Slavery and human trafficking

Annual Statement on slavery and human trafficking – September 2020

Smith & Williamson are independent providers of investment management, accountancy, tax, corporate and financial advisory services to a range of clients, including private clients, corporates, professional practices and non-profit organisations. The Smith & Williamson group have offices in the UK, Ireland and Jersey only.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 which requires organisations to publish a statement each financial year to set out the steps, if any, it has taken to protect against slavery and human trafficking. The statement is published in relation the Smith & Williamson group as a whole, but in particular is made on behalf of the following UK entities:

  • Smith & Williamson Holdings Limited;
  • Smith & Williamson LLP;
  • Smith & Williamson Investment Management LLP; and
  • Smith & Williamson Corporate Services Limited.

We are committed to ensuring our business and supply chain are free from any slavery or human trafficking. As we operate in the financial services sector, many of the service providers we encounter are UK-based entities. They are often themselves regulated by governing bodies such as the ICAEW, FCA or PRA and therefore for these suppliers, in relation to modern slavery, we are able to rely on their own due diligence processes. The other main types of service provider relate to essential office services, such as security, catering, cleaning.

Our office services are outsourced to organisations with their own due diligence procedures for employees and contractors. Our tender process for these contracts includes confirmation of the steps the potential suppliers take to ensure their businesses are free from modern slavery and human trafficking. The due diligence process includes verifying that they have sufficient policies and procedures in place to ensure fair treatment and pay of workers, adequate whistleblowing procedures and confirming that all those employed in the provision of services have the necessary documentation to legally work in the UK.

Contractors working in our premises also have the right to protection under Smith & Williamson’s whistleblowing policies. We are introducing training to staff on the Modern Slavery Act and how to recognise instances of potential slavery or human trafficking.

We have introduced amendments to our material supplier contracts to ensure the terms in the agreements are satisfactory to provide us with confidence that our suppliers have sufficient procedures in place to protect against slavery or human trafficking occurring within their business and supply chain, and for them to make reasonable endeavours accordingly to ensure compliance with the Act by their suppliers. We consider this a proportionate and risk-based approach to evaluate and protect our supply chain.

We have reviewed this statement and our supply chain in light of the coronavirus outbreak and the revised government guidelines. Our employees are still able to access our grievance and whistleblowing processes through remote working. Our business has remained robust and payments to our suppliers have continued as normal. We have implemented government advice to ensure the health and safety of all workers through the pandemic, including protection for front of house workers, cleaners and first aiders.

This statement has been approved on behalf of the listed entities above and the Group by the Corporate Responsibility and Charities Committee.

Will Samuel

26 October 2020

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