Modern Slavery Policy

The Company’s London office is based at 80 Leadenhall Street, London, EC3A 3DH and the Manchester office is based at Embankment East Tower, 100 Cathedral Approach, Greater Manchester, M3 7FB.

The main activities carried out by the Company are insurance and finance recruitment. These activities are consistent throughout the year and are therefore not seasonal.

 

 

Definitions

The Company considers that modern slavery encompasses:

• Human trafficking
• Forced work through mental or physical threat
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse
• Being dehumanised, treated as a commodity, or being bought or sold as property
• Being physically constrained or having restrictions placed on freedom of movement
  
  

Commitment

We acknowledge our responsibilities in relation to tackling modern slavery and commit to complying with the provisions of the Modern Slavery Act 2015.

We understand that this requires an ongoing review of both our internal practices in relation to our labour force and our supply chains. We do not enter into business with any company, in the United Kingdom or abroad, that knowingly supports or is found to be involved in slavery, servitude, or forced or compulsory labour.

 

No labour provided to the Company in the provision of its services is obtained by means of slavery or human trafficking. The Company adheres to the minimum standards required under relevant employment legislation in the United Kingdom.

Supply Chains

To fulfil its activities, the Company’s main supply chains include:

• Smy Services – IT support
• Royal London and People’s Pension –Third-party pension providers
• Howden Insurance – company and medical insurance
• Oakroom Wealth Management – group life insurance
• Staffology – HRIS
• Other systems and platforms required to perform business duties

The nature of our supply chain is primarily service-based within the United Kingdom. First-tier suppliers are our immediate contractors, and we recognise that these suppliers may have further contractual relationships with lower-tier suppliers.

 

We manage and review our suppliers on a regular basis.

 

Potential Exposure

We consider the risk of exposure to slavery and human trafficking to be low within both our business and supply chains. This assessment is reviewed regularly, and appropriate action will be taken if necessary.

Steps Taken

The Company carries out due diligence processes to ensure that slavery and human trafficking do not take place within our business or supply chains. To our knowledge, we have not conducted business with any organisation found to be involved in modern slavery.

 

In accordance with section 54(4) of the Modern Slavery Act 2015, the Company has taken the following steps:

• Reviewing supplier contracts to include termination rights where a supplier is, or is suspected to be, involved in modern slavery
  
  

Key Performance Indicators

The Company monitors the effectiveness of its approach to preventing modern slavery and human trafficking through a defined set of key performance indicators. These measures provide ongoing assurance that appropriate controls are in place and support continuous improvement.

The Company’s key performance indicators include:

• Completion of an annual supplier review to assess compliance with modern slavery and ethical labour standards
• Percentage of new suppliers subject to appropriate modern slavery due-diligence checks prior to onboarding
• Annual risk assessment of suppliers, including identification of higher-risk suppliers requiring enhanced monitoring
• Inclusion of modern slavery and ethical labour clauses within supplier contracts and supplier acknowledgement of compliance
• Monitoring and recording of any concerns, reports, or suspected incidents, including timely investigation and resolution
• Regular review of modern slavery risks and controls by senior management
• Periodic review and update of this policy to reflect changes in legislation, guidance, or business operations

These key performance indicators are reviewed regularly to ensure they remain appropriate, proportionate, and effective.

 

Compliance with This Statement

All employees and individuals working on behalf of the Company must read, understand, and comply with this policy. Preventing, detecting, and reporting modern slavery is the responsibility of everyone working for or under the control of the Company.

 

You must avoid any activity that could lead to or suggest a breach of this policy. Any actual or suspected conflicts with this policy must be reported to a manager or director as soon as possible.

 

If you believe or suspect a breach has occurred or may occur, you must notify your manager or director or report the concern in accordance with the Company’s Whistleblowing Policy.

 

If you are unsure whether a particular situation constitutes modern slavery, you should raise the matter at the earliest opportunity.

The Company encourages openness and supports anyone who raises genuine concerns in good faith. No individual will suffer detrimental treatment for reporting concerns honestly, even if they are ultimately unfounded.

 

Slavery Compliance Officer

All concerns regarding modern slavery should be raised with HR, who will take appropriate action in line with the Company’s obligations.

 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and will be reviewed annually for each financial year.