Modern Day Slavery

Overview

This document records the firm’s commitment to respect human rights in the workplace, including the right to a workplace that is free from discrimination and aligns with our company values. The firm continues to focus on its approach to adopting sustainable and environmental considerations across its business practices and has included ESG as part of its Annual Risk Assessment for 2024 along with the inclusion of an additional firm-wide policy relating to the Anti-Greenwashing Rule that came into effect in May 2024.

The provision of services to our clients may be linked to modern slavery through association with the financial activities of perpetrators of these crimes and their victims. The firm’s library of Risk Management Policies assists us to identify these associations and documents channels for escalation.

Wealthfusion is committed to preventing the products and services offered from being exploited for criminal activity. One of the key areas of focus in this regard is connected to the Anti-Money Laundering and Terrorist Financing Policy and so this document should be read in conjunction with this additional policy and the Employee Handbook.

Purpose

This document is describing the authority and establishes the expectations for the management of Wealthfusion Limited’s (“WFL”) Regulatory Compliance program policies and procedures.

Areas Primarily Affected

This policy affects all WFL’s employees who are responsible for development, review or implementation of business policies and procedures in all jurisdictions that WFL operate.

Definitions

Policy – indicates “WHAT” needs to be included within the Compliance Program against regulatory requirements.

Procedure – indicates “HOW” the policy will be interpreted by documenting the processes that need to be adopted by WFL employees/contractors/temporary resources.

NOTE – there may be supplementary documents that will accompany a Policy and/or Procedure but these will be referenced within these documents.

Policy Statement

The firm’s policies are designed to comply with the local regulatory and legal frameworks but also to provide assurance to our client’s that the firm takes our role and responsibilities very seriously and will endeavour to mitigate risks connected to modern day slavery and corruption wherever possible.

Authority to Issue Policy and Procedures

Any policies that are driven by the need to adhere to and implement Regulatory Compliance activities can only be written and issued by the Head of Risk Management. However, the implementation of the policies will be the responsibility of the business, and these activities must be contained within a set of Regulatory Compliance procedures.

All policies and procedures will be included within a two-year review to ensure they remain current and up to date whilst remaining in line with the regulations and law.

Regulatory Framework Considerations

The firm’s Modern Day Slavery Statement is driven by the Modern-Day Slavery Act 2015 which can be found on the government’s website www.gov.uk.Firms who only meet the following criteria need to consider this Act:

Legal Entities will need to comply if:

  • They are a ‘corporate body’ or a partnership regardless of their incorporation/formation;
  • Conducts business either in full or in part in the UK;
  • Supplies goods or services to clients;
  • Has an annual turnover of £36 million or more;

Human rights are the basis rights and freedoms that belong to every person in the world. In the UK, human rights are protected by the Human Risks Act 1998. The Human Rights Act compels organisations to treat everyone equally, with fairness, dignity and respect.

Victims of Human Rights breaches are forced, threatened or deceived into a situation of subjugation, degradation and control which undermine their personal identified, sense or self. Human Trafficking is defined as the recruitment, transportation, transfer, harbouring or receipt of persons by means of threat, use of force, coercion, or deception for the purpose of exploitation

Modern Day Slavery is the exploitation of a person by another that has control over them. This includes:

  • Labour exploitation
  • Domestic servitude
  • Coerced criminality
  • Sexual exploitation
  • Child exploitation (criminal and sexual exploitation)
  • Poor working conditions
  • Slavery, domestic servitude and forced or compulsory labour is where ownership is exercised over a person, where all work or service exacted from that person is imposed by coercion or under threat of penalty.

Anyone can become a victim of modern day slavery, but more vulnerable people are more likely to be targeted by perpetrators, such as young people, women, those who have previously suffered abuse or violence, people without a home, displaced people including refugees, asylum seekers, people within the LGBTQ+ community, people living with disabilities, people struggling with money or debt, and minors within the welfare system. They are tricked or threatened into work and may feel unable to leave or report the crime through fear or intimidation. They may not recognise themselves as being considered a victim.

Alerts, Triggers and Flags

Business activities are potentially attracting individuals who support the activities shown above from seeking financial gains. This may be in relation to their ongoing business activities and through their supply chains and they may not recognise that these risks exist so careful consideration should be made if any of these indicators are present as part of the onboarding of new clients or third-party suppliers:

  • A business depending on migrant works to meet labour requirements;
  • Workers appearing fearful;
  • Workers who live on site to their normal place of work or in a property owned and/or managed by the business;
  • Workers who do not have an Employee Letter/Contract or other document that outlines their contracted terms;
  • Workers who may not have access to their government issued identification documents;
  • Lack of clear policies that demonstrate that a business complies with local labour laws regarding working hours and minimum wage thresholds;
  • Lack of Code of Conduct guidelines establishing the minimum standards expected of their employer ie. hours of work, days of work, wages and conditions;

High Risk Industries

In line with the list of high-risk industries that can be found within the AML Policy and Procedure documents, there are certain industry segments that could be more susceptible to supporting behaviours that are subject to the Modern-Day Slavery Act 2015 (this list is not exhaustive):

  • Construction
  • Agriculture and Fishing
  • Food production (ie. tea, rice, spices, coffee)
  • Sex Industry
  • Cash Intensive Businesses (ie. Car Washes, Nail Bars, Massage Parlours)
  • Hotels, Hospitality and Restaurants
  • Care Homes
  • Clothing and Fashion
  • Employment services
  • Transportation

Government and Regulatory Links

UK Government – Modern-Day Slavery Guidance

www.gov.uk/government/collections/modern-slavery

UK Government – Modern-Day Slavery Resource Packs

www.gov.uk/government/publications/modern-slavery-industry-factsheets

National Crime Agency – Modern-Day Slavery & Human Trafficking Page

www.nationalcrimeagency.gov.uk/what-we-do/crime-treats/modern-slavery-and-human-trafficking

Due Diligence and Risk Management Approach

As part of the Due Diligence approach that the firm adopts when onboarding new clients, third-party suppliers and employees, is the need to ensure clarity and confidence that the individual(s) remain aligned to the firm’s values and risk appetite statement.

The specific due diligence requirements are documented within the AML Policy and Procedures, however, to receive a holistic approach to the firm’s risk management program, reference should be made to other documents:

  • Employee Handbook
  • Code of Conduct and Conduct of Business Policy
  • Conflicts of Interest and Outside Business Policy
  • Anti-Bribery and Corruption Policy

As a multi-family office, our clients could be individuals or legal entities that wish to establish a business relationship with Wealthfusion. As a small investment management firm, we use a series of Custodian Banking Partners to execute investment trades on our client’s behalf and as part of this due diligence, we continue to monitor and assess the service that our Banking partners provide the firm. Wealthfusion also uses a series of other third-party suppliers to perform business activities such as Audit, Information Technology Support, Finance and Accounting Services as well as Legal Advice and with all of these firm’s we have assessed their risk to the firm as well as the service levels they provide.

The Relationship Managers, Operations and Customer Service team members are the primary points of contact for many of our clients. Each team member has clear ‘roles and responsibilities’ for conducting their role and every employee receives a customised mandatory training program at the start of the business year to ensure their knowledge of the regulatory frameworks remains current. Supporting the mandatory online training modules, are team events which allow employees to express their opinions to other colleagues in a constructive manner and is supported at all times by the Head of Human Resources. The firm operates a performance-based monitoring program which also allows for direct interaction and discussion with the Head of Human Resources should such a conversation be required.

Annual Risk Assessment

The Risk Management Team conduct an end-to-end review of all risk management program elements which identifies the firm’s overall ‘inherent risk’. An inventory of controls is then applied to each of the program elements to generate a ‘residual risk’ score and rating. The inclusion of new controls is mapped against the library of policy and procedure documents to ensure a holistic approach is adopted. Reference to AML controls, policies and procedures along with supporting documentation forms a key element to the annual risk assessment approach.

The entire Risk Management Program is audited once a year by an FCA accredited firm with any findings being included within the following year’s remediation program. The results of the Annual Risk Assessment are presented to the Risk Management Committee as well as the Board of Directors in Q1 of the following calendar year.

Training

The firm believes in continuous education and learning so that our employees are equipped to identify all Compliance and Financial Crime related matters, which will include criminal activity that supports through financial channels connections to modern day slavery.