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Slavery and Human Trafficking Statement

This statement comprises the Slavery and Human Trafficking statement of Charles Stanley Group PLC (“Charles Stanley” or the “Company”) for the financial year ending 31 March 2020, in accordance with section 54(1) of the Modern Slavery Act 2015 (“MSA”).

The Business

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 Company takes its responsibilities seriously with a zero-tolerance approach to slavery, human trafficking or forced labour in any part of our business or supply chain.      

Supply Chains

Charles Stanley does not act as a producer, manufacturer, or retailer of any physical goods and, as a financial services provider, it has a relatively straightforward supply chain compared to many other sectors. Apart from outsourcing some information technology operations to a company based in India and reliance on overseas counterparties for the conduct of share trading, it has no connection with overseas suppliers.  Clear procurement processes are in place with all suppliers and providers, such as cleaning contractors, recruitment consultants, stationary providers, law firms, design agencies 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 also includes, where appropriate, the insertion of provisions into written contracts which oblige suppliers to comply with the Modern Slavery Act 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.

Policies in relation to Slavery and Human Trafficking

Charles Stanley recognises the role it shares with its suppliers in tackling the growing issues of slavery and is continuously seeking ways to improve and maintain its high ethical standards.

It has various practices, procedures and policies to ensure compliance with all human rights laws and UK employment laws. Its Staff Handbook states the Company 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:

  • Equal Opportunities Policy
  • Whistleblowing Policy
  • Harassment Policy
  • Health and Safety Policy
  • Grievance Procedures

Charles Stanley has also committed to pay its staff not less than the current Living Wage (which exceeds the UK’s national minimum wage).

Actions Taken and Planned

Throughout the 2019/20 financial year, the Group has continued to build on the approach introduced over the past few years. Activities have included: 

Throughout 2019/20, the annual compulsory training for all staff in the business has been developed to include slavery and human trafficking to further ensure all staff are aware of all their rights and obligations. As mentioned above, this training is included in the new joiner induction, which is a requirement for all new, part and full-time staff and will be provided to all existing staff during 2020/21. 

Support and Awareness

In 2015 Charles Stanley launched an annual online staff survey which enables people working at Charles Stanley to raise issues of concern, including worries over slavery, bullying and discrimination. During the pandemic two further surveys were undertaken to assess staff morale and well-being and no concerns relating to slavery, bullying and discrimination were raised.

Supplier Due Diligence

The procurement team continues to monitor suppliers and requires evidence that significant suppliers have confirmed their compliance with the Modern Slavery Act. During the 2019/20 review process, no contracts were terminated.

On-going developments to Charles Stanley’s significant supplier due diligence process and the on-going review of their contracts are scheduled to continue during 2020/21.

Charles Stanley supports a Charity of the Year and during the 2019/20 period it raised circa £40,000 for Cardiac Research in the Young (CRY) that funds research and support for those impacted by cardiovascular disease and other heart ailments. Prior to agreeing to support the charity, Charles Stanley sought confirmation of the charity’s activities in relation to the Modern Slavery Act 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 Company, through our suppliers and within the wider communities in which we operate.

Signed for and on behalf of the CSG Board by:

Paul Abberley