Modern Slavery Statement

FCIM's Commitment

FCIM is committed to ensuring that slavery and human trafficking do not occur anywhere within its business operations or supply chains. FCIM upholds the highest standards of integrity and transparency in its business relationships and requires its suppliers and business partners to uphold the same standards, taking necessary and appropriate steps to prevent and address slavery and human trafficking within its own operations and supply chain. 

In order to meet this commitment, FCIM imposes appropriate policies, processes and procedures upon its staff (including its Directors, employees and contractors), suppliers and business partners.

Organisational Structure, Business and Supply Chains

FCIM is an insurance intermediary and provider of premium finance products and is part of the First Central Group of companies. As part of its business, FCIM offers car and home insurance to customers on behalf of its captive insurer (this includes claims handling and policy administration services) and enters into direct agreements for unsecured personal lending (premium finance) with customers. 

FCIM offers insurance and finance to the UK retail market only under its trading name 1st Central. FCIM offers its services via price comparison websites, by telephone, and through its own digital platforms. FCIM operates call centre operations for sales, customer service and claims handling, with outsourced arrangements in the UK and South Africa.

FCIM’s key suppliers and business partners include the following service providers: technology and software; price comparison websites; call centre; car hire; vehicle repairers; and law firms.  First Central works with around 500 suppliers based mainly in the UK with a small number based in Europe and the USA. 

Employee wellbeing (extending to pay, working hours and environment) is a key priority for FCIM and this is reflected in its HR policies, processes and procedures. As at 31 December 2024, the First Central Group directly employed 1,382 employees. Employees of FCIM are engaged on full-time and part-time bases (including flexible working arrangements) and are rewarded fairly for their work. 

Policies, processes and procedures

FCIM’s policies, processes and procedures are fundamental to its internal control and governance framework and include guidance for its employees, Directors and contractors on conduct (including anti-bribery and corruption), recruitment, DEIB (Diversity, Equity, Inclusion and Belonging), health and safety, and whistleblowing. FCIM’s policy on procurement and supplier management enforces a framework of compliance on its suppliers and external business partners to ensure their commitment and practices reflect the high standards FCIM maintains.   

FCIM’s suite of policies, processes and procedures are reviewed and updated annually and, when necessary, throughout the year to align with industry best practice and legislation/regulation, with key stakeholders (including the Compliance and Legal teams) involved in their creation and iteration.  

In respect of its supply chains, FCIM ensures appropriate measures, which are applied on a risk assessment basis, are included in its due diligence and contractual engagement processes. FCIM is committed to thorough due diligence before engagement with suppliers and business partners, with clear oversight of performance and continued due diligence throughout the lifetime of the supply. 

FCIM undertakes segmentation of its supply chain according to risk. The majority (c.70%) of FCIM’s high risk suppliers complete their due diligence via a UK financial services community system called FSQS (Financial Services Qualification System) run by the external provider Helios and endorsed by the Financial Conduct Authority (FCA) who also use this system. The FSQS question-set is updated annually in line with regulatory and legislative requirements for the UK financial services industry and includes 24 questions on Labour Standards. These include asking the following questions of suppliers: 

• Is the supplier compliant with section 54 of the Modern Slavery Act? 
• Do they have a Labour Standards Policy in place?
• Do their policies include identification of human rights risks including modern slavery in their supply chains?
• Do they comply with minimum Labour Standards? 
• Do they have appropriate protective procedures in place to ensure that modern slavery and human trafficking practices are eradicated from their own supply chains?

The Group Legal team ensures that contracts with suppliers include appropriate modern slavery provisions as part of their contractual engagement processes. 

As part of FCIM’s recruitment process, it ensures that all its employees are legally permitted to work within the UK, with no evidence of coercion. FCIM’s interview and selection processes are designed to be fair and transparent. Using structured interview techniques, FCIM ensures that all candidates are assessed based on their skills, experience, and suitability for the role. Employee screenings are mandatory prior to onboarding and include checks on identity, finances, criminal records and appropriate references. 

Training

FCIM’s commitment to the aims contained within this statement flow through the organisation via the process of mandatory annual training for employees and Directors. This training is targeted, monitored and reported on within FCIM. 

Effectiveness and continuous improvement

FCIM monitors and reports internally upon any incidents involving slavery and human trafficking and is committed to taking appropriate action if such activity is identified. During the year ending 31 December 2024, there were no reported incidents relating to slavery or human trafficking within the First Central Group.

FCIM remains committed to continuous improvement in identifying, preventing, and responding to slavery and human trafficking concerns. FCIM shall continue to review and enhance its policies and practices to ensure they remain effective and aligned with industry best practice and legislative/regulatory requirements.

Agreed by The Board 20th May 2025

Ben Tomasetti, Managing Director
First Central Insurance Management Ltd.