This statement is made on behalf of Probitas Managing Agency Limited (“Probitas”) and all subsidiaries, pursuant to section 54(1) of the Modern Slavery Act (‘The Act’). This statement has been approved by the Probitas Board.  

Probitas employs less than 100 staff worldwide.  

Probitas makes use of outsourced suppliers for a number of functions that are key to the business. 

Responsible Business Policy 

We are committed to respecting human rights and tackling modern slavery and human trafficking risks in both our supply chains and any part of our business. It is our policy to offer equal treatment to employees, and prospective employees, ensuring that all are treated fairly and with dignity and respect.  

We aim to be a responsible business; from our environmental efforts, being ethical in our approach to how we do business, our charitable partnerships, supporting our communities and employee fundraising efforts. Our vision is to use our expertise, influence and passion as a force for good in our local communities and the wider world. We have a CSR committee that works to uphold our values in this area and this approach is embedded in our culture and policies.  

Supply Chains  

As a specialist provider of insurance and reinsurance, we do not consider that our supply chains carry a high risk of engaging in slavery or forced labour. We carry out due diligence into our key suppliers to evaluate: 

  • Whether they comply with local laws and regulations; 
  • Whether their culture aligns to our values; and, 
  • Their Corporate Social Responsibility policy. 

Our outsourcing policy is being updated to explicitly assess the risk of a supplier being a concern from a Modern Slavery or Human trafficking perspective.  

Should an elevated risk be identified, the supplier is required to explicitly address the concerns raised by Probitas, and identify the internal risk management in place to ensure this risk is mitigated.  

If any concerns are identified in this process the COO will escalate the concerns to the Executive Committee for a final decision on the appropriateness of using the supplier concerned. 

Our Policies  

As a responsible business, we hold ourselves to the highest standards of ethical conduct. We operate a number of group-wide policies that enable us to identify and mitigate the risk of modern slavery and human trafficking. These include:  

  • The Probitas Code of Conduct 
  • ESG Policy 
  • Outsourcing Policy (and supporting policies);  
  • Financial Crime Policy, inclusive of anti-money laundering, anti-bribery, corruption and fraud; and,  
  • Speak Up Policy.  

These policies are available to all employees, with employee rights and benefits communicated via our employee handbook and individual employment contracts.  

We encourage employees to raise any concern of wrongdoing, including concern related to modern slavery and human trafficking, without fear of reprisal or victimisation. Our whistleblowing policy provides employees with various means by which they can confidentially raise concerns. This includes escalation to senior management, our Whistleblowing Champion or directly to an applicable financial regulator.  


During the past year, we have continued to train our employees on our responsibilities and approach to modern slavery. We will continue to ensure that key persons in our business remain aware of our commitment to The Act.  

Ash Bathia
CEO, Probitas Managing Agency Limited