Modern Day Slavery and Human Trafficking Policy

Modern Day Slavery and Human Trafficking Policy

Modern slavery is a crime and a violation of fundamental human rights. The Company is fully committed to a work environment and supply chain that is free from human trafficking and slavery. The Company will not tolerate or condone human trafficking or slavery in any part of its global organisation.

It is for this reason that every office, regardless of where it operates within the world, adopts the core values to protect and defend human dignity and human rights in our global business practices and supply chain.

Full Policy

Purpose

This policy establishes global standards regarding the UK’s Modern Slavery Act 2015 (MSA). If local laws or regulations have stricter requirements, then these will supersede the requirements stated in this policy.

Scope

This policy applies to the entire Company workforce, operations and subsidiaries in terms of all dealings and transactions in all countries where the Company operates. The entire company workforce including others acting on behalf of the Company are required to read, understand and abide by the provisions referenced in this policy, including its suppliers.

Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. The Company is fully committed to a work environment and supply chain that is free from human trafficking and slavery. The Company will not tolerate or condone human trafficking or slavery in any part of its global organisation.

It is for this reason that every office, regardless of where it operates within the world, adopts the core values to protect and defend human dignity and human rights in our global business practices and supply chain.

Business Structure

FE Fundinfo is a global business with offices operating in the UK, India, Europe and Australia. The business is a leading service provider to the fund industry with the objective of creating greater efficiencies and transparency.

The company’s clients are Asset Managers, Fund Distributors, Independent Financial Advisers, Insurance and Life & Pension companies and private Investors.

The Company has given careful consideration to Section 54 “Transparency in Supply Chains” of the MSA and other similar legislation. The review has concluded that the services we provide are unlikely to be associated with slavery or human trafficking.

Range

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control.

Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Employees are further encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chain of any supplier tier at the earliest possible stage.

If employees believe or suspect a breach of this policy has occurred or that it may occur they must notify their manager or report it as soon as possible by contacting the Human Resources Department based in the UK.

If an employee is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, the matter should be raised with their manager or by calling the Human Resources Department.

Our aim is to encourage openness and we will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any retaliation due to reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

Responsibility

The Director of Legal & Compliance has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy as part of the Global Code of Business Conduct.

Our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Training

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

Employees in the supply chain organization are given additional training on the process of performing the necessary due diligence and inclusion of the necessary language into supplier contracts to ensure that our supply chain is free from slavery and human trafficking.

Breaches

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

This Global Policy annually reviewed and approved by the Board of Directors.