Modern Slavery Statement
Voluntary Slavery and Human Trafficking Statement
We oppose slavery and human trafficking in all its forms. This statement sets out the steps we have taken in 2023-24 to ensure that there is no slavery or human trafficking in our business or in our supply chains.
About Us
We are a full-service risk and compliance consultancy practice operating in the United Kingdom predominantly for regulated clients in the financial services sector. Further details of our Services can be found at www.edmund.pro or by clicking here.
Our annual turnover is under £36 million. Although we are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015, we are making this voluntary statement to show our commitment to ethical trading principles and to set out the steps we are taking to identify risks and tackle modern slavery and human trafficking in our business and in our supply chains.
Our supply chains mainly consist of the following: IT service companies operating in the UK providing email, storage, CRM and accounting capabilities, independent freelance and/or small consultancy practices providing additional consulting or subject matter expertise, legal and professional services suppliers.
Policies and Our Commitment to Ethical Trading
We are committed to ethical trading principles and to acquiring goods and services without harm to others. Our anti-slavery policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
We are a member of the Association of Professional Compliance Consultants, member of the Consumer Duty Alliance and signatory to the Financial Vulnerability Charter. In addition, various of our partners and staff will be members (sometimes chartered members) of professional bodies.
Due Diligence and Risk Assessment
To help identify and monitor the risk of slavery and human trafficking in our supply chain we consider:
• The sector and industry in which our client and/or suppliers operate and whether this may be vulnerable to slavery and human trafficking;
• The specific business or transaction risk associated with a client or supplier, alongside services risk given that certain services might represent an increased risk, such as IT services; and
• Country risk where clients or suppliers are located in jurisdictions that may be vulnerable to slavery and human trafficking utilising data, for example, from the Global Slavery Index.
We also have in place systems and processes to i) identify and assess potential risk areas in our supply chains; ii) mitigate the risk of slavery and human trafficking occurring in our supply chains, iii) monitor potential risk areas in our supply chains, and iv) protect whistleblowers.
We vet suppliers and sub-contractors to ensure that they are committed to ethical labour practices. Our supplier due diligence includes assessments based on self-attestation and documentary/evidence-based reviews on a risk-adjusted basis against information/disclosures on supplier structure, policy framework, relationships, services, compliance and training. We also include anti-slavery and human tracking provisions in all our contracts with suppliers.
We only employ agency workers through reputable employment agencies that adhere to our anti-slavery and human trafficking policy (or equivalent policies).
Effectiveness in Combating Slavery and
Human Trafficking
We use the following key performance indicators (KPIs) to measure how effective we have been at ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:
• The percentage of suppliers and sub-contractors vetted for ethical labour practices;
• The number of inspections of direct suppliers and sub-contractors in our supply chains in the past year;
• The number of reported breaches in the past year; and
• Percentage of staff receiving training on identifying and addressing the risk of slavery and human trafficking in our business and supply chains.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.
