Modern Slavery and Human Trafficking

Phoenix Group Structure and Supply Chain

Phoenix Group is the largest specialist consolidator of heritage life assurance funds in Europe. Our main focus is on closed life fund consolidation where we specialise in the acquisition and management of closed life insurance and pension funds. We call this our Heritage business.

Alongside this, we have an open business which manufactures and underwrites new products and policies to support people saving for their future in areas such as workplace pensions and SIPPs. This open business is underpinned by a strategic partnership with Standard Life Aberdeen plc following our acquisition of Standard Life Assurance Limited in 2018. We also have a market leading brand - SunLife - which sells a range of financial products specifically for the over 50s market.

In total the Group has over 10 million policyholders and £240 billion of assets and we have operations in the United Kingdom, Ireland and Germany. The Group has five operating life companies which hold policyholder assets and a distribution business, SunLife.

The Group operates a highly outsourced operating model and the risk of modern slavery in our supply chain is considered low due to the nature of our business. However, this assessment does not give rise to complacency. The Group’s policies are targeted toward the prevention of modern slavery in our supply chain as well as our own business.

Phoenix Group Policies

Our employees continue to be subject to, and benefit from, a wide range of policies including, disciplinary, grievance, non-discrimination, remuneration and numerous 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.

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.

Our employees and suppliers are encouraged to speak out should they encounter any wrongdoing, including any concerns in respect of modern slavery. They are further supported by the Group’s Whistleblowing policy which provides a number of channels for concerns to be reported confidentially with appropriate action taken.

Service Provider Due Diligence

Our Due Diligence guidelines require that any potential suppliers with an annual turnover in excess of £36M have a published modern slavery statement and policy while those with an annual turnover below £36M provide a copy of their modern slavery policy for review prior to appointment.

These business relationships are then appropriately monitored, proportionally to their potential risk and, in 2018, the practise of conducting additional reviews whenever material changes which may enhance the risk of Modern Slavery are implemented was introduced.

Risk Assessment and Management

Contractual Improvements
In 2018 the group strived to ensure that any new supplier contracts contain express Modern Slavery and audit clauses to enable the Group to conduct a compliance audit in this area.

Risk Assessments
In addition to ensuring that all suppliers with an obligation to do so publish a modern slavery statement, the Group utilises an external monitoring tool to regularly scrutinise our supply base for any indications that action to prevent modern slavery would be required.
Throughout the year, none of the supplier reviews conducted raised any concerns that Modern Slavery was prevalent within our supply chain.

Objectives for 2019

We are never complacent. We will continually review and refresh our risks and assessments in relation to modern slavery and human trafficking as part of our established risk universe; both as an employer and a purchaser of goods and services. In this context, in 2019 we will:

• Consolidate our policies, controls and approach to tackling modern slavery in light of the acquisition of Standard Life Assurance Limited
• Consider the application of enhanced reporting tools for monitoring adherence to the Modern Slavery Act within our supply base
• Consider the implementation of a programme of audits for suppliers where the risk may be considered high

Annual Review
The Phoenix Group will continue to conduct an annual review of this Statement and the actions it takes to combat all forms of modern slavery internally and within its supply chain.

Clive Bannister

Group Chief Executive Officer

Phoenix Group

This is a Group statement. For clarity, all companies addressed by the statement are listed below: