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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 2019. Charles Stanley is required to make this statement pursuant to section 54(1) of the Modern Slavery Act 2015 (“MSA”). The Statement was approved by the Charles Stanley Group Board on 24 September 2019.

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, Charles Stanley is at very low risk of exposure to Slavery and Human Trafficking issues. However, the Company continues to take its responsibilities seriously and has sought ways to champion better work and working lives and to raise awareness of the issues of Modern Slavery and Human Trafficking.

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 other sectors. It is not authorised to conduct any financial services outside of the UK, and save for the outsourcing of some information technology testing operations to a company based in India and reliance on overseas counterparties for the conduct of share trading, it has no connection with supplier businesses outside the UK. In order to take a proactive stance against Modern Slavery, Charles Stanley insists that its suppliers and providers within the UK, such as cleaning contractors, recruitment consultants, stationary providers, law firms, design agencies and catering contractors, all confirm in writing that they have robust Anti-slavery policies and approaches to prevent Human Trafficking in place. The Company regularly reviews the contractual terms in place with its preferred suppliers to ensure that they remain pertinent and proactive – these records are reported to and monitored on a regular basis by the Procurement team within Finance.

Policies in relation to Slavery and Human Trafficking

Charles Stanley recognises the role it shares with its suppliers in tackling the growing issues of Modern Slavery. The Company is committed to a high level of ethical trading within our businesses, for our clients who expect this, and within the supply chain that we utilise. We have a role in seeking assurance from suppliers of their compliance with Slavery and Human Trafficking laws and confirmation that they take Anti-slavery precautions and actions. Charles Stanley is continuously seeking ways to improve and maintain our high ethical standards.
The Staff Handbook states the Company has a zero tolerance to Slavery and Human Trafficking and places a duty on all staff to report any potential infringement arising either internally or externally. Detailed background checks are carried out by an independent firm prior to new employees commencing work with Charles Stanley, which incorporate protections that should allow for the discovery of any human rights abuses and to ensure that Charles Stanley does not participate in any human trafficking practices. 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 Modern Slavery both within the UK and overseas and the illegality of Human Trafficking as well as an explanation the Company’s approach towards Anti-Slavery.

Charles Stanley also has various practices, procedures and policies to ensure compliance with all human rights laws and UK employment laws. 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 2018/19 financial year, the Group has continued to build on the approach introduced over the past few years. We remain concerned and committed to tackling Modern Slavery where we can, within the Company, through our suppliers and within the wider communities in which we operate. Activities have included: 

Due diligence processes

Although Slavery and Human Trafficking concerns are of a low risk to the business, Charles Stanley has introduced an approach to ensure on-going monitoring of suppliers. We assess and review Anti-slavery matters with existing suppliers at the time when each contract is reviewed and/or renewed, and always at inception with any new supplier. 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 as Charles Stanley applies to its own business in this regard. If, after enquiry, any organisation within its supply chain is unable to demonstrate their commitment to their obligations after enquiry, they will not be taken on as a supplier or their services will be terminated. During the 2018/19 review process, no contracts were terminated.

Training

Throughout 2018/19, 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 refreshed for all existing staff during 2019/20. 

Support and Awareness

In 2018 Charles Stanley set up a free and confidential helpline available to all employees, the data provided resulted in the Human Resources Director travelling to branches around the UK, as well as holding sessions in London, to raise awareness of topics raised, including confirming the Company’s zero tolerance of Slavery, bullying and Discrimination.

Supplier Due Diligence

The Procurement team continue to monitor suppliers and require evidence that significant suppliers have confirmed their compliance with the Modern Slavery Act. 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 2019/20.

Charities

Charles Stanley supports a Charity of the Year and during the 2018/19 period, it raised circa £30,000 for the stillbirth and neonatal death charity, SANDS. 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 Modern Slavery or Human Trafficking. A similar approach will be taken with all Charities of the Year going forwards.

Signed for and on behalf of the CSG Board by:

Paul Abberley