Modern Slavery and Human Trafficking Statement


The Modern Slavery Act ("MSA") came into force in the united Kingdom in 2015 requiring large organisations doing business in the UK to produce a "Slavery and Human trafficking" statement. The Act applies to both organisation subsidiaries and the parent organisation if they carry on a business or part of a business in the UK.

This Statement relates to the steps that Cardif Pinnacle has taken to ensure that slavery and human trafficking are not taking place in its direct operations or supply chains. The Board and the CEO attest annually that Cardif Pinnacle complies with this Statement through the information provided by the business.

Introduction

Cardif Pinnacle is the trading name of Pinnacle Insurance PLC, a UK-based subsidiary of BNP Paribas Cardif, itself a subsidiary of BNP Paribas SA, a leader in global banking and financial services registered in France with a presence in 74 countries. As a global responsible investment bank, BNP Paribas seeks to be a contributor to responsible and sustainable global development. The bank's ambition is to have a positive impact on its stakeholders and on wider society. This is why the Group upholds the highest standard of conduct and ethics in areas of human rights, labour, environment and anti-corruption. As a subsidiary within the BNP Paribas Group, Cardif Pinnacle acknowledges its responsibility to comply with the UK Modern Slavery Act 2015 and is committed to driving out acts of modern day slavery and human trafficking within its business and supply chain, and expects the same from suppliers and partners. This commitment is in part based on the International Labour Organisation's fundamental principles of rights to work which we uphold, including:

     a) Elimination of forced and compulsory labour
     b) Abolition of child labour
     c) Elimination of discrimination in respect of employment and occupation.

This statement outlines the policies and procedures which Cardif Pinnacle has in place to mitigate and manage the potential risk of modern slavery and human trafficking in its operations and supply chains.

Policies

Cardif Pinnacle has reviewed its policies to ensure that modern slavery and human trafficking receives increased focus. We have developed a specific Modern Slavery policy which describes how Cardif Pinnacle intends to tackle any risks and deal with any issues related to modern slavery and human trafficking across its business and supply chains. It states that Cardif Pinnacle has a zero-tolerance approach to modern slavery and human trafficking. It further states that we are committed to act ethically and with integrity in dealing with our partners, suppliers and customers, and to implement systems and controls that effectively ensure modern slavery and human trafficking is not taking place anywhere in our business or that of our supply chain.

Other Group and Cardif Pinnacle policies are in place which also contribute to tackling modern slavery and human trafficking as part of our business operations. These include:
     - BNP Paribas Cardif Pinnacle Modern Slavery policy
     - BNP Paribas Cardif Pinnacle Whistleblowing Procedures
     - BNP Paribas Group Code of conduct
     - BNP Paribas Suppliers Code of Conduct
     - Statement of BNP Paribas on human rights

Identifying and managing risks

Cardif Pinnacle has carried out a detailed review with external advisors of its supply chains and procurement processes to identify where there may be risks of modern slavery or human trafficking. This showed that overall there is low risk as the company's activities do not directly involve operations where modern slavery or human trafficking are known to occur.

However, where some categories of products and services provided by third party suppliers present risks in their supply chains. We have identified those categories and shall carry out additional due diligence, including extending our supplier questionnaires to cover the risks of slavery and human trafficking and requesting information about the supplier's own policies and mitigation processes.

Suppliers will also be required to sign up to our code of conduct which prohibits forced or child labour and we will continue to embed clauses within our supplier contracts to ensure that the supplier signs up to and agrees with our policies in all legal contracts.

Employees and suppliers are encouraged to raise any concerns about any issues or suspicion of modern slavery within the Cardif Pinnacle business operations or any tier of our supply chain as soon as they become aware of it. Our whistleblowing procedure ensures that anyone raising such concerns may request that their disclosure is kept strictly confidential.

BNP Paribas and Cardif Pinnacle have extensive and rigorous risk management and compliance processes in place in the company. Modern slavery and human trafficking risk is included in these risk management and compliance processes, and will be managed and monitored on an ongoing basis by the company's risk function in conjunction with other relevant business functions.

Awareness and Training

As part of Group-wide compliance processes, a human rights training course is available to BNP Paribas Cardif Pinnacle employees to raise awareness of how human rights issues, including modern slavery and human trafficking, may impact BNP Paribas' business operations and what role employees play in mitigating the risk. Staff involved in procuring products and services in those categories where there is a potential supply chain risk shall be provided with additional guidance and training.

This statement is owned by the Executive Management Team and approved by the Board of Directors. It is reviewed annually and published on the Cardif Pinnacle website.

Date: 27/07/2017