For the year ending 31 December 2019
James Hay Partnership Management Limited (along with the other members of its group) (together “James Hay”) provide retirement wealth planning solutions. With over 40 years’ experience, we have evolved with the market to become trusted by over 58,000* investors, holding over £27 billion* in pension and investment savings.
James Hay has a policy of zero-tolerance to modern slavery and has implemented controls to mitigate the risks of slavery and human trafficking occurring in our business or in our supply chain. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes our Modern Slavery and Human Trafficking Statement for the financial year ending 31 December 2019.
James Hay employs over 600 staff and is regulated by the Financial Conduct Authority (FCA). We are owned by Epiris GP Ltd, a UK-based private equity firm.
Our supply chain
James Hay’s commitment to eradicating modern slavery is embedded into our business through our Supplier Code of Conduct which sets our expectations as to behaviours and practices of our suppliers and reflects our own business values and standards.
As a provider of financial services, we do not have a very long or complex supply chain. Our main suppliers are predominantly UK based providers of goods and services that enable us to maintain and develop our operations. While we consider our suppliers to be at relatively low risk of engaging in practices of modern slavery and human trafficking, our Supplier Code of Conduct requires suppliers to comply with all applicable laws, thereby mitigating the risk that any practices which might amount to modern slavery.
Our Policies in relation to Slavery and Human Trafficking:
As part of our commitment and obligations under the Modern Slavery Act and other legislation relating to the detection and prevention of modern slavery, our Supplier Code of Conduct reflects our commitment to act ethically and with integrity in all our business relationships.
Our whistleblowing policy ensures a safe environment for any employee wishing to report any actual or suspected wrong-doing. We also conduct regular employee engagement surveys for our employees, which offers a further opportunity for employees to raise (in confidence) any concerns they may have regarding any wrong doing or breaches of law.
We strive to ensure that there is transparency in both our supply chains and our own business and look for the same standards from our contractors, suppliers and other business partners as we apply in our own business.
What we’re doing to prevent Slavery and Human Trafficking
James Hay mitigates the risk of modern-slavery in its business and supply chain through a number of controls including:
- Due diligence which is undertaken in respect of suppliers, the results of which have demonstrated that our suppliers present a very low risk of modern slavery or human trafficking in our supply chain.
- Our Terms and Conditions of Purchase which are regularly reviewed and, where necessary, updated.
- Review by our procurement team of our contractual arrangements with suppliers.
- Incorporation of terms requiring compliance with all applicable laws (including the Modern Slavery Act) in our standard contracts.
- Anti-money laundering processes and controls: as a financial institution, James Hay is at risk of handling cash and other assets that could have been financed by modern slavery. James Hay has in place a Financial Crime Framework, an Anti-Bribery Policy, a Money Laundering Reporting Officer and controls for identifying and preventing any form of money laundering (including that which may facilitate financing that supports modern slavery).
- Robust HR policies and practices that align with our obligations under the Modern Slavery Act, which include background checking on all new employees and contractors.
James Hay remains committed to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking is not taking place in our business or supply chain. We continue to develop our approach, educate our employees and assess and manage risks on an on-going basis.
Alastair Conway CEO, James Hay Partnership
as at October 2019