TMF UK Modern Slavery Statement

SLAVERY AND HUMAN TRAFFICKING STATEMENT | TMF UNITED KINGDOM AND ITS UNITED KINGDOM AFFILIATED ENTITIES | 2020

TMF Group is a global organisation with a presence in over 80 countries around the world. TMF United Kingdom (UK) and its UK affiliated entities (hereafter “TMF UK”) understands its obligations under the Modern Slavery Act 2015 (hereafter “The Act”) but also its obligation to uphold the highest standards in ensuring that we contribute to a fair and ethical world together with TMF Group. TMF UK is committed to policies and procedures to combat slavery and human trafficking in our supply chains and in all other parts of our business.

According to The Act, modern slavery refers to slavery, servitude and forced or compulsory labour. We recognise that modern slavery is a crime which affects vulnerable people across a host of industries and businesses. It also results in enormous trauma to survivors wherever they are; both in the UK and abroad. TMF UK’s commitment to the spirit and obligations under the Act are outlined within this statement.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

TMF UK and TMF Group are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Procurement Policies reflect our commitment to acting ethically and with integrity in all our business relationships. This includes implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. TMF UK also recognises the role of financial service providers in combatting modern slavery and human trafficking globally. In addition to procurement, we have detailed Know Your Client / Anti-money Laundering policies to ensure we Know Our Customer and their source of wealth, and that we only transact with individuals and organisations who meet the highest standards of compliance. During the next fiscal year TMF Group will be reviewing our Procurement Policies to ensure they are fit for the current and future purposes of the organisational structure and growth.

CUSTOMERS

TMF Group’s client acceptance and ongoing monitoring includes the completion of detailed risk assessments and continuous monitoring and review of our clients.  All new clients to TMF UK as part of TMF Group must first be vetted by the local office compliant with local regulatory and TMF Group compliance standards, and are then independently reviewed by our Group Compliance function. Where detailed procedures are completed, these include but are not limited to, identifying ultimate beneficial owners and controllers and independently reviewing publicly available information on the prospective client.

TMF Group also have ongoing monitoring procedures in place to comply with the EU’s AML Directive and other relevant regulations. Full reviews of clients are completed periodically in accordance with the client risk rating. Escalations can be made to the TMF Group Acceptance Committee for final decision during take on and periodic reviews, when significant risks to TMF Group’s risk appetite may be present.

OUR SUPPLY CHAIN

TMF UK generally feels that it operates in a relatively low risk industry for modern slavery and human trafficking.  However, this risk is increased when we engage suppliers of products and services.  From a risk management perspective, we have adopted a risk-based approach in managing supply chain risk. This approach includes identifying and reviewing suppliers and vendors that fall within industries that can carry higher risk and establishing appropriate controls or mitigations; an example of which is due diligence questionnaires. TMF Group utilise a centralised independent procurement team, who ensure the highest standards are maintained across the organisation.

EMPLOYEES

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, TMF UK as part of TMF Group provides information and training to our staff involved in procurement, new client onboarding and internal finance.  We continue to update and develop training for all new employees and for all existing employees on a periodic basis. In 2019, TMF Group achieved 100% acknowledgment of each employee’s binding responsibility to uphold the TMF Group Code of Conduct, which specifically includes TMF Group’s commitment to human rights and fundamental labour rights, and is extended to the relations that TMF Group has with subcontractors, agents, consultants, contractors, interns and trainees.

If an employee has any concerns, TMF Group have detailed policies and procedures setting a standard approach for dealing with these concerns and the individuals an employee should speak with. This includes a whistle-blowing policy with various internal reporting options that allow employees to raise concerns confidentially and if desired, anonymously. During the next fiscal year TMF Group will finalise the Whistle-blower awareness campaign, which includes an all staff training and internal guideline for the stakeholders involved in the speak up channels or reporting.

This statement is made pursuant to Section 54-1 of the Modern Slavery Act 2015.

SIGNED

KEVIN BUTLER
MANAGIND DIRECTOR - UKI