1.1 This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (Act) and applies to Global Reach Group Limited and all its trading subsidiaries, Global Reach Partners Limited, Global Reach Markets Limited and Foreign Currency Exchange Limited (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 and relationships. 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 suppliers within the UK. 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:
- Supply of food & drinks
- Office and IT supplies
4.3 GRG is implementing a due diligence process when approving new suppliers which takes into consideration the geographical location, industry sector and nature of the commercial transaction, and assesses the risk from a slavery and human trafficking perspective.
4.4 As a business we seek to build relationships with reputable suppliers. All suppliers entering into new or extended contracts with GRG are required to self-certify as to whether the Act applies to them and that they meet the requirements of the Act.
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, harsh or inhumane treatment is tolerated.
6. Responsibility for the policy
6.1 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.
6.2 The Chief Financial Officer 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.
7. Compliance with the policy
7.1 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. Employees are required to avoid any activity that might lead to or suggest a breach of this policy.
8.1 This statement was approved by the Board of Directors of Global Reach Group Limited on 27th June 2018 and will be reviewed annually. It is available on our website at www.globalreachgroup.com.