Modern Slavery Statement (2022-2023)

A) ORGANISATION

This statement applies to Sloane Risk Group Limited (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2022-2023.

B) ORGANISATIONAL STRUCTURE

Sloane Risk Group is a SME with a hierarchical structure, projects consist of full-time contracts and bespoke consultancy programs for corporate and private clients. Employees and where relevant Contractors typically work in the field or from home. The senior management team consists of the Managing Director and the Technical Director who both own 50% of the organisation’s shares.

With its headquarters in London, Sloane Risk Group is a well-known and trusted brand and leader in security and compliance services. Sloane Risk Group Ltd conducts global counter-espionage, protective security and compliance services for corporate and private clients.

Our purpose is to make the world a safer and more secure place in which to work and live.

We do this by:

Delivering industry-leading security solutions to our customers
Providing subject matter expertise to our clients
Delivering industry-leading safe room, security system design and installation
Delivering industry-leading compliance services to make buildings and structures safer to live and work in.
Providing rewarding work for our employees.
Making a positive social and economic contribution in our communities.
Building a company that creates significant and sustainable value for our key stakeholders.

C) DEFINITIONS

Sloane Risk Group Limited considers that modern slavery encompasses:

Human trafficking
Forced work, through mental or physical threat
Being owned or controlled by an employer through mental or physical abuse or the threat of abuse
Being dehumanised, treated as a commodity or being bought or sold as property
Being physically constrained or to have restrictions placed on freedom of movement

D) COMMITMENT

Sloane Risk Group Limited acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Sloane Risk Group Limited understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

Sloane Risk Group Limited does not enter into business with any other organisation, in the United Kingdom or abroad, that knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to Sloane Risk Group Limited in the pursuance of its own services is obtained through slavery or human trafficking. Sloane Risk Group Limited strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in EMEA, APAC and NA regions.

E) SUPPLY CHAINS

In order to fulfil its activities, Sloane Risk Group Ltd’s main supply chains include those related to the provision of fuel, transport, SaaS, PaaS and Sub Contractors who we understand will maintain their own relationships with lower-tier suppliers.

F) POTENTIAL EXPOSURE

Sloane Risk Group Limited considers its main exposure to the risk of slavery and human trafficking to exist unknowingly through the use of 3rd party suppliers.

In general, Sloane Risk Group Limited considers its exposure to slavery/human trafficking to be extremely unlikely as we onboard all direct contractors and request thorough vetting forms from subcontractor organisations.

G) IMPACT OF COVID-19

Sloane Risk Group Limited concludes that the COVID-19 pandemic did not adjust the risk of modern slavery to a level above that which existed before the pandemic, which is as set out under ‘POTENTIAL EXPOSURE’ above.

During the pandemic, staff and employees still had access to the grievance procedure to raise any concerns that they may have had.

In line with emergency legislation passed by the Government, employees have been paid Statutory Sick Pay during periods of self-isolation where it has not been possible to agree a temporary period of homeworking.

The organisation’s modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times.

H) STEPS

Sloane Risk Group Limited carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

Sloane Risk Group Limited has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, Sloane Risk Group Limited has taken the following steps to ensure that modern slavery is not taking place:

A thorough review of supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery

Implementation of due diligence measures to identify and assess the potential risks in our supply chain
undertaking impact assessments of our services upon potential instances of slavery

I) KEY PERFORMANCE INDICATORS

Sloane Risk Group Limited has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in Sloane Risk Group Limited or its supply chains.

Confidential monthly review of staff whistle-blowing communications
Confidential monthly review of supply chain whistle-blowing communications
Annual review of supplier contracts
Annual review of contractor on-boarding procedures

J) POLICIES

Sloane Risk Group Limited has the following policies which further define its stance on modern slavery

Corporate Social Responsibility Policy
Ethical conduct policy
Whistle Blowing Policy
Supplier Code of Conduct

K) TRAINING

Sloane Risk Group Limited provides the following training to staff to effectively implement its stance on modern slavery On-boarding company e-learning package which defines modern slavery and states how to report suspicion of modern slavery within our workforce or supplier work force.

L) SLAVERY COMPLIANCE OFFICER

Sloane Risk Group Limited has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to Sloane Risk Group Limited obligations in this regard.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Date of approval 01/04/22

Signed: Mrs Hayley Elvins
Managing Director
Date 01/04/22

Document Number: SRGP0722023
Version 1