As part of our process of selecting new suppliers and business partners, due diligence is carried out that includes a risk assessment of their approach to ethical matters including a review of policies and procedures to avoid modern slavery and human trafficking.
The Board of CHBL believes that although our business model presents a low-risk of exposure to slavery or human trafficking, legal and regulatory obligations are met wherever we operate and the same standards from all the parties with whom we contract and partner with are expected.
Policies relating to slavery and human trafficking
The Catalina “Flight Plan” sets out our core values, including the requirement that we adhere to the highest standards, choosing the right way over the easy way.
The following Catalina Group policies also support our commitment to working to influence and mitigate the risk of modern slavery in our organisation and supply chain, through ensuring that robust standards and processes are in place across our business to manage risks relating to our relationships with third parties:
• Anti-Bribery and Corruption Policy
• Anti-Money Laundering Policy
• Global ESG Policy
• Outsourcing Risk Management Framework
• Sanctions Policy
• Whistleblowing Policy
• Modern Slavery and Human Trafficking Policy
The Whistleblowing Policy encourages anyone (including directors, our employees, temporary personnel, contract personnel, suppliers and clients) to report in good faith any issues or concerns about how potential violation of human rights, legal or regulatory requirements and improper or unethical business practices such as fraud or bribery. These Catalina Group policies are also supported by additional policies and procedures at subsidiary level, including the UK Outsourcing Policy.
The policies are available to our workforce via our intranet sites and, where appropriate, colleagues complete annual training modules to ensure they understand their responsibilities.
Outsourcing
Catalina may outsource certain activities to support its business. Outsourced activities are subject to enhanced due diligence by Catalina.
Performance Indicators
Catalina aims to measure the performance of anti-slavery actions within the group which would include training and awareness of staff on modern slavery issues. The Whistleblowing Policy refers employees to the Whistleblowing hotline where they can report any issues or concerns they may have regarding slavery or human trafficking in our business or supply chains is reviewed and reported as appropriate.
People
We are an equal opportunities employer, committed to creating and ensuring a non-discriminatory and respectful working environment for our staff.
We make our people aware of our policies and of their employment rights in several ways, including through our intranet site and the company inductions. All employees are required to complete training on whistleblowing, which provides guidance on how to raise concerns in a secure and confidential way.
To date, through our formal channels of reporting there were no cases of human rights issues raised in 2023.
Next Steps
Catalina reviews its risks in relation to modern slavery and human trafficking to identify measures we can take as a business to prevent modern slavery occurring in our business and supply chain.
We intend to take the following additional steps:
1. Catalina will publish a new Group Code of Conduct which will reinforce the importance of the expected conduct in line with our values. Training will also be included alongside attestation of adherence as appropriate.
2. Catalina is implementing a new vendor management process to ensure our supplier onboarding process reflects our values as a business.
Statement Approval
This Statement has been approved by the Board of Directors of CHBL on behalf of the Catalina Group of companies on March 19, 2024. Catalina Worthing Insurance Limited, Catalina Services UK Limited and Catalina Holdings UK Limited also approved this statement on or around the same date.
