Modern Slavery and Gender Pay
In accordance with Section 54 of The Modern Slavery Act 2015, this statement is an update on the progress that Schroders Personal Wealth (SPW) has made during 2020 towards combatting modern slavery in our business and supply chains. It also outlines our plans for 2021
We recognise the responsibility we have towards our clients, stakeholders, our employees and society as a whole and corporate responsibility matters enormously to us.
SPW is a financial planning company, established on June 1st 2019. It is backed by one of the UK’s leading fund managers and one of the UK’s leading retail banks,.
Our purpose is simple: to help people realise their dreams by unlocking the power of financial planning. Our advisers are therefore highly qualified, with professional expertise across financial planning and investments.
SPW’s head office is in London and we have 10 other regional offices including Edinburgh, Cardiff, Manchester, Leeds, and Birmingham. We employ more than 650 employees, all of whom work in the UK.
Suppliers play an important role at SPW. 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. We therefore work closely with our suppliers to ensure they meet their contractual obligations and comply with all applicable laws, regulations, and industry best practice.
Our current supply base comprises approximately 200 suppliers, the majority of which are in professional services sectors such as management consultancy, legal, HR, IT, marketing and communication. They are primarily located in the UK, with some in other European countries and North America.
In almost all cases our suppliers are medium to long-term service providers, rather than seasonal providers. We recognise that sectors such as cleaning, catering, property, and security are potentially higher risk, especially where separately outsourced, therefore we have mostly consolidated these under one long-term managed service agreement. This enables us to better monitor and manage this risk.
Policies in relation to Slavery and Human Trafficking:
The policies and procedures we have in place reflect our commitments to operating responsibly and ethically as a business and as individual employees. These policies help us to embed modern slavery considerations into our operations and include payment of the Real Living Wage. In addition, our Whistleblowing policy encourages employees and members of our supply chain to report any actions they believe to be unsafe, unethical or unlawful. SPW employees are required to familiarise themselves with relevant policies by way of mandatory training requirements and a breach of SPW internal policies can result in disciplinary action including dismissal.
Our employment vetting standards apply to all permanent and non-permanent employees that we recruit, including temporary staff and contractors. Our recruitment procedures ensure that all prospective employees are legally entitled to work in the UK. 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 on-boarding process. 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. Before establishing a business relationship with a supplier we conduct a number of on-boarding checks to assess potential financial, legal and regulatory exposures. It provides insight into the suppliers’ structure, operations, culture, supply chain and customer relationships.
SPW’s standard contractual terms and conditions incorporate clauses requiring suppliers to confirm that slavery and human trafficking is not taking place and that they are complying with the requirements of the Modern Slavery Act. SPW does not permit its key suppliers to subcontract work without SPW consent.
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 helps us ensure that suppliers continue to fulfil our needs and have the capabilities to meet our regulatory and legislative obligations. All our suppliers undergo an annual due diligence refresh, and we seek assurance that they have effective processes in operation to continue to support our business.
To help identify risk, SPW subscribes to Risk Ledger, a supplier qualification system for the financial sector. Qualifying each of our suppliers 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, Sourcing 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.
In 2020, we implemented a new Sourcing and Supplier Management system. This has allowed 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.
Training which highlights the issues with modern slavery and human trafficking is mandatory for all colleagues and completed on an annual basis, and is subject to a completion audit trail. This training includes the ‘red flags’ that will assist colleagues in detecting the signs of modern slavery and how to report it. 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. SPW regularly reviews and updates its training materials to deal with new risks.
Key Performance Indicators
We recognise that it’s difficult to put a numerical value on the outcomes and impacts of an approach to tackle modern slavery. The Key Performance Indicators (KPIs) we’ve adopted for our activities and progress for 2020 are:
Zero instances of modern slavery (or wider human rights issues) reported in our business or supply chain through our grievance mechanisms
100% completion rate of our employees required to do the modern slavery e-learning module
100% of critical suppliers that have agreed to our Supplier Code of Conduct
100% (139) new suppliers have been issued with modern slavery due diligence questionnaires
SPW 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. Initiatives that we are looking to implement in 2021 include:
reviewing the frameworks and disclosures that will promote our commitment to responsible and sustainable business behaviours
implementing a new Risk Management system which will allow us to risk score our supplier portfolio, and produce additional MI to assist in the ongoing monitoring of our supply chains
validating a sample of the vetting and background checks our resource suppliers have conducted on their staff
This statement was approved by the Board of Directors of Schroders Personal Wealth and signed by the CEO on 29th June 2021 and will be reviewed and updated annually.
Mark Duckworth, CEO at Schroders Personal Wealth
Gender Pay Gap
Our vision is for all colleagues, whatever their role or circumstance, to have the resources and flexibility they need to achieve what’s important to them, both inside and outside work. We are committed to doing more to ensure all colleagues have equal opportunities, for example, through promoting agile working, supporting career progression of those with high potential, and being certain our recruitment process leaves no room for bias. Measuring and addressing the gender pay gap plays a huge part.
The gender pay gap is the measure of the difference in average pay between all men and all women across an organisation, expressed as a percentage. It is regardless of their role, seniority, length of service or location and any other differentiating factors. It helps us to identify what is working as well as addressing where more action is needed to support and empower women as we grow our business. This is our first Gender Pay Report as a business, and we are committed to monitoring the numbers closely over the coming years, and doing more to improve gender diversity.