Slavery and human trafficking transparency statement

1. Introduction

1.1 This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (Act) and applies to the Global Reach

Group(GRG).

1.2 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as servitude,

forced and compulsory labour, slavery, and human trafficking. All of these have in common the deprivation by one

person of another person’s liberty in order to exploit them for personal or commercial gain.

1.3 This statement sets out GRG’s approach to dealing with the potential risk of slavery and human trafficking (as

defined in the Act) occurring within GRG’s supply chain or any part of its business.

 

2. GRG’s Business

2.1 GRG offers foreign exchange facilities, including spot, forward and option contracts as well as payment services, to

corporate and private clients across the globe.

 

3. Policy statement

3.1 GRG maintains a zero-tolerance approach to modern slavery and human trafficking. As a business, we are

committed to acting ethically and with integrity in all our business dealings. We will not knowingly support or do

business with any organisation that is involved in either.

3.2 Consequently, we are intent on implementing effective systems and controls to ensure modern slavery is not taking

place anywhere in our own business or in any of our supply chains. We expect the same high standards from all of

our contractors, suppliers and other business partners and by corollary we expect our suppliers to hold their own

suppliers to the same high standards.3.3 As part of our contracting processes, we are working towards including

specific contractual prohibitions against the use of forced, compulsory or trafficked labour.

 

4. Supply Chain

4.1 Based on the nature of our business, GRG believes it has a relatively straightforward supply chain. The vast majority

of our products and services are technology or office supply related and are provided by local suppliers within the

jurisdictions in which we operate. As such, we believe that the risk of slavery and human trafficking issues in our

supply chain is low. Accordingly, we have adopted a risk based approach to the assessment of and the due diligence

we carry out but recognise the importance of reviewing this approach on a regular basis to ensure compliance with

our legal requirements.

4.2 We have identified the following areas of our supply chain as having a higher risk in relation to modern slavery and

human trafficking:

• Cleaning

• Utilities

• Supply of food & drinks

• Office and IT supplies

4.3 As a business we seek to build relationships with reputable suppliers. All suppliers entering into new or extended

contracts with GRG will be required to self-certify as to whether the Act applies to them and that they meet the

requirements of the Act.

 

5. Employment

5.1 While GRG does not have, or consider that it needs a formal human rights policy, our employee policies are

consistent with general human rights principles and applicable human rights legislation. This approach applies to

all persons working for, with or on our behalf of GRG in whatever capacity, including employees, directors, officers,

agency workers, interns, contractors, external consultants, third-party representatives and business partners.

5.2 In addition to covering such issues as health & safety, training and remuneration, Global Reach’s employment

standards encompass the following:

• Employment shall never be coerced and shall always be freely chosen;

• Freedom of association and the right to collective bargaining are respected;

• Work conditions are safe and hygienic;

• Child labour is not used;

• No one is paid less than the minimum wage in their country of operation;

• Working hours are not excessive;

• No discrimination is practised and equality is promoted;

• No bullying or inhumane treatment is tolerated.

 

6. Responsibility for the policy

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations,

and that all those under our control comply with it.

 

7. Compliance with the policy

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the

responsibility of all those working for GRG. All members of staff of GRG, including employees, directors, officers, agency

workers, interns and contractors are required to avoid any activity that might lead to or suggest a breach of this policy.

 

8. Approval

This statement was approved by the Board of Directors of Global Reach Group Holdings (Jersey) Limited on 29th

November 2022 and will be reviewed annually.