Introduction
The Modern Slavery Act (MSA) 2015 and Section 54 of the MSA Act requires organisations supplying goods or services with a turnover of £36 million or more to publish an annual slavery and human trafficking statement. It also requires us to make transparent the action we take to ensure our business, and our supply chains are free of modern slavery, and the effectiveness of those actions.
As a firm operating in the financial services sector, we are committed to adhering to and promoting strong professional ethics and acting with integrity and transparency in all business dealings and to continually improving our policies and practices in order to safeguard against any form of modern slavery taking place within the business or our supply chain. This commitment ensures compliance with the Act and our recognition of the responsibility we have to prevent modern slavery in all its forms, both in our business, and in our supply chains.
Organisation structure
We are part of AFH Financial Group Limited, registered in England (Companies House number: 07638831). We are an entirely UK based company. The Group has offices across the UK.
For Financial Planning firms within the Group, business activities cover a wide range of financial products and services including financial advice across life and health protection, savings and investments, retirement planning, tax planning and mortgage advice.
For Wealth Management firms within the Group, business activities include the provision of portfolio management and stockbroking services.
Anti-slavery policy
Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls to ensure slavery and human trafficking is not taking place within our business or our supply chains.
We aim to provide a rewarding working environment in which people are valued and respected. Our policies and procedures aim to ensure that we create a safe and inclusive working environment for our staff, underpinned by our culture and values.
We have several policies and interventions aimed at employee wellbeing, including:
- equality, including diversity and Inclusion and preventing discrimination at work
- whistleblowing
- grievances
- harassment and bullying.
We also provide resources to embed our culture, to set expectations of values and behaviours, to support the health & wellbeing of our staff and we have recruitment processes which aim for inclusion and fairness.
Our supply chains
As a Group, we buy a wide range of goods and services. Our supply chains include:
- providers of financial products
- recruitment agencies
- software providers
- office suppliers
- third party consultants.
Supplier adherence to our values
We have zero tolerance to slavery and human trafficking. We expect the same high standards from our suppliers, contractors and other business partners and will not enter into business with any organisation which knowingly supports or is found to be involved in slavery, servitude and forced compulsory labour. We will conduct regular follow up activity to ensure that suppliers continue to adhere to our values.
Due diligence processes for slavery and human trafficking
- through undertaking due diligence in our activity, we seek to ensure that we do not inadvertently support Modern Slavery. We make our processes known to potential staff and suppliers as a means of encouraging good practice
- we ensure that all staff are legally entitled to work in the UK and that the contract is directly with them.
- we also ensure that any recruitment agency we utilise for the placement of temporary staff follows the same requirements to confirm the identity and right to work of individuals placed with us
- when we undertake our procurement process potential suppliers must self-declare if they meet the relevant criteria in the Modern Slavery Act 2015
- we will further review our supplier onboarding process to embed checks on suppliers to ensure compliance with the requirements of the Modern Slavery Act 2015
- identify and mitigate the risk of slavery and human trafficking occurring in our supply chains.
The output of this activity will serve as a measure of our effectiveness in combating slavery and human trafficking.
Risk Assessment and Management
The two main areas of risk in relation to modern slavery for the Group relate to our contractual arrangements and the recruitment of staff. The steps that we will take to manage these risks ensure that consideration of the modern slavery risks and prevention are added to our Procurement Policy review process as an employer and producer of goods and services.
We will also ensure when undertaking a further review of relevant people policies they include the consideration and prevention of risks of engagement of people or groups.
The Group consider the risk related to the Modern Slavery Act compliance is deemed low, for the following reasons:
- the Group is almost entirely UK based and operates in the field of financial services
- our supply chain is limited to goods and services which are required to support an organisation of this nature (e.g. support services and computer hardware / software)
- use of non-UK based suppliers is limited.
Training
We will ensure that staff involved in procurement and recruitment receive training and guidance on modern slavery and ethical employment practices.
Contact
If you suspect modern slavery, report it to the Modern Slavery Helpline on 08000 121 700 or the Police on 101. In an emergency call 999, your information could save a life.
In addition, staff and external contacts can report any concerns in relation to potential modern slavery linked to AFH operations to peopleoperations@afhgroup.com.
Alexis Larvin, Chief Risk Officer
AFH Financial Group Ltd
Date: 17 October 2024