Modern Slavery
Statement2023

Admiral Group Modern Slavery Statement I Modern Slavery Statement 2023

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Admiral Group Modern Slavery Statement
2023
This statement has been published in accordance with the Modern Slavery Act
2015. It also follows the guidance as set within the Home Office’s “Transparency inSupply Chains: A Practical Guide” document and utilises the framework as
described within the Ethical Trading Initiative’s Modern Slavery Framework. The
statement sets out the steps taken by Admiral Group Plc and other relevant groupcompanies [1] (‘Admiral’ or ‘Group’) during the year ending 31 December 2023 toprevent modern slavery and human trafficking in its business and supply chain.

Admiral Group’s purpose is to “Help more people to look after their future.
Always striving for better, together.” Admiral looks to do the right thing, and thisincludes the approach to modern slavery. Since the publication of the firstModern Slavery Statement in 2017, the business has continued to follow a zerotolerance approach to modern slavery in all forms. Admiral seeks to inform all
members of staff of modern slavery risks across all areas of the business andprovide them with the tools and platforms to report concerns. Continued
commitment to the prevention and termination of modern slavery is championed
through Admiral’s robust approach, policies, training, and risk management.
[1] This statement sets out the steps taken by Admiral Group plc, Admiral Insurance Company Limited, EUI Limited, and Admiral
Financial Services Limited, all of which fall within the scope of section 54(2) of the Modern Slavery Act 2015 and the Modern Slavery
Act 2015 (Transparency in Supply Chains) Regulations 2015. Admiral subsidiaries that are not required to comply with the requirements
are required to follow Group guidance.

Admiral Group Modern Slavery Statement I Modern Slavery Statement 2023

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Admiral Group supports the aim of the Modern Slavery Act 2015
and seeks to ensure that modern slavery and human trafficking
does not feature in any form across the business and supply
chain. The Group recognises that modern slavery can occur invarious forms. Admiral defines modern slavery in accordance with
the Modern Slavery Act 2015 in that it encompasses servitude,
forced or compulsory labour, child labour, exploitation, being
controlled by an employer, debt bondage, being physicallyconstrained, being sold or treated as a commodity, having
restrictions on freedom of movement and human trafficking inorder to exploit them for personal or commercial gain, all ofwhich constitute an offence under the Act.

Our progresssince 2022's
Statement
The business has continued totake positive strides towards
evolving and strengthening its
approach to the prevention ofmodern slavery in 2023 and has
made progress in several areas.

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As always, Admiral has continued to monitor any risks or breaches related tomodern slavery within the business and its supply chain. The business is pleased toreport that no breaches were made in EUI (the largest Admiral Group business) in
2023.
The Due Diligence Questionnaire (DDQ) process and questions have undergoneenhancements, focusing more directly on modern slavery. These refined questions
delve into finer details, bolstering Admiral’s ability to effectively manage risks
across the supply chain. As the landscape evolves, Admiral remains vigilant,
committed to staying abreast of changes and continuously refining inquiries
accordingly.
Continuous improvements have been made to improve data and reporting
capabilities to spot trends and risks quickly and to respond appropriately.
Continued monitoring and adaption to due diligence, the risk assessment andsupply chain risk controls, are key building blocks for this, providing far more data.
These changes allow quicker identification of risks across the supply chain, in turnimproving speed of reporting capabilities, with the view to develop andcustomise a comprehensive suite of reports.
The Supplier Working Group (SWG), led by the Head of Procurement, has taken
proactive steps to raise awareness about Modern Slavery among attendees.
Going forward, quarterly reports on Modern Slavery, inclusive of whistleblowing
instances, identified risks, and pertinent activities, will be reviewed by the group.

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Dip checks were undertaken across Admiral’s Strategic andCritical Supply chain to review DDQ Modern Slavery
Responses, confirming compliance with the Modern Slavery
Act reporting requirements. A follow up set of checks acrossthe lower risk key supplier population have revealed areas
for improvement, prompting initiatives to potentially provide
training or alignment to Admiral’s policies and statements.
Internal staff training remains a priority, mandatory for all
current and new employees, with an annual completion
requirement. Presently, 96.6% of staff have fulfilled thisobligation, ensuring a high level of awareness andcompliance throughout the organisation.
Admiral has submitted its Modern Slavery Statement to thevoluntary Slavery Registry service to continue to promotevisibility.

Our organisation,
structure andsupply chain
Admiral Group Plc is the holding
company for a group ofcompanies providing insurance
and ancillary products andservices. As of 31 December
2023, the business has around
13,500 employees and nearly 10
million customers worldwide.

Our organisation, structure and supply chain I Modern Slavery Statement 2023

Our employee headcountand % per location

Admiral operates principally, and isincorporated, in the UK. The
business is also licensed tounderwrite insurance in Europe andthe United States of America. The
Group has offices in multiple
countries across the world (UK, USA,
Canada, France, Italy, Spain, andIndia) and is listed on the London
Stock Exchange.
All companies within Admiral Groupare regulated insurance or service
companies or provide ancillary
services to our insurance activities.
Further details about Admiral’s
structure can be found on our
website (Admiral Group).

8665 (64%)
832 (6%)2070 (15%)
601 (4%)521 (4%)446 (4%)423 (3%)7

Our approach, policies
and contractual controls
Admiral Group is fully committed to running theorganisation in a responsible and ethical manner.
Whether it be through its comprehensive
recruitment processes, procurement of service
activities, training and support, Admiralendeavour’s to continuously monitor any potential
risks of modern slavery in the business and supply
chain, to identify issues before they occur andtake swift and effective steps to ensure all staff
share a collective responsibility towards theeradication of any potential issues.

Our approach, policies and contractual controls I Modern Slavery Statement 2023

Recruitment
Admiral’s recruitment processes involve several background checks
which include identification validation, financial history information,and references along with an individual’s right to work status.
Members of staff are also allocated working patterns and hours
relevant to their role.
Admiral Group currently trades between 8am and 10pm Monday to
Friday, 9am to 8pm on Saturday and 10am to 8pm on Sunday. We arealso open on public holidays except for Christmas Day, Boxing Day
and New Year's Day. To meet the demands of our customers eachdepartment operates its own shift system. If an employee works in a
department that operates outside Admiral Group trading hours, they
will have specific working hours stated in their offer letter or on acompany change of hours form.
Admiral ensures that the cost of recruitment is not passed onto
employees whether they are recruited within the UK or overseas. Costof recruitment, interviews and training is fully paid for by AdmiralGroup.

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Our approach, policies and contractual controls I Modern Slavery Statement 2023

Procurement
Admiral functions as a purchaser, acquiring goods and services tosupport its team and customers. Admiral expects suppliers not only tofacilitate transactions but also to share Admiral’s strong commitment
against modern slavery, both within their own operations andthroughout their supply chain.
To uphold ethical standards, Admiral Group routinely assesses the riskof modern slavery across its supplier network. This ongoing evaluation
is a proactive approach to identify and address potential issues,ensuring that our supply chain aligns with our values and actively
works towards eliminating modern slavery.

Training
Admiral Group is proud to offer an extensive platform in which totrain colleagues on all aspects of modern slavery and, crucially, what
to do if they suspect its existence in any part of our business or supply
chain. Modern slavery training is mandatory for all staff as part oftheir annual compliance training schedule.

10Our approach, policies and contractual controls I Modern Slavery Statement 2023

Processes
Admiral also provides all staff with the tools and processes that allow
them to highlight any modern slavery concerns within our day-to-day
operations. Furthermore, we ensure that management have the tools
and confidence to act upon any reports of modern slavery swiftly.
Admiral employs several internal policies which to drive efforts
against all types of modern slavery. Such policies include.
·
·
·
·
·
·
·

General Standards of Conduct
Anti-Fraud and Suspicious Events Policy
Anti-Bribery Policy
Financial Crime Policy
Equality, Diversity and Dignity at Work Policy
Procurement Policy
Anti-Slavery, Exploitation and Human Trafficking Policy

These policies look to equip all staff with the knowledge andguidance needed to have a shared responsibility for theidentification of modern slavery. Final responsibility for the preventionof modern slavery sits with the Admiral Group Board with delegation
to our Group Procurement department.

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Our approach, policies and contractual controls I Modern Slavery Statement 2023

Anti-slavery, exploitation andhuman trafficking policy
Specifically, Admiral’s Anti-Slavery, Exploitation and
Human Trafficking Policy, which was released in 2017,highlights its shared responsibility in the prevention ofmodern slavery and the steps taken to report any
concerns. The policy, found clearly within its internal
employee handbook, provides more information onmodern slavery and informs colleagues to notify
appropriate individuals if they have any concerns
regarding modern slavery. Admiral also includes
information should any colleague wish to use theWhistleblowing Policy. Finally, the Modern Slavery
Helpline number is signposted for use by allcolleagues.

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Whistleblowing policy
Admiral Group also has a comprehensive Whistleblowing
Policy that is visible to everyone internally in its employee
handbook and further signposted from our chatbot function. It
clearly outlines why such a policy is important within thecompany and lists 10 potential areas of concern that may
guide colleagues if they wish to highlight any issues. The policy
details the steps taken after a disclosure is made and remains
transparent as to who in the company will receive notifications
about concerns. Colleagues are given information such as aninternal and external telephone number to raise concerns
along with an email address. In 2023, there were no
whistleblowing reports of modern slavery.
Any reports are fully investigated by a small specialist teamand actions are taken when appropriate such as notifying theauthorities. A record is maintained of Whistleblowing issues
and where appropriate reported to the regulators.

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Procurement policy
Admiral places a strong emphasis on maintaining a meticulous Procurement Policythat not only aligns closely with the Chartered Institute of Procurement and Supply
Code of Conduct but also establishes the essential minimum standards for all
procurement activities conducted within the United Kingdom. This policy
underscores the pivotal role of staff members in promoting the eradication ofunethical business practices by diligently managing business relationships andconducting due diligence to identify and address potential modern slavery risks
during procurement activities.
Admiral’s commitment to ethical business practices and the mitigation of modern
slavery risks is reflected in the explicit incorporation of these principles within its
policies. These policies are effectively communicated to colleagues throughvarious channels, including the employee handbook, intranet and mandatory
yearly training ensuring widespread awareness and understanding.
Acknowledging the inherent challenges posed by increased demand for supplierservices, often coupled with financial pressures, Admiral proactively addresses thisissue within our procurement framework. Given the nature of its business, where
procured services are often reactive to claims frequency and policy book size,
Admiral recognises the potential strain on suppliers. In response, incorporation ofprompt payment schemes into supplier contracts have been undertaken. These
negotiated schemes are designed to not only alleviate financial pressures but also
ensure that payments are made promptly, fostering fair and transparent financial
relationships across Admiral’s supply chain. This proactive approach demonstrates
commitment to ethical procurement practices and responsible suppliermanagement.

Risk assessment &due diligence
Admiral Group provides
insurance and financial products
as well as ancillary products to
consumers and as a result, theevaluated risk of modern slavery
in the business is low.

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The Global Slavery Index places most of Admiral Group’s business locations towards the lower risk
end of the ranking of estimated prevalence of modern slavery [2]. However, Admiral does haveoffices in India. According to the Global Slavery Index India is higher in vulnerability and prevalenceof modern slavery. The key areas highlighted as vulnerable are Governance issues, lack of basic
needs, inequality, disfranchised groups and effects of conflict.
Admiral Indian operations contains 15% of the workforce, who have been referencing complianceagainst the UK Modern Slavery Act and associated Indian Bonded Labour and Child Labour, Sexual
Harassment of Women at Workplace (Prevention, Prohibition and Redressal) in all its contracts since2020. There have been no Modern Slavery breaches identified in 2023 within the India operations.
From a colleague perspective, all of Admiral’s staff either work within one of its offices or from theirhomes, with our approach to hybrid working since the pandemic. In addition, there are mechanisms
in place within the business to prevent modern slavery and ensure adequate visibility and training, as
mentioned in the previous section.
Hence, any risk relating to modern slavery that can be found within the Group is more likely to exist
within Admiral’s supply chain who provide services in various forms. Admiral takes our responsibility
towards ethical working conditions seriously and employs several measures to evaluate and monitor
suppliers across the Group. Within this context, Admiral Group has delegated day-to-day policy
implementation operations to its Group Procurement department, which allows for a higher level ofoversight and governance with Group Procurement holding assurance responsibility oversight for
onboarding and ongoing due diligence.
[2] The Ethical Trading Initiative Framework is recommended by UK Gov and provides guidance and structure to companies completing their Modern Slavery
Statements. This framework suggests sections aligned to the following 6 areas. Structure, business, supply chains. Policies. Identification of risks. Due diligence.
Effectiveness. Training and capacity buildingRisk assessment & due diligence I Modern Slavery Statement 2023

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Admiral’s approach to risk assessment is to aid identifying any potential concerns withregards to modern slavery across its supply chain, with processes being reviewed
annually. Admiral’s comprehensive risk assessment process considers several factors tounderstand exposure such as geographic location, the nature of goods and services
being supplied, supply chain length and the use of temporary or migrant labour.
Following this assessment, suppliers are categorised into 3 supplier types based on a risk
profile generated from the following criteria:
·
·
·
·
·

Total cost of ownership
Criticality of service
Sharing of data
Access to internal systems
Category of purchase

As noted above, Admiral has over 1,780 contracted suppliers. These are further
separated into 18 Critical suppliers, 502 Strategic Suppliers, 885 Key Suppliers and 375
suppliers. Admiral does not act as a manufacturer or retailer of physical goods.
All suppliers identified as Critical, Strategic or Key are mandated to complete a duediligence questionnaire that captures a supplier’s position on anti-modern slavery
processes. This encompasses their risk management processes in their own supply chain
and any breaches that may have occurred within the preceding 12 months.

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Admiral Group’s procurement policies drive collaboration with
suppliers to ensure their practices are fit for purpose. Whilstcollaboration is recommended in assisting our suppliers, Admiralretains the right to terminate contracts should breaches ofmodern slavery be identified.
The Group Procurement team have undertaken continuous dip
checks across Admiral’s (EUI) supply chain. A recent audit of those
suppliers classified as critical, strategic, and lower risk key
supplies revealed that all those with a revenue of over £36 million
have a statement/policy in place, which was available to review.
However, suppliers with a revenue of under £36 million showed
areas for improvement. In line with Admiral’s mission to enhance
our supply chain and provide smaller businesses with theopportunity of additional training and / or to work with our Group
Procurement team in order to use Admiral's Modern Slavery
Statement as a best practise guide to developing their own in linewith the suppliers general risk profile, category of supply andopportunity for Modern Slavery to exist.
We have not identified any instances of modern slavery in ourbusiness or supply chain in 2023.

Effectiveness and
KPIs
Admiral Group continues tomonitor its effectiveness tocounter modern slavery throughvarious KPIs; with the two main
KPIs mentioned in our 2020statement again highlighted
below.

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Modern Slavery Training: In 2022, the completion rate for Anti-Slavery was 95.3% and now in 2023
it is 96.6%. A continued commitment exists, to creating a culture of informing colleagues andencouraging shared responsibility for modern slavery identification.
Reports of Modern Slavery: There were no reports of modern slavery in 2023 (2022: nil). Monitoring
the risk of modern slavery is continual, and Admiral is committed to principles as set within the UN
Guiding Principles on Business and Human Rights [3] to provide guidance on ethical operation.
Should any violations be identified, we will confirm the violation and will take action to improve andrefine practices that protect and respect human rights and provide appropriate remedy. Admiralreports on several additional metrics, noted below:

96.6% of colleagues having

completed and passed the modern
slavery training

0 modern slavery or related complaints /reports about Admiral Group or its supply
chain

0 confirmed modern slavery cases

identified within Admiral Group or its
supply chain[3]

UN Guiding Principles on Business and Human Rights, 2011

Training

Risk assessment & due diligence I Modern Slavery Statement 2023

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As part of Admiral’s approach to preventing all aspects of modern slavery, the business
reinforces policies through robust, relevant and assessed training and communication. AdmiralGroup also attended external training and has taken the opportunity to learn more about
mitigating modern slavery, including training that was hosted by the CPS [4] . These engagements
were used to help create more robust internal policies as well as a comprehensive training
package.
Admiral’s modern slavery awareness training was created in 2017 and is offered to all employees
via an in-house e-learning platform. Admiral's commitment to addressing modern slavery can befurther strengthened through comprehensive training and education initiatives. Internally, thecompany has successfully embedded a mandatory annual training program for all employees.
Looking forward, Admiral aims to extend its focus to suppliers, fostering a more inclusive
approach to eradicating modern slavery.
During 2022, the completion rate for employee modern slavery training was 95.3%. This has now
risen to 96.6% for 2023. The business views this as an acceptable outcome within the context oflong-term absences which drives the remaining non-completion. In 2022, staff rated the AntiSlavery, Exploitation and Human Trafficking online course at 4.8/5. As the global risk to modern
slavery is ever evolving, so too does Admiral’s approach to mitigation against it. The Modern
Slavery Training package is reviewed for continued relevance on an annual basis, with the latest
version having been released in October 2022.
[4]

Crown Prosecution Service

Key priorities
for 2024
Committed to amplifying
Admiral’s voice against all
forms of modern slavery inits business and supply
chain, Admiral continues tostrengthen the processes inplace.

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In 2024 the aim will be to build upon the work in 2023 with several priorities:
Understanding and analysing the impact of the enhancements delivered in 2023, which includes
the following:
Further enhance and monitor our DDQ question set incorporating focus on awareness of Modern
Slavery including more detailed information to identify any gaps and potential risks.
Continue to monitor Supply chain risk controls, governance activities – higher risk suppliers will
be required to demonstrate management of such risks through the ongoing contract management
process.
Admiral continues to improve and further align with the guidance set within the Ethical Trading
initiative, this includes improved reporting and early identification of any suppliers at risk will
support this initiative.
Training (External):
Admiral is looking to introduce training programs tailored for suppliers, covering modern slavery
awareness, prevention, and reporting. These programs may take the form of online modules,
workshops, or webinars.
Facilitating collaborative workshops is another valuable approach. These gatherings would provide
a platform for suppliers to share best practices, challenges, and insights related to modern slavery
prevention. This collaborative environment encourages continuous improvement and a collective
commitment to addressing the issue.

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Supplier Landing Page
Clear communication is paramount in conveying the company's commitment to eradicating modern slavery. Establishinga dedicated Supplier landing page can serve as a central hub for easily accessible information on policies andprocedures, reinforcing expectations from suppliers. From this dedicated page Admiral can provide comprehensive
documentation and resources, including guidelines, toolkits, and examples, to assist suppliers in understanding andimplementing anti-modern slavery measures.
Creating dedicated support channels for suppliers to seek guidance or report concerns related to modern slavery,
prominently featured on the Supplier landing page, will encourage open communication and issue resolution
This page will provide a direct link to our modern slavery statement.
Audits and SRM
To ensure suppliers' adherence to modern slavery standards, consistent audits and assessments should be conducted.
This process involves transparently sharing findings and collaboratively addressing any identified issues. Furthermore, amore robust risk assessment strategy can be implemented by conducting regular evaluations to gauge the likelihoodand impact of modern slavery within the supply chain. This assessment should consider factors such as geographic
locations, industry sectors, and the types of labour involved.
In addition to audits, a comprehensive approach involves the implementation of Supplier Relationship Management(SRM), facilitating regular and thorough audits of suppliers. These audits may include on-site visits, document reviews,
and interviews with workers to assess compliance with anti-slavery policies and procedures.
Encouraging transparent reporting from suppliers is crucial. Suppliers should be prompted to provide clear reports on
their own anti-modern slavery efforts, necessitating disclosure of relevant policies, practices, and measures they have inplace. This comprehensive approach ensures a proactive and vigilant stance against modern slavery within the supply
chain.

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Contractual
Integrating modern slavery compliance clauses into supplier contracts makes adherence a contractual obligation,
and adjusting the due diligence questionnaire ensures a more comprehensive understanding.
Consistent updates on the company's efforts to combat modern slavery, communicated regularly, enhancetransparency and build trust among suppliers. By implementing these measures, Admiral can cultivate an informed
and vigilant supplier network, actively contributing to the overarching goal of eliminating modern slavery within its
supply chain.
On the transition of the Supplier Working Group (SWG) now chaired by the Head of Group Procurement, inclusion ofa quarterly standing agenda item for modern slavery. The agenda item will review the data gathered through thedue diligence process and include discussion on the top risks within the supply chain as well as emerging risk.
Annual colleague training will continue as part of the continued education for colleagues on modern slavery.
Increase engagement and collaboration with not-for-profit social enterprises who specialise in the eradication ofmodern slavery.
This statement was approved by the Boards of Admiral Group, Admiral Insurance Company Limited and EUI Limited.
Signed by;Milena Mondini de Focatiis
Group Chief Executive Officer
11 June 2024