Modern slavery and human trafficking statement
We are committed to working to ensure that there is no modern slavery or human trafficking in our supply chain or in any part of our business. This commitment is an integral part of our policies and our approach to human rights, which is informed by the UN Guiding Principles on Business and Human Rights.
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps and measures we have taken to seek to ensure that modern slavery and human trafficking does not occur in any part of our business operations or within our supply chain.
First Rate Exchange Services is organised into two business units: First Rate and Bank of Ireland First Currency Services for the provision of wholesale and retail Foreign Exchange Services.
Cash is the most favoured payment type used by criminals; however prepaid card products also carry a risk. For example travel money cards maybe used to pay for illicit on-line transactions or be used by criminal operators to pay victims who are forced into providing illicit services.
We operate a number of policies which reflect our commitment to acting ethically with regard to our employees, customers and all our business relationships, and they together address our approach to the identification and prevention of modern slavery and human trafficking:
- Modern Slavery Policy Statement is the standard we operate to in order to ensure that modern slavery and human trafficking does not occur in any part of our business or within our supply chain. As noted below, the policy statement is used for training purposes and is communicated to all senior managers and relevant staff within our business.
- Code of Conduct and Ethics Policy lays out the expectations and guiding principles for appropriate workplace behaviour.
- Speak-Up Policy details the procedures our employees should follow if they have any legitimate concerns about wrongdoing, unlawful conduct, acts of bribery, financial malpractice, dangers to the public or the environment, or possible fraud or other risks.
- Human Resourcing Policy outlines our approach to recruiting employees for all jurisdictions in which we operate. The principles of equality and diversity underpin all aspects of our resourcing activity, with recruitment and selection processes that are designed to ensure fairness, diversity and transparency.
- Anti-Bribery and Corruption Policy applies to all directors, officers and employees of the business, as well as third parties such as suppliers and sets out the rules we adopt with a view to preventing bribery and corruption in our business and supply chain.
- Anti Money Laundering Policy applies to all our employees and consolidates our policies and procedures to prevent the commission of financial crime and the movement of money which has derived from crime.
Training and awareness
We are committed to raising awareness of the policies listed above with all First Rate employees. Our Compliance Training Programme includes;
- Annual roll out of compulsory reading of key policies (listed above) which includes obtaining an attestation to confirm staff acknowledgement and adherence to each of these policies.
- Annual roll out of Compliance Computer Based Training for key regulatory matters including Anti Bribery and Corruption and Anti Money Laundering.
Our senior managers also receive further support that includes training and line management guidance to ensure consistency of approach in terms of our recruitment processes, management of suppliers, fair treatment at work, and inclusion and diversity.
Our supply chain
We are principally an office-based business based in the UK only and offering foreign currency and exchange services to customers in the UK and wholesale notes globally. Our supply chain consists predominantly of goods and services purchased in order to assist in the delivery of such services (such as payment and settlement services, financial institutions, CIT Companies, technology and outsourced process providers, professional services and software providers).
We adopt a ‘zero tolerance’ approach to modern slavery and human trafficking and we expect our supply chain to adhere to the same values. Our suppliers tend to be mainly UK-based, which means that it is easier for us to assess whether or not they have in place suitable anti-slavery and human trafficking policies and processes and to verify any assurances given. We also expect our overseas suppliers or foreign outsourced services to meet equivalent standards to the UK.
We have carried out an assessment of our business and supply chain and consider that there is minimal risk of modern slavery or human trafficking. We have formed this view by adopting a risk-based approach in relation to our supply chain and concluding that foreign currency exchange (wholesale and retail) is not typically an industry with a high risk of modern slavery or human trafficking. We have, however, reviewed suppliers that operate within industries or countries that carry a higher degree of risk.
- In conducting appropriate due diligence, we assess our key suppliers across a number of key risk areas, at the on-boarding stage and annually thereafter by the way of an attestation ‘Compliance Supplier Attestation’, to identify where modern slavery and human trafficking risks may arise. Attestations are obtained from suppliers on a risk based approach.
- Detailed financial analysis and assessment of their maturity, reputation and experience is also included. We may also seek to identify if our suppliers operate a vendor management programme and carry out due diligence on their own suppliers to ensure that appropriate standards are being passed through the supply chain.
- We seek assurances (where appropriate) from our suppliers that they are complying with all applicable laws and regulations which includes laws relating to minimum wages, working conditions, overtime, child labour and applicable labour and environmental laws. This allows us to select suppliers to work with us who adhere to the same high standards as we do.
- Our suppliers are required to notify us of a breach of any applicable laws or regulations. We also select a number of suppliers and monitor the content of modern slavery and human trafficking statements published by them.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes First Rate Exchange Services Ltd slavery and human trafficking statement for the financial year ending 31 March 2019. APPROVED BY THE BOARD OF FIRST RATE EXCHANGE SERVICES LIMITED ON 18 SEPTEMBER 2019.
Responsibility for ensuring that First Rate Exchange Services has appropriate policies in place to identify and prevent modern slavery and human trafficking rests with the Board of Directors who have approved this statement. The statement is reviewed annually.
Approved by Board of Directors, First Rate Exchange Services Ltd.
Gary Fitton, Chief Executive
18 September 2019