Modern slavery and human trafficking statement
Modern Slavery Act 2015
Introduction from CMA Management, part of the QuestGates Group.
• Policy Statement
This policy applies to all persons working for CMA or on our behalf in any capacity, including employees at all levels, directors, agency workers, seconded workers, volunteers, agents, contractors and suppliers.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.
CMA is committed to improving our practices to combat slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement.
CMA strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains.
We expect our suppliers to hold their suppliers to the same high standards.
- Modern Slavery and Human Trafficking Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking.
- Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited.
Commitment: We shall be a company that expects everyone working with us or on our behalf to support and uphold measures to safeguard against modern slavery.
Organisational structure
CMA provides full-time claims-handling services to insurers, their legal representatives and vehicle information suppliers.
We are known as Claims Management & Adjusting Ltd or CMA or CMA Adjusters; founded in 1994 by the current MD, Philip Swift. As of 01/2024, we are part of the QuestGates Group.
The principal activity undertaken by the CMA is the resolution of insurance claims. These are mainly vehicle related together with ancillary activities necessary to facilitate this. Additional activities include tracing, social media enquiries and obtaining vehicle data information.
CMA is a body incorporated at Companies House and employs paid staff with an annual turnover of approximately £1 million.
Our policies on slavery and human trafficking
CMA is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free, we have put in place a designated Modern Slavery and Human Trafficking Policy. Our Modern Slavery and Human Trafficking Policy demonstrates our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk we have in place:
Human Resource procedures
- A comprehensive range of policies and practices have been applied including an Equality and Diversity Statement, Dignity at Work, formal grievance and disciplinary policies to protect and ensure that staff rights and responsibilities are upheld
- Regarding pay, CMA has safeguards to ensure that the hourly rate of staff does not fall below the current London Living Wage
- Procurement procedures
- Engage with our supplier base
- Identify and monitor potential risk of slavery and human trafficking in our supply chains
- Incorporate within the tender process to address slavery and human trafficking with potential new suppliers.
Supplier adherence to our values
CMA has zero tolerance for slavery and human trafficking. To ensure all those in our supply chain (including contractors) comply with our values we have in place a supply chain compliance action list.
- Engage with supplier base to secure a commitment to work with CMA to identify and monitor slavery and human trafficking down the supply chain.
- Engage with potential new suppliers about commitment to our Modern Slavery Policy.
Raising awareness
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we intend to provide training to our staff, via Modern Slavery as a regular agenda item to be discussed at management meetings.
Our effectiveness in combating slavery and human trafficking
We have built upon existing monitoring and developed further processes to allow for more effective reporting in the longer term.
Further steps
Following a review of the effectiveness of steps we have taken to date to ensure that there is no slavery or human trafficking in our organisation and supply chains, we intend to take the following further steps to combat slavery and human trafficking.
Human Resources
Our policies and reporting mechanisms are regularly reviewed to identify areas for further review and issues to be addressed.
To check for inconsistencies between policy and practice, CMA undertakes Staff Surveys, which include questions about the experiences of staff relating to their experience at CMA, instances of bullying/harassment/discrimination and the ability to manage work-life issues as employees.
If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships
Updates:
03/2025 – Transparency in Supply Chains (TISC) Statutory guidance
Approved By Senior Management Personnel of CMA
updated: 03/2025
10/2025 – Questgates Modern Slavery Statement, which applies to the Questgates Group, of which CMA is a part
This statement applies to The QuestGates Group for the financial year July 2025 to June 2026.
QuestGates Group is the UK’s largest independent claims management and loss adjusting organisation, structured across multiple specialised subsidiaries, including Hyperion Adjusters, Structural Surveys and Design, Ramsay McMichael, QGLaw, Brownsword, and Topping’s.
Through strategic expansion and acquisitions (e.g., TSS, Keating’s, Rossiter’s), the Group operates 15 offices across England, Scotland, and Ireland, ensuring broad accessibility. We also partner with VRS Adjusters, granting access to expertise across 300 offices in 140 countries.
The Group is organised into four key operational divisions: Loss Adjusting, Claims Management, Building Consultancy, and Legal Services, supported by central functions. Our values, passion, trust, flexibility, and unity guide our service philosophy.
Led by an experienced Board of Directors, QuestGates is recognised for attracting and nurturing industry talent. We have earned prestigious awards, including Insurance Times Claims Excellence Awards –
Excellence in Customer Care (2025) and Modern Claims Awards – Outstanding Commitment to Training and Apprenticeships (2025). We also hold Gold standard status in Investors in Customer.
Our mission is to provide specialist claims-related services focused on clients, customers, and teams, delivering outstanding service supported by innovative digital solutions.
As part of our corporate social responsibility, we hold several accreditations, including commitments to mental health at work, the Prince’s Responsible Business Network, Payroll Giving, the 2024 Top Insurance Employer award, and alignment with the Good Business Charter.
QuestGates Group actively manages its economic, social, and environmental impact, aiming for Net-Zero emissions across all scopes by 2040 through digitalisation, supplier engagement, innovative building techniques, and waste reduction.
We define modern slavery as including:
• Human trafficking
• Forced work via mental or physical threat
• Being controlled or owned by an employer through abuse or threat
• Dehumanisation or being treated as property
• Physical restraint or restriction of freedom of movement
We acknowledge our responsibility to combat modern slavery and comply with the Modern Slavery Act 2015. This includes ongoing reviews of internal labour practices and supply chains.
We will not conduct business with any organisation knowingly involved in slavery, servitude, or forced labour.
All labour provided is obtained in compliance with relevant employment legislation in the UK, Scotland, and Ireland, often exceeding legal minimums.
Our main supply chains involve office maintenance, stationery, and equipment. Many suppliers are intermediaries with further subcontractors.
We identify our main slavery risks in purchasing goods, due to multi-tiered supply chains, reliance on low-cost materials, and suppliers in regions with weaker labour protections.
To mitigate risk, we:
• Conduct regular risk assessments and audits
• Build transparent supplier relationships
• Enforce stringent supplier codes of conduct
• Collaborate with industry stakeholders to promote fair labour practices
Overall, our exposure to modern slavery risk is limited, but we remain vigilant to prevent it within our business and supply chains.
To date, we have not engaged with any organisation involved in modern slavery. Per Section 54(4) of the Modern Slavery Act 2015, we have:
• Reviewed supplier contracts to include termination rights for suspected involvement in modern
slavery
• Implemented measures to identify and assess supply chain risks
• Embedded a zero-tolerance policy on modern slavery
These steps, alongside KPIs, provide a comprehensive overview of our efforts to prevent modern slavery.
David Nicholls serves as our Modern Slavery Compliance Officer, handling all related concerns.
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and will be reviewed annually.