Anti modern slavery policy

Modern slavery is a term used to describe actions such as slavery, forced and compulsory labour, child labour, etc.  Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited.

Risk assessment

We consider that our holistic working environment has very low risk of modern slavery arising.  We work with professional firms with high calibre and high-principled people such as law firms and actuaries who do not tolerate this sort of action or behaviour.  Our supply chains are minimal as our principal work is consultancy – we do not rely on others to do the work we do.  We use a small number of suppliers and we carry out enquiries to satisfy ourselves that modern slavery does not operate.

Our policy and commitments

We take a risk-based approach to our contracting processes and keep them under review.  We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery in our contracts with third parties.  Using our risked based approach we will also assess the merits of writing to suppliers requiring them to comply with our code of conduct, which sets out the minimum standards required to combat modern slavery and trafficking.

We expect everyone working for us or on our behalf to support and uphold the following principles to safeguard against modern slavery:

  • We have a zero-tolerance approach to modern slavery in our organisation.
  • Employees and must not engage in or facilitate any activity that might lead to a breach of this policy.
  • Employees must report any instance or suspicion that modern slavery may be operating within the business, a supplier, or client.

Consistent with our risk-based approach we may require:

  • Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their anti modern slavery policy.
  • As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with anti modern slavery principles.
  • 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 would likely include termination of their contract and reporting the firm or individuals to the relevant authorities.