This Statement is made voluntarily on behalf of Record Currency Management Ltd and Record Group Services Ltd (“Record”, “we”, “our” or “us”) and is published pursuant to section 54 of the UK Modern Slavery Act (“the Act”) and the United Nations Global Compact Principles, of which Regord is a signatory of.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another for the exploitation for personal or commercial gain. This Statement outlines the steps Record has taken to detect and prevent modern slavery and human trafficking from occurring in our organisation and supply chains.
Our Company and Commitment
Record is a specialist currency and derivatives asset manager, providing solutions to institutional clients. Record operates in a sector and country which both have a relatively low risk of modern slavery and human trafficking. Neverthless, Record seeks to provide its services according to the highest ethical and professional standards and takes a zero-tolerance approach to modern slavery and human trafficking within its business acticities and supply chains.
Our Approach
Our apprach to combatting modern slavery and human trafficking is discussed further below:
Operational
We have a number of policies and procedures that govern the way we operate and aid us in identifying and mitigating modern slavery and human trafficking risk within our business. These include:
Detailed background checks which are carried out on all new staff and outsources contractors through an independent third party provider, ensuring that any history of human rights abuses, if known, will be flagged and identified prior to joining Record.
Staff conduct Notice and Code of Ethics policy which represents that standards by which all Record staff are expected to conduct their business.
Staff are encouraged to report any unprofessional or illegal behaviour through various channels described in our Staff Conduct notice. In addition, our Whistleblowing Policy enables staff to raise concerns anonymously about any suspected violations of the law or Code of Ethics, including concerns about modern slavery, to senior management without fear of recrimination.
Supply Chains
Record only deal with reputable and well-established suppliers and expect the same high standards from all of our suppliers, contractors and any other third parties.
Record’s suppliers are largely based in advanced OCED countries, mainly the UK, Europe and the USA. Further, our supply chain is relatively short and predominantly comprises high skilled professionals. As a result, we believe there is limited risk of modern slavery taking place in our supply chain. However, we recognise that certain goods and service requirements for our office facilities, such as office equipment, cleaning services and IT services, may carry a higher risk of modern slavery. Therefore, Record considers the risk of its supplier relationships on a case-by-case basis and assesses suppliers across four risk factors:
the type of workers they employ (e.g. migrant workers, base-skilled);
whether or not they operate a high risk business model (e.e. significant labour outsourcing, seasonality);
the nature of the goods or services they are providing us with (e.g. cleaning services, maintenance services); and
location (e.g. country ranking on the Global Slavery Index)
Where suppliers have been identified as high risk, due diligence is carried out by assessing company policy and procedures, as well as requesting a due diligence questionnaire to be completed. The company must provide appropriate evidence that it has satisfactorily assessed its own risk of involvement in modern slavery and has preventative measures in place.
Investment Process
Record has a responsible investment policy, which incorporates appropriate ESG considerations into its investment process. Record’s responsible investment policy (available at https://www.recordcrm/storage/uploads/docs/Responsible-Investment-Policy.pdf) sets out its approach to responsible investment, in line with its status as a signatory to the United Nations-supported Principles for Responsible Investment.
Ongoing Plans
Regularly review our approach to modern slavery and human trafficking in our supply chain to ensure our due diligence process is effective.
Implement training to educate relevant employees about the risks of modern slavery and human trafficking.
Continue to asses our ability to expand this process across all Records Group companies.
Implement a Supplier Code of Conduct agreement before the nect reporting period in April 2023.