As a global insurer and reinsurer with diverse and complex operations and supply chains, we recognise that we have the potential to negatively impact human rights, causing harm to individuals and communities. Any actual, or potential, violation of human rights is likely to have multifaceted risk consequences, such as reputation, brand, financial, legal, regulatory and operational risk. QBE rejects any form of slavery and takes measures to prevent modern slavery risk across our operations and supply chain.
Our Group Human Rights Policy provides an overview of how QBE manages a range of sensitive human rights topics across the business as part of our existing policies, procedures, frameworks and decision making.
Read our Group Human Rights Policy
The Group Board oversees human rights and modern slavery-related issues at QBE in line with our broader approach to sustainability.
Across QBE, various teams are responsible for integrating human rights and anti-modern slavery considerations across the business. Our Group Sustainability team works collaboratively with the Group ESG Risk, Group Impact and Responsible Investments, Group Chief Underwriting Office, Group Third-Party Risk Management, Group Legal and Group People teams to effectively consider and embed human rights and reduce modern slavery risks across our operations and processes. Further information about sustainability governance can be found here.
Integrating human rights into our core business
At QBE, we are committed to continually improving our employee experience, wellbeing, safety, and workplace environment, wherever our people are located. We strive for a culture that embraces diversity, seeks feedback, and encourages people to speak up. Building a culture that supports and enables us to achieve our purpose, vision and strategy is a strategic priority for our business.
We provide our employees with training, education and online resources on discrimination and appropriate workplace behaviour consistent with our Group Code of Ethics and Conduct. Consistent with local employment laws, across our global operations, 28.9% of our employees are covered by collective bargaining agreements. All our employees have the right to freedom of association.
As a signatory to the PSI, we take an active approach to risk management. We continually work to integrate sustainability, and to address current and emerging ESG risks (such as modern slavery risk) and opportunities, in our decision-making processes. Our Group Underwriting Standards (GUS) continue to support our commitment to responsible underwriting.
Our Environmental and Social Risk Framework outlines our position on sensitive sectors requiring minimum due diligence processes or revised risk appetites and strategies. These sectors were identified based on a risk mapping of key environmental and human rights risks in our underwriting and investment portfolios. Where possible, we encourage our customers to adhere to best practice risk management practices in their business activities.
We continue to embed human rights considerations in our investment portfolio strategy. We consider material ESG factors, such as modern slavery and human rights issues, into investment analysis and decision-making. All investment grade corporate credit issuers must meet relevant criteria set out in our E&S Risk Framework, Group Sanctions Policy and Group Human Rights Policy. We integrate ESG into the credit analysis process through our internal, proprietary credit assessment framework that identifies suitability and eligibility for our portfolio.
We broadened our due diligence questions to consider an additional 14 data points on human rights and modern slavery in order to determine the level of risk exposure an investee might have. Updated focus areas included policies, controversies, labour standards, and diversity, equity and inclusion, informed by data sourced from our third-party data provider.
As part of the implementation of our Group Human Rights Policy, we incorporated additional human rights-focused questions for all our external managers, in both the selection and ongoing monitoring process. Our methodology produces a quantitative indicator score of how our external fund managers are implementing responsible investment practices and approaching key ESG areas. This allows us to understand our exposure to ESG risks and opportunities and informs our engagement approach, with the aim of achieving impactful real-world outcomes.
The QBE Foundation seeks to create strong, resilient, and inclusive communities across the globe where human rights are respected. We work in partnership with community organisations, guided by our global strategy, with a focus on climate resilience and inclusion - two areas where we believe we can have the greatest impact.
Our Global QBE Foundation Terms of Reference helps guide the governance, strategy and activities of the Foundation. This specifically references our Group Human Rights Policy, including the need for our divisional teams to conduct due diligence processes for new community partnerships as we enter into agreements to consider human rights risks. Our Group Human Rights Policy and Supplier Sustainability Principles are shared with our partners as part of the partnership onboarding process. Further information about our work in the community can be found on our QBE Foundation page.
QBE aims to mitigate any potential adverse impacts arising from our operations by taking appropriate action, including the leveraging of our business relationships. In 2023, we reviewed our Supplier Sustainability Principles (SSPs) and will replace this with the Supplier Code of Responsible Conduct (Supplier Code). The Supplier Code will be formally rolled out across the business in 2024. The SSPs set out QBE’s minimum expectations of our suppliers which includes prohibiting human trafficking, slavery, servitude, debt bondage, forced or involuntary labour or child labour within their own supply chains and practices. Moving from a principles-based document to a Supplier Code will reinforce QBE’s commitment to managing modern slavery risks in our supply chain.
QBE’s Third-Party Risk Management (TPRM) Policy and Minimum Standards provide a consistent framework across our enterprise to conduct third party risk assessments covering a range of risk domains such as modern slavery, privacy, conduct risk, and financial crime risk.
For the modern slavery risk domain, risk assessments occur prior to onboarding and are repeated periodically, giving us visibility of potential modern slavery risks in our supply chain. Our modern slavery risk assessment process requires suppliers that are found to operate in both a high-risk sector and a high-risk geography to complete a further, more detailed modern slavery risk assessment. This assessment informs our understanding of the control procedures that they have in place to identify and mitigate modern slavery risks within their operations or within their own supply chains. It helps us to determine whether we can work with the supplier and if any remedial action may be required before we do. For further insight into our supply chain due diligence, refer to our annual Modern Slavery and Human Trafficking Statement.
We have a voluntary online human rights training module which is available for any employee to complete. To date, we have delivered specific training to employees in the operational areas that we identified as having direct responsibility or contact with our supply chains. These teams include people in our Risk, Compliance, Corporate Affairs & Sustainability, and Procurement teams.