Modern Slavery Act

This is the statement of steps that Financière has taken to ensure that slavery and human ‎trafficking are not taking place in our business or in our supply chains

Our Policy Relating to the Modern Slavery Act

This statement is made pursuant ‎to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes our Modern Slavery Act ‎Transparency Statement for the most recent financial year.‎

Financière, as one of the world’s largest independent financial strategic advisory groups, is rightly held to high ‎standards of ethics and integrity in all that we do. Our approach to business is a deeply-held sense of ‎responsibility to our people, to our environment and to the communities in which we operate. Although the impact of the Act predominantly vests within Financière, the initiatives taken in response ‎to the Act are built on a common set of values on which the Financière’s internal operations, relations ‎with stakeholders and investment decisions are based.‎

Following the publication of our slavery and human trafficking statement for the most recent financial year, Financière re-assessed (1) its current staff profile and recruitment practices (covering ‎employees, contractors and agency staff) and (2) its supply chain (with a focus on tier one suppliers). In ‎this risk assessment we looked at the potential for vulnerabilities in relation to slavery and human ‎trafficking, considering the probability of such risks materialising, the impact of them doing so, and the ‎control mechanisms we have in place that attempt to mitigate such risks.‎

Staff profile and recruitment practices

We have rigorous HR policies and practices which are in line with our obligations pursuant to the Act; ‎background checking procedures are thorough and apply equally to permanent employees as to ‎contractors. We have not found any evidence to suggest that modern slavery is present within our ‎business. Although we have assessed that we are at low risk in this respect, we remain alert to possible ‎risks of modern slavery and we will continue to adhere by our stringent HR standards.‎

Supply chain

Our first tier suppliers were categorised by the risk evident in the sectors and the jurisdictions in which ‎they operate. ‎

  • We reviewed our previously compiled list of high risk sectors where slavery and human ‎trafficking are considered to be particularly prevalent ‎
  • We also referred to the Global Slavery Index to determine the list of countries where slavery is ‎most widespread, as a proportion of the population

The composite parts of this double-headed approach of sector and jurisdiction will be reviewed ‎annually to ensure our methodology remains relevant and robust.‎

Using these two concepts of sector and jurisdiction we accorded our suppliers the appropriate rating ‎on the following basis:‎

  • Low risk supplier: a supplier that is BOTH (i) working in a sector which is considered to be low ‎risk, AND (ii) incorporated in (and predominantly operating within) a jurisdiction which is low ‎risk
  • Medium risk supplier: a supplier that is EITHER (i) working in a sector which is considered to be ‎high risk, OR (ii) incorporated in (or predominantly operating within) a jurisdiction which is high ‎risk
  • High risk supplier: a supplier that is BOTH (i) working in a sector which is considered to be high ‎risk, AND incorporated in (or predominantly operating within) a jurisdiction which is high risk.‎

The results of our due diligence found that the vast majority of our first tier suppliers were low risk ‎additionally we have some medium risk suppliers and a very small number of high risk suppliers. As a ‎response to this, in contracts with suppliers we implement a variety of measures depending on the ‎level of risk presented, including (1) asking that the supplier represents and warrants that they comply ‎with the Act (to the extent applicable) and other anti-slavery legislation, (2) requesting that the supplier ‎will adhere to our Anti-Slavery Policy, (3) specifying the level of background checks we want performed ‎on staff working on our contracts, and (4) requesting that certain high risk suppliers submit an annual ‎slavery and human trafficking report setting out the steps it has taken to ensure that slavery and ‎human trafficking are not taking place in any part of our business.‎

The risk assessment we completed will be repeated in each financial year in order to ensure that our ‎internal and external processes continue to be held to high and exacting standards. ‎

We are committed to rooting out instances of abuse in our business and supply chains and re-affirm ‎our zero-tolerance approach to slavery and human trafficking.‎