Learn more about our:
Modern Slavery Statement and Policy
Our Modern Slavery Statement
Last Updated: 1 July 2021
To read our latest Marsh McLennan Modern Slavery Statement, please download a copy here.
Our Modern Slavery Policy
Last Updated: 1 July 2020
This Policy operates in Australia and covers Marsh Pty Ltd and its related entities (“Marsh”). It complements Marsh’s code of conduct, The Greater Good, which sets out the standards weexpect of our colleagues and business partners.
Modern slavery can occur in various forms, including forced or compulsory labour, discriminatory employment practices, human trafficking, debt bondage or bonded labour, or child labour.
We are committed to conducting our activities fairly, honestly and with integrity, in accordance with the applicable laws. We do not tolerate modern slavery in any part of our business, or in the business of our upstream or downstream business partners. We are committed to ensuring that these type of activities do not take place in our supply chains.
How do we identify Modern Slavery Risks?
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all colleagues working for Marsh. Colleagues are required to avoid any activity which might lead to a breach of this Policy.
If you believe or suspect that slavery is occurring, you must notify your manager as soon as possible, or report the matter via ethicscomplianceline.com.
If you are unsure whether a particular act, the treatment of workers or their working conditions may constitute modern slavery, you should still raise the matter so that it can be investigated.
We aim to encourage openness. We will not tolerate retaliation against any colleague who raises a concern in good faith as a result of reporting their suspicion that modern slavery may be taking place in our business or supply chains.
Members of the public or people not employed by Marsh should write to: The Chief Compliance Officer, Marsh Pty Ltd, One International Towers Sydney, 100 Barangaroo Avenue, Sydney NSW 2000 or email email@example.com to raise any concern or suspicion of modern slavery in any part of our business or related supply chain.
How do we enforce the Policy?
If an issue is identified in the business of our upstream or downstream business partners, we will work with them to prepare a corrective action plan and resolve the matter within an agreed timeframe.
We reserve the right to terminate commercial relationships with any business partner if they are found to be involved in modern slavery.
Any colleague who breaches this Policy will face disciplinary action which could result in dismissal for misconduct.
How do we raise awareness of this Policy?
A copy of this Policy is available on our website and on our internal intranet pages for colleagues.
General awareness training is provided to all colleagues when they join Marsh.
Those colleagues closely involved in recruitment and procurement are trained in this Policy.
Our approach to modern slavery must be communicated to all our upstream or downstream business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Who is responsible for the Policy?
Responsibility for this Policy rests ultimately with the Board of Directors of Marsh Pty Ltd.
Managers at all levels are responsible for ensuring those reporting to them not only understand but also comply with the Policy.
Product Development & Distribution Policy
This Policy sets out the JLT Risk Solutions Pty Ltd (JLT) approach to developing and distributing retail insurance products for its appropriate target markets where JLT is acting on behalf of insurers. This Policy aims to support JLT’s customer focussed approach by aiming to provide our customers with products that are consistent with their likely objectives, financial situations and needs.
To ensure our design and distribution obligations are met, our customers’ needs will remain at the centre of our product lifecycle including:
1. The product design stage;
2. The product delivery stage;
3. The product review stage; and
4. The product modification or decommission stage.
In further supporting this objective, JLT will have in place Target Market Determinations (TMDs) which will guide the distribution of our products for appropriate target markets. These TMDs will be available on JLT’s and/or the relevant insurer’s website for all relevant products from 5 October 2021.
2. Product Design
The first stage of a product’s lifecycle is the design stage. JLT is committed to ensuring our products are designed so as to be consistent with the likely objectives, financial situations and needs of our customers for whom they are intended.
We recognise that we have a range of customers with different complex and multifaceted interests that should be considered in the development and design of our products.
When new products are developed or our current products are updated, we will start by assessing the likely objectives, financial situations and needs of the target market. This assessment may include:
- market research and feedback to assist us in understanding the customers likely objectives;
- needs analysis of internal and external data, industry data and other metrics; and
- our own experience and expertise.
From 5 October 2021, TMDs will be available for retail products describing the type of customers comprising the target market for the insurance product.
3. Product Delivery
After a product has been appropriately designed, the product will be assessed to ensure that we identify the distribution channels and arrangements that are reasonably likely to result in our products reaching consumers in the target market.
We will take all reasonable steps to ensure our retail products are distributed in accordance with the TMDs including: assessing the most appropriate distribution channels for each individual product; setting distribution conditions that our distributors must follow including distribution in line with TMDs; obtaining information about the distribution from distributors; customer feedback and taking appropriate action in response; and adherence to our regulatory requirements.
4. Product Design and Delivery Review
Regular reviews will take place to ensure that our retail products are operating the way they were designed to operate and that they continue to meet our customers’ needs. Regular reviews are also important to ensure our products are distributed in a way that is likely to reach our designated target market.
Product reviews may include measuring complaints, customer feedback and other claims data and market conditions whilst also drawing on the experience of our own staff.
Commencing from 5 October 2021, product design and delivery reviews may also occur in response to TMD review triggers.
5. Product Modification or Decommission
Following a product review, it may be assessed that the product or its distribution channel require modification to ensure they remain consistent in achieving the likely objectives, financial situation and needs of our customers.
Our products may also require modification in response to regulatory changes. If following a review it is identified that a product is not delivering customer value and cannot be enhanced or distributed in a manner consistent with achieving the likely objectives, financial situation and needs of our customers, it may be decided that the product be decommissioned.
This Policy has been developed by JLT in conjunction with Marsh Legal, Compliance & Public Affairs team and will be reviewed on an annual basis or as required.
Date of next review: 1 July 2022
JLT Product Development and Distribution Policy v.1.0.