1.1 This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (Act) and applies to the Global Reach
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
• 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.
5.1 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.
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.