According to the International Labour Organisation (‘ILO’), more than 40 million people worldwide are victims of modern slavery. Anti-Slavery International estimates that one in four of them are children and almost three quarters are women and girls.
Modern slavery encompasses the recruitment, movement, harbouring or receiving of people through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. This includes slavery, servitude, child labour, forced labour, human trafficking, debt bondage, forced marriage, deceptive recruiting for labour or services, and slavery-like practices. An ILO report says that forced labour generates around US$150 billion a year for traffickers.
Benchmark Capital Limited (‘Benchmark’) has a corporate responsibility to respect human rights, whether in our role as an employer, as a buyer of goods and services or when carrying out our fiduciary duties as a provider of financial services. Our culture of integrity and acting with purpose means that we are committed to doing what we can to prevent any form of modern slavery from taking place in our own business operations and supply chain. Modern slavery is a complex and multi-dimensional issue and requires a considered and thorough approach. We are committed to continually improving our systems and processes so that we achieve our desired standards and goals.
This statement has been prepared to comply with section 54 of the UK Modern Slavery Act 2015. This statement sets out how Benchmark Capital Limited and its in-scope subsidiaries (the ‘Group’ or ‘we’) assess and report on the risks of modern slavery practices within our business operations and value chain, and the measures we have taken to address these risks. Entities in scope of UK modern slavery reporting legislation are Benchmark Capital Limited, Best Practice IFA Group Limited and Fusion Wealth Limited. All data in this Statement is at 31 December 2021, unless stated otherwise.
Benchmark is a holding company for and provides centralised support services to its operating subsidiaries within the Group. It is also the main employing entity of the Group’s UK employees.
The Group's objective is to power financial advisers through insight and integrated tools, services and investment solutions that differentiate their client propositions. The Group is part of the wider Schroders plc Group (‘Schroders’ or the ‘Schroders Group’), a world-class global asset manager that actively and responsibly manages investments for a wide range of institutions and individuals across Europe, the Americas, Asia Pacific, Middle East and Africa.
We are committed to respecting human rights and avoiding human rights infringements including modern slavery. The Group undertakes to act ethically and with integrity in all its business relationships, in line with its corporate values and policies, and to take all reasonable measures to require members of its supply chains to do the same. This includes the prevention of modern slavery and human trafficking.
The Benchmark Board, and boards of in-scope subsidiaries in the Group, review and approve the information disclosed in this statement. The Group Chief Executive signs the statement on behalf of the Group.
Our policies and standards
Benchmark adopt Schroders Group policies and standards where applicable and appropriate to the Group. We have a set of policies and standards guided by international principles and applicable laws and regulation. There are a number of policies, processes and measures in place that help to assess and manage modern slavery risks across our business, such as:
Risk assessment and due diligence
The risk of modern slavery within our direct business operations is deemed to be low because all our employees work in roles that are office-based and/or require specialist qualifications. We consider that modern slavery risks are most likely to be found in our supply chain and we therefore take a risk-based approach to managing these.
Below, we’ve outlined our risk management and due diligence process relating to the three key areas of our business where we have interaction and influence on respecting human rights – our employees, supply chain and clients.
We continuously manage the risk of modern slavery in our workforce by making sure that the people we hire have the right to work in the relevant country and that their basic rights as workers are protected.
All employees go through an employment verification process where we conduct pre-employment checks, including right to work checks, prior to joining. We commit to providing fair wages and benefits and a secure and healthy working environment for our people. We protect health and safety at work, promote wellbeing and a culture that fosters workplace flexibility and recognises and encourages the need for work/life balance.
We comply with all applicable minimum wage laws in all jurisdictions in which we operate (currently all employees are within the UK). We were particularly mindful of the impact of a lower employee presence in offices as a result of Covid-19, for our facilities team. We maintained all salaries, paying everyone in full throughout the pandemic.
In 2020, we published a Flexible Working Charter to offer our employees the opportunity to choose optimal working patterns to suit their client, team and personal needs.
We will not tolerate forced, bonded, involuntary or child labour and we recognise the right of workers to form and join all types of association.
Our supply chain
The Group relies on external service providers for goods and services to supplement and contribute to our own infrastructure. Our suppliers are largely composed of business and professional services organisations in low risk countries.
We take a risk-based approach to the sourcing, onboarding and monitoring of our suppliers. We are committed to doing what we can to address the risk of modern slavery, maintaining appropriate controls to support prevention and assessing our supply chain.
We expect all of our suppliers to operate in a responsible, ethical, open and transparent way, fully compliant with all applicable laws and regulations. We have an established framework that governs our approach to selection, onboarding and management across our supply chain. As part of our onboarding process, due diligence is carried out for suppliers, as appropriate to the type of engagement. We may ask suppliers to confirm their compliance with existing legislation and to provide their Modern Slavery Act Statement if they have one. We may also ask them to confirm what training they have in place for their employees, and to confirm that no instances of modern slavery have been recorded within the organisation or its supply chain, and that neither the organisation nor anyone connected to it has been convicted of or investigated for any offence relating to modern slavery or human trafficking.
The Schroders Supplier Code of Conduct sets out the high standards and behaviours expected from our partners and covers human rights, ethical sourcing, bribery and corruption, living wages, diversity and inclusion, health and safety and the environment. All suppliers that fall into scope of our global policy requirements are requested to commit to the Schroders Supplier Code of Conduct. 100% of our critical suppliers have attested to our Supplier Code of Conduct (or provided an appropriate equivalent). This is also the case for all significant suppliers and for every new vendor we onboard.
We are committed to paying suppliers on time. Throughout the pandemic we committed to paying small and medium-sized companies as swiftly as possible, irrespective of contracted payments terms and maintained payments to those service providers impacted by the reduced employee presence in our offices throughout 2021, with the intent that salaries could be fully maintained.
Benchmark is committed to performing robust due diligence on the clients that we provide financial services to. We only provide financial services to clients who meet our Group principles including our Group Financial Crime Risk Appetite Statement.
We ask a number of questions to ensure our clients are legitimate and validate this information with independent information wherever possible. For example, we have controls in place to ensure that funds we receive are not from the proceeds of crime. We also screen all of our clients on an initial and ongoing basis. All of this evidence is analysed and recorded prior to onboarding and refreshed periodically to ensure that our clients continue to meet our standards.
We regularly review our control framework to ensure that our policies, procedures and systems help guard against existing and emerging threats, when onboarding and monitoring clients, across our business.
Key Performance Indicators
We recognise that it’s difficult to quantify outcomes and impacts of an approach to tackle modern slavery. Over time we will enhance our measurement of assessing the effectiveness of our approach and progress with smarter metrics. Some of these indicators may be more experience based, including qualitative feedback, case studies or corrective actions. Key Performance Indicators (KPIs) that summarise some of our activities and progress for 2021 are:
We have robust procedures in place to make sure that our people can raise any issues or concerns, confident in the knowledge that they will be taken seriously and investigated fully. This is captured in the Group Whistleblowing Policy.
Concerns regarding illegal or unethical behaviours, including modern slavery, can be reported by employees. These concerns are reported using an independent and confidential third party global reporting service, Safecall, who provide an online portal and 24-hour phone line. Concerns can be raised anonymously either online or using a regional freephone number. Our standard reporting practices and escalation mechanisms mean that any such issue would be quickly brought to the attention of senior management.
In 2021, the Group did not identify any instances of modern slavery in any of our business relationships or receive any reported concerns.
We have laid the foundations for our approach to respecting human rights and preventing modern slavery in our business and wider value chain. We are committed to developing a comprehensive yet proportionate approach and to continually improving our processes to combat slavery and human trafficking. In 2022, we will focus on:
This statement has been approved and signed by the Boards of Benchmark Capital Limited, Best Practice IFA Group Limited and Fusion Wealth Limited and will be reviewed and updated annually.