Introduction
This Modern Slavery Policy outlines the commitment of Black Lion Wealth Management ("the Company"), a UK-based financial services provider, to prevent and combat modern slavery within its operations and supply chains. The Company acknowledges its responsibility to respect human rights, promote fair labour practices, and ensure that slavery and human trafficking have no place in its business activities.
Policy Statement
2.1. Compliance with Legal Requirements
The Company is dedicated to complying with all applicable laws and regulations related to modern slavery, including the Modern Slavery Act 2015 (the "Act") and associated guidance. The policy aims to go beyond mere legal compliance by actively engaging in efforts to eradicate modern slavery.
2.2. Prohibition of Modern Slavery
The Company prohibits any form of modern slavery, including forced labour, human trafficking, debt bondage, servitude, or any other violation of basic human rights.
2.3. Supply Chain Responsibility
The Company recognizes that the risk of modern slavery can extend beyond its own operations. It is committed to working closely with suppliers, contractors, business partners, and other stakeholders to ensure that they adhere to the same high standards in relation to modern slavery prevention.
Governance and Accountability
3.1. Responsibility
The Company's Board of Directors is ultimately responsible for ensuring the effectiveness of this policy, its implementation, and ongoing compliance. The responsibility for day-to-day management and monitoring of the policy rests with the designated [Job Title], who will report directly to the Board.
3.2. Risk Assessment
The Company will conduct regular risk assessments to identify and evaluate potential modern slavery risks within its operations and supply chains. The assessments will consider geographical, industry-specific, and other relevant factors.
3.3. Due Diligence
The Company will undertake due diligence to identify and mitigate modern slavery risks. This will include assessing suppliers, contractors, and other business partners to ensure they comply with the Company's policy, as well as engaging in appropriate risk-based auditing and monitoring activities.
Training and Awareness
4.1. Employee Training
The Company will provide training to employees, contractors, and other relevant individuals to raise awareness about modern slavery, its forms, and indicators, and to ensure they understand their responsibilities under this policy.
4.2. Reporting Mechanisms
The Company will establish clear and confidential reporting mechanisms to enable employees, suppliers, contractors, and other stakeholders to raise concerns or suspicions regarding potential modern slavery issues. The Company will investigate and respond to such reports promptly and appropriately.
Continuous Improvement
The Company is committed to continually reviewing and improving its practices to combat modern slavery. This includes staying up to date with relevant legislation and best practices, monitoring the effectiveness of this policy, and periodically reporting progress to relevant stakeholders.
Communication and Transparency
The Company will communicate its commitment to eradicating modern slavery both internally and externally. This policy will be readily available to all employees, stakeholders, and the public via the Company's website or upon request.
Compliance and Consequences
Non-compliance with this policy may result in disciplinary action, up to and including termination of contracts or employment, as well as potential legal consequences in accordance with applicable laws and regulations.
Review and Approval
This policy will be reviewed annually or whenever significant changes occur in the legal or operational landscape related to modern slavery. Any updates or amendments will be approved by the Board of Directors.
Signed:
Kay Mechial
Director
Black Lion Wealth Management Ltd
Date: 16th June 2023
