This statement comprises the Slavery and Human Trafficking statement of Charles Stanley & Co. Limited (“CSC”), its subsidiaries and parent company (together “Charles Stanley” or the “Group”) for the financial year ending 30 September 2022, in accordance with section 54(1) of the Modern Slavery Act 2015 (“MSA”).
Charles Stanley provides a range of wealth management services within the UK to both private and institutional clients. Given the nature of Charles Stanley’s operations, it is at very low risk of exposure to slavery and human trafficking issues. However, the Group takes its responsibilities very seriously with a zero-tolerance approach to slavery, human trafficking or forced labour in any part of our business or supply chain.
Everything we do is driven by our core values which define how we work with our clients, colleagues, supply chain and the wider communities within which we work. Our values of caring for each other and promoting fairness and transparency extend to our colleagues, suppliers and stakeholders who we expect to align with our values.
Clear procurement processes and controls are in place with all suppliers and providers. The majority of our supply chain is made up of service providers based in the UK who we consider are generally at a lower risk of modern slavery and human trafficking than some overseas service providers. Where we outsource or place reliance on key suppliers in higher risk jurisdictions, we seek to put in place clear contractual obligations with regards to anti-slavery and human trafficking laws or ensure they are required to comply with international human rights laws. Clear procurement processes and controls are in place with all suppliers and providers, such as cleaning contractors, recruitment consultants, stationary providers, law firms, design agencies, IT software and hosting providers, and catering contractors.
We regularly assess and review anti-slavery matters with existing suppliers when each contract is reviewed and/or renewed, and at inception with new suppliers. This includes, where appropriate, the insertion of provisions into written contracts which oblige suppliers to comply with the MSA and hold them to the same standards that Charles Stanley applies to its own business. If any organisation within its supply chain is unable to demonstrate their commitment to their obligations, they will not be taken on as a supplier or their services will be terminated.
Charles Stanley recognises the role it shares with its suppliers in tackling the growing issues of slavery.
We have various practices, procedures and policies to ensure compliance with all human rights laws and UK employment laws. Our Staff Handbook states the Group has zero tolerance for slavery and human trafficking and places a duty on all staff to report any potential infringement arising either internally or externally. At the Group induction event – held for all new staff at the corporate head office within two months of their joining - there is a specific training session on issues relating to slavery and human trafficking.
Key policies include:
Charles Stanley has also committed to pay its staff not less than the current Living Wage (which exceeds the UK’s national minimum wage).
Throughout the 2021/2022 financial year, the Group has continued to build on the approach introduced over the past few years. Activities have included:
Training remains front and centre on slavery and human trafficking and is included within our annual compulsory training for all staff in the business to further ensure all staff are aware of all their rights and obligations. This training is also included in the new joiner induction, which is a requirement for all new, part and full-time staff. Our training aims to encourage all staff to be aware of potential signs of modern slavery throughout the Group including in relation to suppliers, clients and other counter parties.
Through our whistleblowing procedure, staff are encouraged to report any concerns in confidence and anonymously with incidents escalated to the Board and the executive management team so that they can be dealt with effectively.
Regular engagement with staff including our annual online staff survey which enables people working at Charles Stanley to raise issues of concern, including worries over slavery, bullying and discrimination. During 2021/22 further surveys were undertaken to assess staff morale and well-being and no concerns relating to slavery, bullying and discrimination were raised. Further surveys will take place regularly over the forthcoming financial year.
The Procurement function continues to monitor suppliers and requires evidence that significant suppliers have confirmed their compliance with the MSA. During the 2021/2022 review process, no contracts were terminated because of non-compliance.
On-going developments to Charles Stanley’s key supplier due diligence process and the on-going review of their contracts are scheduled to continue during 2022/2023.
Charles Stanley supported Open Palm, our Charity of the Year during the 2021/22 period. Prior to agreeing to support the charity, Charles Stanley sought confirmation of the charity’s activities in relation to the MSA to ensure that no proceeds could be used to support slavery or human trafficking. A similar approach will be taken with all charities going forwards.
We remain concerned and committed to tackling slavery where we can, within the Group, through our suppliers and within the wider communities in which we operate.
Signed for and on behalf of the CSG Board by: Paul Abberley
This statement was approved by the Board on 28 November 2022