This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It constitutes the slavery and human trafficking statement for Darwin Technologies Limited and the Benefit Express Limited (together “Darwin”, or “Darwin Group”) in respect of the financial year ending 31 December 2019.

Our Business

Darwin is a SaaS (Software as a Service) provider of global employee benefits and employee engagement software. The Darwin Group is a wholly owned indirect subsidiary of Mercer Limited (‘Mercer’), part of the Mercer global consulting business, a leader in advancing health, wealth and career. Mercer Limited is a wholly owned subsidiary of Marsh & McLennan Companies (‘the MMC Group’).

Group Structure

The MMC Group is a global professional services firm offering clients advice and solutions in risk, strategy and people. The MMC Group has approximately 75,000 employees worldwide and approximately 13,380 employees in the United Kingdom.

Our Supply Chain

As a SaaS provider, Darwin does not operate in an industry where modern slavery is prevalent but nevertheless is committed to taking steps to uncover any potential risks within its supply chain.

Darwin’s Risk and Compliance function is responsible for ensuring that its supply chain complies with applicable modern slavery legislation.

Our Policies

Darwin has various policies in place which aim to minimise the risk of modern slavery or human trafficking, and encourages reporting of any related concerns, including:-

  • A Robust Procurement Policy: In addition to the rigorous supplier assessment processes, Darwin has implemented an additional questionnaire focused on modern slavery activities/signals. The questionnaire is deployed on a risk basis, according to the nature of services provided. The Darwin Board reviews the level of responses received. Suppliers are required to report what steps they are taking regarding identifying the risk of modern slavery within their particular supply chain which enables Darwin to better assess the potential risks of modern slavery in their own supply chains. The questionnaire is reviewed and refined each year.

Darwin includes a requirement for compliance with modern slavery legislation in its standard terms and conditions and contracting agreements with suppliers.

  • The Greater Good: Darwin is committed to conducting business in a responsible way and in accordance with MMC Group´s Code of Conduct. This is a significant part of Darwin's culture and it sets out the ethical and professional standards which apply to employees of Darwin. Colleagues are expected to act with integrity, honesty, courage and promote mutual respect.
  • Whistleblowing: Respect and a culture of openness in the workplace is a key aspect of the MMC Group’s Code of Conduct. Darwin encourages colleagues to report any concerns, including any concerns relating to modern slavery or human trafficking. Darwin's whistleblowing procedure utilises an Ethics & Compliance Line (a service administered by a third party) which makes reporting straightforward and confidential.


Darwin's Modern Slavery Policy has been rolled out to all staff, and incorporated into induction training.  It includes information on who staff should contact if they have any concerns. Employees are encouraged to report any concerns or suspicions regarding the presence of modern slavery within the supply chain.

Going Forward

Darwin recognises that tackling modern slavery requires a continuing year-on-year commitment and will continue to undertake due diligence in our supply chain and review and improve procedures to help identify and prevent the risk of modern slavery or human trafficking occurring. Darwin recognises the importance of continuing this work during the Covid-19 pandemic and will seek to adapt its activities and priorities as required.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and has been approved by the Board of Darwin Group on 11 June 2020.

Stephen Read,

Chief Executive Officer, Darwin Technologies Limited



Darwin helps organisations achieve their benefits, people, and wider business goals by increasing engagement, streamlining administration, controlling cost and reducing risk. And your employees are able to access and engage with their benefits wherever they are in the world.


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