Modern Slavery and Human Trafficking Statement
In accordance with the provisions of Section 54 of The Modern Slavery Act 2015, this statement is an update on the progress that Schroders Personal Wealth have made during 2019 and our plans for 2020 towards combatting modern slavery in our business and supply chains. Corporate responsibility matters enormously to us; we recognise the responsibility we have towards our clients, stakeholders, our employees and society as a whole.
Schroders Personal Wealth is a financial planning company, established on June 1st 2019, and backed by Lloyds Banking Group plc and Schroders plc. At Schroders Personal Wealth, our purpose is simple: to help customers benefit from financial advice that is relevant to them and their financial wellbeing. We know there is a growing need for financial advice and it’s going to continue to grow. By bringing together two leading financial services companies – one from banking, one from investment management – we will offer a personalised financial planning service to more people than before. We employ approximately 500 employees (on a full-time equivalent basis), all of whom work in the UK.
Suppliers play an important role in Schroders Personal Wealth. Appropriate collaboration with suppliers helps to increase our competitive advantage by streamlining resources, enhancing expertise, and opening up markets and clients. However, we recognise that we may face various potential risks from suppliers, including reputational, compliance and integrity risk, therefore we work together with our suppliers to ensure they meet their contractual obligations and comply with all applicable laws, regulations and industry best practice.
Our active supply base currently comprises of approximately 200 suppliers, the majority of which are in professional services sectors such as management consultancy, legal, HR, IT, marketing and communication and are primarily located in the UK, with some in other European countries and North America. We recognise that sectors such as cleaning, catering, property and security are potentially higher risk, especially where separately outsourced, therefore we have consolidated these under one managed service agreement. This enables us to better monitor and manage this risk.
Policies in relation to Slavery and Human Trafficking:
We have a number of policies and procedures in place that reflect our commitment to operating responsibly and ethically as a business and as individual employees. These help us to embed modern slavery considerations into our operations. Our policies include; Colleague, Sourcing, Speak Up (whistleblowing) and Anti-Bribery. Our Code of Responsibility provides clear guidelines for doing business fairly and responsibly. Our Code of Responsibility encourages employees to report, through our whistleblowing service, Speak Up any actions that are unsafe, unethical or unlawful. SPW employees are required to familiarise themselves with relevant policies by way of mandatory training requirements.
In our internal operations, our Pre-employment Vetting Standards, apply to all permanent and non-permanent employees that we recruit, including temporary staff and contractors. We also use a number of recruitment agencies to fill roles. UK agencies are bound by contracts which require compliance with specific Modern Slavery and Anti-Bribery clauses.
We expect all suppliers to conform to our Code of Supplier Responsibility which we share through the supplier contract. It defines our expectation in terms of responsible business behaviour, including human rights and labour issues.
We undertake due diligence on all our suppliers and have an established framework setting out the accountability for on-going performance measurement to monitor, review and manage these relationships. We operate two lines of defence as part of our Supplier Management Framework - our approach is risk-based and proportionate, taking into account the nature, scale and complexity of our business. Our defence covers the key stages of the procurement lifecycle from gathering requirements, supplier selection, due diligence, negotiation and contract award, supplier management and exit or renewal.
First Defence: Pre-Engagement Due Diligence Before establishing a business relationship with a supplier we conduct a number of on-boarding checks to assess potential financial, legal and regulatory exposures of prospective third party suppliers. It provides insight into the suppliers’ structure, operations, culture, supply chain and customer relationships. In addition, we assess all our suppliers using our Automatic Portfolio Monitoring (APM) system - a risk screening tool allowing us to monitor compliance with anti-bribery, sanctions and related prohibitions policies.
Second Defence: Ongoing Supplier Monitoring Once the relationship is formed, we ensure that the supplier and its performance is monitored throughout the relationship lifecycle, not just at the on-boarding stage. Ongoing monitoring via a number of key activities help us ensure that suppliers continue to fulfil our needs and have the capabilities to meet our regulatory and legislative obligations. All of our material suppliers undergo an annual due diligence refresh, and we seek assurance that there are effective processes in operation to continue to support our business. Schroders Personal Wealth subscribe to a third-party managed supplier qualification system for the financial sector – this ensures we adopt a standardised approach to compliance and assurance, which forms an integral part of our supply chain management. Should a supplier provide an answer that is non-compliant with the UK Modern Slavery Act, Supplier Managers are required to investigate and manage through to resolution prior to contract signing. If a modern slavery issue is identified during an annual review of an existing supplier and deemed sufficiently serious, a review of contract terms is undertaken including the right to terminate.
Completion of a Fraud and Financial Crime training module is mandatory for all colleagues and completed on an annual basis - all new hires are required to complete the training module as part of their induction. This training includes a specific modern slavery case study and the ‘red flags’ that will assist colleagues in detecting and reporting this activity. This is further supported by training for colleagues in specific roles such as Sourcing and Supplier Management covering the requirements of the UK Modern Slavery Act and the risks of slavery and human trafficking. It is available for colleagues to replay and download for future reference.
In 2020 we will be implementing a new Sourcing and Supplier Management system. This will allow us to ensure centralised visibility of all of our contractual relationships, while enabling us to prioritise activities on key areas of contract risk and ongoing supplier management. As part of this implementation we will augment key supplier information captured at pre-engagement stage, to enrich our risk identification and highlight any potential areas of concern for us to address.
Schroders Personal Wealth will continue to monitor, embed and evolve the way we identify and mitigate modern slavery and human trafficking risks in our business and supply chain. No modern slavery concerns were identified as part of current assessment procedures of our supply chain.
This statement was approved by the Board of Directors of Schroders Personal Wealth on 24 June 2020 and will be reviewed and updated annually.
James Rainbow, CEO at Schroders Personal Wealth