Slavery and Human Trafficking Statement

Introduction from the CEO

Modern slavery and human trafficking are crimes that affect communities and individuals across the globe. As a Group, BGL strictly prohibits the use of forced labour and human trafficking in all of its operations and global supply chains.
BGL Group considers it imperative that, as a business, there should be total transparency in our efforts to meet the requirements of the Modern Slavery Act 2015 (the Act).

The following statement outlines BGL Group’s adherence to the Act and highlights the steps we take to ensure that there are no occurrences of slavery or human trafficking within the organisation or its supply chains.
As highlighted in our company values, it is a fundamental policy of BGL Group to conduct our business with honesty, integrity and in accordance with the highest ethical standards.

We are committed to the ongoing review of our practices to ensure we continue to meet the requirements of the Act

Matthew Donaldson, CEO

Our Business

BGL Group is a major financial services provider, operating in the UK and France. The Group specialises in consumer insurance and price comparison, employing in the region of 3,000 people.

The Group owns brands including:, one of the UK’s top price comparison sites; Junction, the insurance partnership business;, the online life insurance provider; Frontline, the owner of insurance brands Dial Direct and Budget Insurance; and the French price comparison site

Related Company Policies

BGL Group is committed to ensuring that modern slavery and human trafficking do not exist within any part of our business or supply chains in accordance with the principles set-out in our Whistleblowing Policy. Additionally, we are in the process of supplementing this policy with a Code of Conduct which will reflect our existing commitment to operate ethically and with integrity in all our business relationships. The implementation and enforcement of effective systems and controls within the organisation and our supply chains will safeguard against slavery and human trafficking.

Risks to the BGL Group associated with the Act are managed in accordance with the Group Risk Management Policy. Specific materiality assessments are carried out across the supply chain in accordance with BGL procurement guidelines. Additionally the group operates a Whistleblowing Policy and actively encourages the reporting and exposure of unethical behaviour.

Due Diligence Process for Slavery and Human Trafficking

BGL employs staff members predominantly from within the UK, with a small contingent based in France. Employee relations are managed consistently across the Group by the Human Resources department. All relevant employees are paid at least the UK National Living Wage.

Facilities services procured through third parties have been grouped into tiers, based on value and importance. Allowing us to identify which of our service providers we should focus the most attention on.

We have written to suppliers seeking assurance that the precepts of the Act are being followed/adopted, though clearly expecting a more complete and robust attestation from those few facilities suppliers who directly fall under the tenets of the Act. Where no assurance is forthcoming, we will engage with those parties at contract review to ascertain whether there is sufficient concern to replace them.

Our Effectiveness in Combating Slavery and Human Trafficking

BGL also uses independent third party auditors to conduct an externally facilitated Workplace Condition Review on key third party suppliers to bring insights on ways we can tackle slavery and human trafficking. We plan to carry out annual audits to ensure adherence to anti-slavery standards. The remit of these audits is to assess and benchmark our suppliers from a social point of view including Labour, Health and Safety, Management Systems and Environment and how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains.

Supplier Adherence to our Values and Due Diligence Processes

We have a zero tolerance approach to slavery and human trafficking. To ensure all suppliers comply with our values, we have a supply chain review programme in place. This consists of:

• Carrying out additional due diligence on suppliers; and
• Writing to suppliers and seeking confirmation regarding compliance with the Act.

We do not rely solely on our supply chain’s commitment to being compliant. conducts annual social and working condition audits for areas of the supply chain that could be susceptible to slavery. These checks include payroll and young worker registration, local minimum wage standards, hygiene certification and facility evacuation plans.


To ensure a high level of understanding of the risks of modern slavery and human trafficking in our organisation and supply chains, we have provided training to our employees this year to raise awareness of this issue throughout the Group and in depth training to those dealing with third party suppliers.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes the BGL Group Slavery and Human Trafficking Statement for the financial year ending 30 June 2017.
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