Modern Slavery Statement
We wish to remind all clients who have joined us through 2020 of our continued commitment to a zero-tolerance approach to modern slavery.
Weybridge Assets, Inc. (WA) has taken steps to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business. This statement is only in relation to WA and its business, not the business of its supplier firms. References to “our people” only refers to those individuals working on behalf of WA, not the suppliers.
In accordance with Section 54, Part 6 of the Modern Slavery Act 2015 (the Act), this statement sets out the steps that WA has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business. This Statement was reviewed and approved by the Board on 19 March 2021 and signed by our CEO, who is the owner of and responsible for the day-to-day implementation of, the Modern Slavery Policy (the ‘Policy’).
The Act requires commercial organisations supplying goods or services with a turnover of more than £36 million to prepare and publish an annual ‘Slavery and human trafficking statement’. The statement must set out the steps an organisation has taken, if any, during its financial year to ensure that slavery or human trafficking is not taking place in its business or supply chain.
What is modern slavery?
Modern slavery is an international crime, affecting an estimated 29.8 million slaves around the world – a growing global issue that transcends age, gender and ethnicities. Sadly, vulnerable people from overseas as well as across the UK and Europe, are forced to work illegally against their will across many different sectors from agriculture, construction, hospitality, retail, manufacturing, and more.
Our Business & Structure
Since opening our doors in 2004, the company’s vision has remained the same, to create clients by providing each and every customer with unparalleled levels of service and convenience. We are equally committed to conducting our business in a manner that prevents modern slavery.
Underpinning this is our culture, which is at the heart of our business. We recruit, train and lead our colleagues to create FANS in each of our communities. We are inclusive and diverse and we believe this approach means that our colleagues and us, as an organisation, are well placed to uphold the standards set out in our Policy.
We are committed to making a difference and delivering a different type of investing, keeping our products and services as straightforward as possible. We have our HQ in Singapore with a representative office in Moscow and plans for further global reach into the USA in 2022.
We provide investors with a variety of services, including:
- Personal Wealth Management
- Research & Analysis
- Financial Risk Management
- Fund Management
- Corporate Finance
- Timely Focused Recommendations
- Free Publications & Newsletters Subscription
- Underwriting Service
We are principally a wealth management, advisory and brokerage business, servicing both corporate and private clients worldwide through simple, transparent products.
The organisation and structure of our business has not changed materially since the publication of our previous Modern Slavery Statement in March 2020.
Since publishing our last Modern Slavery Statement, we now have over 72 colleagues, over 90% of whom are full time colleagues, paid no less than the National Real Living Wage.
Our Policy confirms that we will conduct all business with integrity and that we have a zero tolerance approach to modern slavery. We continue to be committed to acting professionally and fairly in all our business dealings and relationships wherever we operate, including enforcing appropriate systems and controls to ensure, on a risk basis, that modern slavery is not taking place in our business or supply chains.
We seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent and trusted. Our policies and procedures relating to the Modern Slavery Act are in line with our culture and values.
We also operate a Whistle-blowing Policy which encourages disclosure from any person, internal and external. WA thoroughly investigates any disclosure, overseen by the Whistle-blowing Champion, who is a member of the Board and reports, at least annually, to the Board on the effectiveness of the Whistle-blowing Policy.
Our Business & Supply Chains: Assessment and Management of Risk
Our business largely uses professionally qualified people employed directly by WA. Our people policies ensure fair treatment of our people around the world.
When we deal with a new supplier firm, a thorough due diligence process happens to ensure that the firm has a good reputation with appropriate practices in a number of areas including people and culture.
Supplier Due Diligence
To ensure all those in our business and supply chains comply with our Policy, we have developed our supplier assurance programme.
We continue to operate a triaging approach based on risk. When modern slavery risk is identified, we ask suppliers to:
- Implement due diligence to ensure that its officers, employees, associated persons and downstream suppliers comply with the Act.
- Attest that they have modern slavery guidelines in policies and standard terms, conduct regular risk assessments in relation to modern slavery, undertake modern slavery training and have not been subject to investigation or conviction as a result of activities relating to modern slavery.
Suppliers are required to update this attestation on an annual basis.
Our programme continues to develop and we have started with first tier suppliers but, during 2021, we are beginning to gather information on second tier suppliers.
We identified that we have 352 active third parties with whom we engage. Of these:
- 62% are Singapore based
- 20% are USA based
- 13% are UK based
- 0.1% (3) are based in India (Modern Slavery Prevalence Index Rank 53/167 and Vulnerability to Modern Slavery score 54.49/100)
- 0.04% (1) are based in South Africa (Vulnerability to Modern Slavery score 53.76/100)
- 4.86% are based in countries that either do not rank within the Top 60 of the Modern Slavery Prevalence Index or do not have a Vulnerability to Modern Slavery score over 50).
Of the 4 suppliers who are based in higher risk countries or have a higher vulnerability score, we are undertaking further assessment. In our previous Statement, we reported that 10 out of 85 suppliers who had revenue of more than £36 M had not published a Modern Slavery Statement and since publication:
- 4 have been exited
- 4 have now published a Statement
- 2 are based in the UK and USA where modern slavery risk is relatively low but we intend to engage with them in relation to non publication.
We have also reassessed 122 existing supplier relationships. Of these, we identified 18 may be vulnerable to modern slavery risk. We did on site assessments of 6 of them, as part of a separate audit programme, and we did not observe any modern slavery red flags. We will continue our programme to follow up with the remaining suppliers in 2021 to determine what processes they have in place to comply with the Act.
Customer Due Diligence
As a Brokerage, we are aware that the risk of modern slavery extends beyond the supply chain, potentially to clients. We have due diligence processes in place in relation to onboarding clients, to mitigate these risks, including Anti-Money Laundering (AML) Know Your Customer (KYC) checks at account opening and ongoing during the relationship.
To ensure that all colleagues are fully aware of our zero tolerance position and commitment to ensuring that there is no modern slavery in our business or supply chains we again required all colleagues to complete a computer based training package on modern slavery. As previously stated, this will continue to be completed annually by all colleagues.
We will continue to develop our approach to demonstrating the effectiveness of our Policy and processes to address the risk of modern slavery and remain committed to ensuring, in high risk areas, that modern slavery is not taking place in our business or supply chains.
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our Modern Slavery Statement for the financial year ended 31 December 2020. It has been approved by Weybridge Assets Board and will continue to be reviewed annually.