Background
Modern slavery takes many forms. The most common are:
- Human trafficking. The use of violence, threats or coercion to transport, recruit or harbour people in order to exploit them for purposes such as forced prostitution, labour, criminality, marriage or organ removal.
- Forced labour. Any work or services people are forced to do against their will under threat of punishment.
- Debt bondage/bonded labour. The world’s most widespread form of slavery. People trapped in poverty borrow money and are forced to work to pay off the debt, losing control over both their employment conditions and the debt.
- Descent–based slavery. Most traditional form, where people are treated as property, and their "slave" status was passed down the maternal line.
- Slavery of children. When a child is exploited for someone else’s gain. This can include child trafficking, child soldiers, child marriage and child domestic slavery.
- Forced and early marriage. When someone is married against their will and cannot leave. Most child marriages can be considered slavery.
In the United Kingdom the relevant legislation covering these abuses is the Modern Slavery Act 2015 which can be found here.
Our Policy
As part of our commitment to combatting modern slavery we have put in place this policy which sets out our commitment and approach to this area.
This Policy covers the activities of Square Mile Investment Consulting and Research Limited, Square Mile Investment Services Limited and Ethical Money Limited (jointly referred to as "Square Mile").
Our Business
Square Mile provides investment research and consulting services and acts as an investment manager. The clients of Square Mile are generally FCA regulated firms who are based in the UK. Suppliers to the business and the office are also based in the UK and the Firm does not engage in activities that would open itself up to the risk of modern slavery or operate in jurisdictions where there is a risk of this occurring.
We have a robust recruitment and onboarding process with multiple checks built in to ensure all individuals employed by us have the right to work in the UK, are paid a fair salary in compliance with all relevant rules and regulations, and are not subjected to human trafficking or forced labour.
All employees acknowledge the Firm's Compliance Manual and Staff policies as part of their induction programme.
Square Mile takes a zero-tolerance approach to slavery and human trafficking within our operations and expect the same from any parties we deal with.
We consider that the risks of Modern Slavery in our business is low.
Due Diligence procedures
When engaging new suppliers or taking on new clients we will be mindful of the risks of modern slavery and exercise enhanced due diligence for suppliers and clients where we believe there is greater risk in this area.
Identifying assessing and managing risk
On an annual basis the risks of Modern Slavery will be reviewed and, if applicable, entered into our risk register.
Training and engagement available to staff
All staff have received a copy of this policy and senior management is available to answer questions if required. Formalised training is not considered necessary at this stage based on the fact that the risk of Modern Slavery in our business is low.
We also have a Whistleblowing Procedure in place which provides staff with the opportunity to raise any concerns they may have in relation to slavery or forced labour.