Fluent Money Group Modern Slavery Statement 2023
This statement sets out the actions that Fluent Money Group (FMG) has undertaken to review the potential modern slavery risks that it might face, and to manage its processes that are aimed at ensuring that there is no slavery or human trafficking in its business or supply chains.
As part of the Financial Services sector, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
Organisational Structure and Supply Chains
We have over 400 employees who are committed to supporting the day-to-day operation of the firm, including overseeing the activities of its subsidiary entities.
The nature of FMG’s supply chain reflects the fact that it is primarily a recipient of services, rather than goods and materials. Essentially, it relies on a mix of general business suppliers (ranging from facilities management support to technology solutions), as well as financial services providers, such as mortgage providers and insurance providers. The relationships with many of these key suppliers and outsourcers are well-established, with appropriate governance and oversight procedures in place.
Process and Risk Assessments
FMG has implemented key processes to assess whether or not particular activities present material risks in relation to slavery or human trafficking. Specifically:
- It holds a Risk Register of all operations, and regularly reviews this in the context of supply chain and business operations.
- There are no high-risk activities identified in relation to modern slavery or human trafficking.
As set out below, a series of policies have been established and reviewed jointly by the Finance, Operations, and the Risk & Compliance teams. These are designed to set out the appropriate steps for assessing business activity and supply chain exposure and to enable risks assessments to be appropriately undertaken, with any known, or suspected, instances of slavery or human trafficking being fully investigated and reported.
FMG operates the following policies that describe its approach to the identification of modern slavery and human trafficking risks and the preventative steps to be taken in its operations:
- Whistleblowing policy– all employees and stakeholders are encouraged to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for individuals to make disclosures, without fear of retaliation.
- Employee Handbook- The organisation’s employee handbook, including its ‘Behaviours Framework’, clearly sets out to employees the actions and behaviour expected of them. The organisation strives to maintain the highest standards of conduct and ethical behaviour in its operations, including managing its supply chain.
- Supplier Relationship Policy- The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.
- Recruitment & Selection policy- The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency before accepting workers (although in general it does not use agency staff due to the nature of our regulated business).
Procurement and Due Diligence
FMG continuously reviews and enhances its procurement policies and procedures to better document and manage its relationships within its supply chain.
Naturally, the starting point for such relationship management and record keeping is the due diligence undertaken when considering taking on new suppliers, which includes:
- Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
- Evaluating the modern slavery and human trafficking risks of each new supplier;
- Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
- Conducting supplier audits or assessments through the organisation’s own employees or third-party auditor, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
- Taking steps to improve substandard suppliers’ practices, including providing advice to suppliers, sometimes through a third-party auditor, and requiring them to implement action plans;
- Asking suppliers to confirm their compliance with our standards and requirements in order to provide products or services to our business; and
- Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
FMG continues to review its key performance indicators (KPIs) in light of the requirements of the Modern Slavery Act 2015. As a result, it:
- Operates a system for supply chain verification, whereby the organisation evaluates potential suppliers before they enter the supply chain; and
- Reviews its existing supply chains, whereby the organisation evaluates all existing suppliers.
To better understand and respond to potential slavery and human trafficking risks our employees are given whistleblowing training, and suppliers are also made aware of our expectations in relation to modern slavery.
This statement has been approved by FMG’s board of directors on 11/05/2023.