• Modern Slavery and Human Trafficking

    The Phoenix Group remains committed to addressing modern slavery, servitude, forced labour; and human trafficking in all its forms and carrying out our business in a fair, honest, ethical and open manner. The Group’s Sourcing and Procurement Policy requires that all resources understand all potential modern slavery and human trafficking risks related to our business and we ensure that we have systems and controls in place to prevent these risks from occurring in our business and/or in our supply chains. In addition, the Group operates a number of employee policies to address the risk of modern slavery and human trafficking within our business.

    As required by the Modern Slavery Act 2015 (the “Act”), this statement describes the steps that the Phoenix Group has taken during the financial year ended 31 December 2018 to prevent modern slavery from taking place in our supply chains and within our own business.

  • 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 

    Clive Bannister

    Group Chief Executive Officer

    Phoenix Group


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

    Name Country
    CRN
    28 Ribera del Loira
    ES
    A82228073
    3 St Andrew Square Apartments Limited
    GB
    SC108543
    330 Avenida de Aragon SL
    ES
    B82829391
    Abbey Life Assurance Limited
    GB
    710383
    Abbey Life Trust Securities Limited
    GB
    843568
    Abbey Life Trustee Services Limited 
    GB
    1451364
    Alba LAS Pensions Management Limited
    GB
    SC060928
    Alba Life Trustees Limited
    GB
    SC31475
    Axial Fundamental Strategies (US Investments) LLC
    US
    4386668
    Britannic Finance Limited
    GB
    3588089
    Britannic Money Investment Services Limited
    GB
    2171236
    CH Management Limited
    US
    4762852
    G Park Management Company Limited
    GB
    06878047
    Gallions Reach Shopping Park (Nominee) Limited
    GB
    05777118
    Hundred Sari
    LU
    B 165972
    Iceni Nominees (No. 2) Limited
    GB
    04266393
    IH (Jersey) Limited
    JE
    109362
    Impala Holdings Limited
    JE
    6306909
    Inesia SA
    LU
    B66 931
    Inhoco 3107 Limited
    GB
    5188136
    Lake Meadows Management Company Limited
    GB
    02467063
    Lothian Developments III (Nederland) B.V.
    NL
    33305403
    Mutual Securitisation plc
    IE
    276735
    National Provident Institution
    GB
    ZC000065
    National Provident Life Limited
    GB
    3641947
    NP Life Holdings Limited
    GB
    3725026
    Opal Reassurance Limited
    BM
    39187
    Pearl (WP) Investments LLC
    US
    4299734
    Pearl Assurance Group Holdings Limited
    GB
    3245996
    Pearl Group Holdings (No. 1) Limited
    GB
    3524909
    Pearl Group Holdings (No. 2) Limited
    GB
    5282342
    Pearl Group Management Services Limited
    GB
    3588063
    Pearl Group Secretariat Services Limited
    GB
    3588041
    Pearl Group Services Limited
    GB
    5549998
    Pearl Life Holdings Limited
    GB
    4560778
    PGH (LC1) Limited
    GB
    6308404
    PGH (LC2) Limited
    GB
    6308409
    PGH (LCA) Limited
    GB
    5257400
    PGH (LCB) Limited
    GB
    5282338
    PGH (MC1) Limited
    GB
    6386849
    PGH (MC2) Limited
    GB
    6386851
    PGH (TC1) Limited
    GB
    6386847
    PGH (TC2) Limited
    GB
    6386846
    PGH Capital Public Limited Company
    IE
    537912
    PGMS (Glasgow) Limited
    GB
    SC159852
    PGMS (Ireland) Holdings Unlimited Company
    IE
    341950
    PGMS (Ireland) Limited
    IE
    342705
    PGS 2 Limited
    GB
    3725038
    Phoenix AW Limited
    GB
    1225468
    Phoenix Customer Care Limited
    GB
    3315193
    Phoenix ER1 Limited
    GB
    10196658
    Phoenix ER3 Limited
    GB
    10844152
    Phoenix ER4 Limited
    GB
    11121610
    Phoenix ER5 Limited
    GB
    11720413
    Phoenix Group Holdings
    KY
    202172
    Phoenix Group Holdings plc
    GB
    11606773
    Phoenix Life Holdings Limited
    GB
    6977344
    Phoenix Pension Scheme (Trustees) Limited
    GB
    1912908
    Phoenix SCP Limited
    GB
    4013361
    Phoenix SCP Pensions Trustees Limited
    GB
    2404622
    Phoenix SCP Trustees Limited
    GB
    SC108046
    Phoenix SL Direct Limited
    GB
    586343
    Phoenix Wealth Holdings Limited
    GB
    3223752
    Phoenix Wealth Trustee Services Limited
    GB
    2155360
    Scottish Mutual Assurance Limited
    GB
    SC133846
    Scottish Mutual Pension Funds Investment Limited
    GB
    SC61343
    SL (NEWCO) Limited
    GB
    SC297006
    SLA Belgium No. 1 SA
    BE
    BE0638.954.836
    SLA Germany No. 2 S.a.r.l.
    LU
    B198324
    SLA Germany No. 3 S.a.r.l.
    LU
    B199656
    SLA Germany No. 1 S.a.r.l.
    LU
    B186141
    SLA Ireland No. 1 Sarl
    LU
    B191411
    SLA Netherlands No. 1 B.V.
    NL
    60700793
    SLACOM (No. 10) Limited
    GB
    SC271362
    SLACOM (No. 8) Limited
    GB
    SC271358
    SLACOM (No. 9) Limited
    GB
    SC271360
    SLIF Property Investment GP Limited
    GB
    SC388872
    Standard Life Agency Services Limited
    GB
    SC170047
    Standard Life Assets and Employee Services Limited
    GB
    SC593510
    Standard Life Assurance (HWPF) Luxembourg S.a.r.l.
    LU
    B186108
    Standard Life Assurance Limited
    GB
    SC286833
    Standard Life International dac
    IE
    408507
    Standard Life Investment Funds Limited
    GB
    SC068442
    Standard Life Lifetime Mortgages Limited
    GB
    SC193441
    Standard Life Master Trust Co. Limited
    GB
    09497864
    Standard Life Pension Funds Limited
    GB
    SC046447
    Standard Life Private Equity Trust plc
    GB
    SC216638
    Standard Life Property Company Limited 
    GB
    SC101362
    Standard Life Trustee Company Limited
    GB
    SC076046
    Sunlife Limited
    GB
    5460862
    The Heritable Securities and Mortgage Investment Association Limited
    GB
    SC000668
    The Pearl Martineau Galleries Limited Partnership
    GB
    LP006989
    The Pearl Martineau Limited Partnership
    GB
    LP006988
    The Standard Life Assurance Company of Europe BV
    NL
    33.272.024
    UK Commercial Property Estates Holdings Limited
    GG
    52248
    UK Commercial Property Estates Limited
    GG
    53361
    UK Commercial Property Finance Holdings Limited
    GG
    60016
    UK Commercial Property GP Limited
    GG
    45385
    UK Commercial Property Holdings Limited
    GG
    45386
    UK Commercial Property Nominee Limited
    GG
    45400
    UK Commercial Property REIT Limited (formerly known as UK Commercial Property Trust Limited)
    GG
    45387
    UK CPT LP
    GG
    709
    Vebnet (Holdings) Limited
    GB
    00792165
    Vebnet Limited
    GB
    SC207389
    Welbrent Property Investment Company Limited
    GB
    04617102
    Castle Hill Credit Opportunities Holdings Limited
    GB
    48883
    The Moor House Limited Partnership
    GB
    LP004819
    Moor House General Partner Limited
    GB
    4130878