About the reporting entity MetLife Australia (MLA)
MetLife Australia group (MLA) is a financial services group with the main operating entity being MetLife Insurance Limited (MIL) (ABN 75 004 274 882 and AFSL 238096). In addition to MIL, the MLA group is made up of:
MetLife General Insurance Limited (MGIL);
The Direct Call Centre Pty Limited (DCC); and
MetLife Investments Pty Limited (MIPL).
Members of the MLA group are all subsidiaries of MetLife, Inc a New York based life insurer which has subsidiaries located around the world. MLA has around 370 employees with its head office located at 2 Park Street, Sydney NSW 2000 and has branches in Melbourne and Brisbane.
As the reporting entity of the MLA group, MIL is a life insurance organisation which issues life insurance products to retail and wholesale clients (as those terms are defined in the Corporations Act 2001 (Cth)). In issuing life insurance products, MIL undertakes activities in relation to distribution, claims and underwriting. To support the operations of MIL, MIPL acts as a trustee entity and holds MIL’s insurance assets.
MGIL is a general insurer which is in run‐off and DCC is currently non‐operational. This modern slavery statement is made by MLA.
MetLife global structure, operations and supply chain
i. MetLife, Inc
MetLife, Inc (MetLife) is based in New York, USA and has 150+ years of experience. MetLife has established its status as a trusted global leader in the delivery of effective and innovative insurance, employee benefits, and retirement solutions worldwide, aimed at helping customers build a more confident future.
MetLife has leading market positions in United States, Australia, Japan, Latin America, Asia, Europe and the Middle East through organic growth, acquisitions, joint ventures and partnerships, and protects around 90 million customers in over 40 countries.
MetLife companies offer life, accident and health insurance, retirement and savings products through agents, third‐party distributors such as banks and brokers, and direct marketing channels. MetLife leads the market in corporate insurance solutions in the US, Latin America, Asia, Europe and the Middle East.
MetLife serves 90 million customers worldwide and has US$4.7 trillion of life insurance protection policies in force globally. MetLife has 49,000 employees globally and is positioned 80th on the 2020 Forbes Global 2000 ranking of world’s largest public companies.
ii. MetLife in Australia
MIL is a leading provider of life insurance, partnering with employers, superannuation funds and financial advisers to help Australians protect their lifestyles by being a financial safety net when a tragic event impacts their lives. MIL is the third largest insurer in group life insurance and the second largest in corporate insurance in Australia, covering 1.5 million customers and paying over $533 million in claims to policyholders in 2020.
Specifically, MIL provides life insurance through three distribution channels:
1. Superannuation (Group) — Offering Death, TPD and IP cover through a life insurance policy within an individual’s superannuation fund account. MIL partners with superannuation funds to design products that are catered for the membership base of the fund.
2. Retail (through independent financial advisers) — Offering Death, TPD, Trauma and IP cover that is tailored to the individual’s needs and personal circumstances.
3. Corporate — Offering Death, TPD and IP cover as a group policy purchased by an employer, with employees ultimately given the benefit of the cover under the policy.
iii. MLA Supply Chains
MLA supply chains include third party suppliers of services, which support MLA to provide financial services to our clients. A non‐exhaustive list of these suppliers include:
IT equipment, software and hardware;
Real estate and property management services;
Education and training services;
Treasury and Banking services;
Marketing, media and related advertising and design services;
Operational services, including medical services;
Travel and accommodation services;
Corporate Social Responsibility services.
Risks of modern slavery practices in operations and supply chains
Through the existing procurement risk assessment processes in place, MLA strives to only deal with reputable suppliers that are aligned to our values. We seek to minimise the risk of modern slavery practices, however we recognise that modern slavery risks may occur in these businesses as some may be domiciled overseas and MLA may not always have sufficient oversight of these practices or places of work.
Actions taken to control the risks of modern slavery
MLA has a zero‐tolerance approach to modern slavery and human trafficking, including in our supply chains. This forms part of our commitment to conduct our business ethically and lawfully as set out in MetLife’s Code of Business Ethics. All our employees are required to act in accordance with the Code of Business Ethics. An employee’s failure to comply will result in disciplinary action and may lead to termination of their employment.
The steps taken to specifically address modern slavery risks after the implementation of the Modern Slavery Act 2018 (Cth) are enhancing the existing procurement processes and risk assessments to include assessment of any modern slavery risks in our supply chains. MLA also requires suppliers onboarded since the Modern Slavery Act 2018 (Cth) to confirm if they have ever been convicted of an offense involving modern slavery and whether they have the adequate due diligence processes in place to ensure there is no modern slavery in their supply chain. Vendor agreements have been updated to include a standard modern slavery clause and MLA will publish an external modern slavery statement on the website once it appears on the Australia Border Force website.
Assessing the effectiveness of the controls
Implementation of the actions taken to assess and address modern slavery risks were overseen by the Regulatory Changes and Interactions Committee (RCIC) which reports into the Risk Management Committee (RMC). The RCIC agrees that current practices are sufficient to identify and address modern slavery risks to acceptable levels. This is due to the above mentioned steps in conjunction with the existing risk management framework.
MLA has an established speak up and risk management culture whereby operational and regulatory incidents are promptly reported, managed and remediated. Any modern slavery risks identified are escalated to the Risk and Compliance department, and Legal if required, for further assessment and action. The RMC reports into the Board Risk Committee (BRC) and oversees any regulatory compliance, which also include modern slavery.
In addition, there is a robust whistleblowing process in place where employees can anonymously report concerns of any breaches to the Code of Business Ethics.
This statement was made pursuant to the reporting requirements under the Commonwealth Modern Slavery Act 2018 (Cth) and constitutes MLA’s modern slavery statement for the financial year ending 31 December 2020.
The Boards of MIL and MGIL approved this statement on behalf of all entities under MLA on 28/06/2021. The Board of MIL approved this statement as parent entity of DCC and MIPL. Signed on behalf of MLA by the Chair of the Boards of MIL and MGIL, Mr. Geoff Brunsdon and the Chief Executive Officer of MLA, Mr. Richard Nunn.