Slavery and Human Trafficking Statement

Whilst AXA – Global Healthcare is not legally required under the UK Modern Slavery Act 2015 to publish an annual modern slavery statement; the Board of AXA – Global Healthcare is voluntarily publishing this statement as evidence of its commitment to combatting and preventing slavery and human trafficking within the organisation and its supply chains.

The AXA Group has a long history of adhering to and promoting strong professional ethics and is committed to conducting its business according to the highest standards of honesty and fairness. This commitment to observing such ethical standards is designed not only to ensure compliance with applicable laws and regulations in the various jurisdictions where AXA operates but also to earning and keeping the continued trust of its clients, shareholders, personnel and business partners. AXA believes that its success and reputation is not only dependant on the quality of its products and the services provided to its clients, but also on the way it does business.

Engagements and policies in relation to modern slavery and human trafficking

The AXA Group is committed to respecting internationally recognised human rights principles as defined by the United Nations Universal Declaration of Human Rights, the core standards of the International Labour Organisation and the Guiding Principles for the implementation of the United Nations “Protect, Respect and Remedy” Framework (Ruggie Principles). 

The AXA Group is also committed to applying international general and sector-specific standards such as the UN Principles for Responsible Investment, the UN Principles for Sustainable Insurance and the UN Global Compact (“UN GC”). Since 2003, AXA adheres to the UN GC and has formally committed to promoting its ten guiding principles, including those on human rights (such as avoiding complicity in human rights abuses and supporting and respecting the protection of internationally proclaimed human rights) and labour standards (such as supporting the elimination of all forms of forced and compulsory labour and the effective abolition of child labour).

In addition, the AXA Group has put in place policies to support its commitment to ethical business practices across the organisation. These include: 

• The AXA Group Human Rights Policy¹, which aims to ensure that (i) the Group does not cause or contribute to adverse human rights impacts and (ii) such impacts are addressed when they occur. The policy also sets out AXA’s commitment to identify, prevent and/or mitigate adverse indirect human rights impacts that are linked to its operations or services, through its business relationships or projects it has invested in or insured. 
• The AXA Group Compliance and Ethics Guide² (the “Guide”) , which establishes guiding principles and Group-wide policies designed to ensure that all AXA Group companies and their personnel have a common vision of the Group’s ethical standards (including the UN GC principles on human rights, labour standards, environment and anti-corruption) and operate in accordance with those standards. All AXA employees are encouraged to report promptly any practices, actions or conduct that they believe are inappropriate or inconsistent with any of the policies set out in the Guide through their local whistleblowing procedures. Senior officers of AXA entities are asked to submit an annual certification to confirm that they comply with all the provisions set out in the Guide

Management of the modern slavery and human trafficking risk in the company’s operations

AXA acknowledges its responsibility to respect human rights in its operations and conducts its business in compliance with applicable employment regulations in the jurisdictions in which it operates. The AXA Group Compliance and Ethics Guide sets out protections for AXA’s employees and their rights, in particular, it emphasises that: 

• AXA is committed to upholding the right of freedom of association and collective bargaining, as well as maintaining constructive labour management relations in every country in which it does business, and to doing so with due respect for different national approaches to social dialogue;
• AXA respects the rights of its employees to enjoy just and favourable conditions of work, including health and safety protections, and is committed to providing adequate information and training on health and safety and wellbeing issues. 

In addition, AXA promotes diversity and inclusion by prohibiting any form of discrimination between current, past or prospective staff on the basis of age, race, nationality, ethnic origin, gender, sexual orientation, religion, marital status or disability through its Diversity and Equal Opportunities Policy.

Due diligence process in relation to the company’s supply chains

AXA ensures it works with suppliers that meet the AXA standards with respect to ethics and corporate responsibility through a clearly documented process for supplier selection and contracting. 

In accordance with such process, standard contractual terms with suppliers include specific reference to AXA’s corporate responsibility requirements, and suppliers are required to provide a formal commitment to uphold the core standards of the UN GC by signing AXA’s “Corporate Responsibility clause”. Notably, the suppliers agree to refrain from using or accepting that their own suppliers and sub-contractors make use of, child labour (under 15 years old) or forced labour.

Detection of a direct or indirect violation by the supplier of the AXA corporate responsibility requirements is discussed directly with the supplier with a view to establishing a mutually agreed and documented corrective action plan. Where any issue is not resolved satisfactorily, the Companies reserve the contractual right to end their relationship with the relevant supplier.

^{¹Available at https://www.axa.com/en/about-us/our-commitment-to-human-rights} 

^{²Available at https://www.axa.com/en/newsroom/publications/compliance-ethics-guide}