Introduction

This statement sets out our actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2018 to 31 March 2019.

As a responsible employer operating in the Financial Services sector, the Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The Company is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure

It is the Company’s policy to maintain a strong corporate culture and identity, attracting quality customers and staff, building long-term value into the business. The Company is committed to providing the highest quality of thoroughly researched financial advice, which is professional, efficient and user friendly.

Supply chain and Supplier Due Diligence

Our supply chains are mainly in respect of recruitment, the procurement of office supplies, materials and equipment, and the provision of professional and support services, principally in relation to IT, facilities, finance, human resources and marketing. We seek to engage with suppliers who are reputable and well established within financial services.

In order to support our statement, we aim to build relationships with reputable suppliers to ensure expectations of business behaviour are both clear and consistent; and we expect our direct suppliers to be working towards having suitable anti-slavery and human trafficking policies.

In terms of HR procedures, we have rigorous identity and background checking in place and work with carefully selected and reputable third parties to source candidates. Once in employment, we encourage a culture of speaking up about any concerns. Key policies include:

• Anti Bribery and Corruption policy
• Whistle blowing policy
• Recruitment of foreign workers policy
• Equal opportunities and anti harassment policy
• Grievance policy
• Health and Safety policy
• Free confidential helpline to employees
• Anti Money Laundering and Counter Terrorist Financing Policies

Modern Slavery Risk Assessment

Whilst due to the nature of our business we consider that our company remains low risk from a modern slavery perspective we remain vigilant and are paying particular attention to the following parts of our business in our assessment of Modern Slavery Risk.

• Our UK supply chain is primarily UK procured however some IT support, software and IT services are delivered from overseas locations.
• We are increasingly using employment agencies to bring in employees as our business grows on a full time and temporary basis

Training

The Modern Slavery Act requires all company employees to consider the relationship that they have with other companies and to be alert to the possibility of slave labour and/or human trafficking. We are in the process of designing a training module to teach employees about the risks of Modern Slavery as well as incorporating the training into our staff Induction.

Measuring Effectiveness

We have developed a number of initiatives in line with the criteria below and these are currently being delivered to ensure that the criteria are met in advance of the publication of our next statement.

1. Implementation of an employee training module on modern slavery which will cover the basic principles and be delivered to those responsible for working with suppliers.
2. Modern slavery training incorporated into our induction training.
3. Any reports or concerns or risks relating to modern slavery and human trafficking are tracked and reported to the company’s HR Director and resolved.
4. All new contracts with suppliers include clauses which address the parties obligations.

Monitoring and Reporting

If issues are identified in relation to modern slavery and/or human trafficking, these will be reported to our Director.