This statement sets out the actions taken by Mattioli Woods plc to identify and eliminate all potential modern slavery risks related to our business.
It also explains the steps put in place aimed at ensuring there is no modern slavery or human trafficking in our own business and our supply chains. This statement relates to actions and activities during the financial year ended 31 May 2021.
As part of the financial services sector, Mattioli Woods recognises it has a responsibility to take a robust approach to modern slavery and human trafficking. We are therefore absolutely committed to preventing both activities (in all its forms) in all areas of our business, and in our supply chains.
Organisational structure and supply chain
Mattioli Woods is one of the UK’s leading wealth management providers with total assets under management, administration and advice of £15 billion. Our supply chain is one of general business suppliers, as well as specialist services such as investments, pensions, property and employee benefit services. All of which are professional services based in the UK, rather than products or commodities sourced from high risk countries. Further, Mattioli Woods operates in (and all its supply chain is confined to) the United Kingdom.
The following process allows us to assess whether a particular activity is high risk when it comes to modern slavery or human trafficking:
- Mattioli Woods holds a register of all its operations, regularly reviewing this in the context of its supply chain and business operations.
- There are no high-risk activities identified in relation to modern slavery or human trafficking because we only operate in the UK in financial services and do not source products or services from higher risk regions.
Anti-slavery initiatives at Mattioli Woods
Our general operational polices are developed through consideration of our group business activity as well as the markets we operate in within our operations function.
We achieve this through a multi-disciplined approach where the finance, HR, compliance and risk teams collaboratively review the group’s business activity and supply chain. Policies are reviewed and approved annually by the Governance Committee.
Mattioli Woods operates the following specific policies that describe our approach to the identification of modern slavery risks and human trafficking and the steps to be taken to prevent both in our operation.
- Whistleblowing policy
Mattioli Woods encourages all its employees, as well as consultants, contractors and other business partners (collectively referred to as staff for the purposes of this statement) to report any concerns related to the direct activities, or the supply chains, of the group. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for staff to make disclosures (the policy is released to all employees annually) – without fear of retaliation – independently to our non-executive director Martin Reason. Employees, clients, or others who have concerns can follow either our whistleblowing or complaints procedure.
2. Employee code of conduct
Mattioli Woods’ code of conduct makes clear to staff the actions and behaviour expected of them when representing the group. Mattioli Woods strives to maintain the highest standards of employee conduct and ethical behaviour in all its operations and when managing its supply chain.
- Supplier code of conduct
Mattioli Woods is committed to ensuring its suppliers also adhere to the highest standards of ethics. Suppliers are required to demonstrate they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure they meet our standards of the code and improve their workers’ working conditions if needed. Any serious violations of the supplier code of conduct will lead to the termination of the business relationship.
- Recruitment/agency workers policy
Due to the nature of our regulated business, Mattioli Woods does not use agency or temporary workers. However, if there was ever a need for us to do so, we would only use reputable employment agencies by validating their recruitment practices before commencing with any hiring. With all our recruitment, we fully verify new employees through an independent third-party company that specialises in identifying any fraudulent data or information, which informs us of anything suspicious.
Mattioli Woods is committed to respecting fundamental human rights in all its activities. The recruitment process for direct employees is designed to ensure that no employees are at risk of modern slavery or human trafficking.
- Due diligence of suppliers
Mattioli Woods undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers too. We regularly review and conduct assessments through our own employees or third-party auditor, focusing on slavery and human trafficking. We take steps to improve sub-standard suppliers’ practices, including providing advice to suppliers (sometimes through a third-party auditor), and requiring them to implement action plans.
Any known, or suspected, instances of modern slavery or human trafficking are investigated through our risk management and compliance functions.
The role of staff and HR
To better understand and respond to potential modern slavery and human trafficking risks, our employees are given awareness training while our suppliers are also made aware of our expectations.
We also review our salaries on an annual basis to ensure our employees are not paid below the national minimum wage, we are an established partner with Living Wage Foundation, and pride ourselves to ensure that all employees are paid above the national minimum wage. We provide a benefits package to all employees – including pension auto enrolment – regardless of the employee’s role within our business. We want to guarantee we are fair and consistent throughout our business. In September 2021, all employees’ benefits were reviewed with some of the benefits being enhanced.
Following the introduction of the Modern Slavery Act (2015), the group continuously reviews its key performance indicators. As a result, we:
- require all staff to have complete ongoing training on modern slavery and is repeated annually
- have assessment documents to verifying potential suppliers before we use them in our business
- regularly review our existing suppliers to ensure they meet our standards ie auditing of supplier salaries to ensure they are in line with national minimum wage.
Mattioli Woods requires all employees to complete online training on modern slavery and human trafficking annually. It covers;
- the basic principles of the Modern Slavery Act (2015)
- how staff can identify and prevent modern slavery and human trafficking
- what staff can do to flag up potential modern slavery or human trafficking issues to the relevant parties within the group
- the external help available, for example through the Modern Slavery Helpline, the Gangmasters and Labour Abuse Authority and the ‘Stronger Together’ initiative
Assessments of existing and new suppliers
We review and assess the risk of slavery and human trafficking in relation to various aspects of the business by identifying:
- the signs of modern slavery and human trafficking
- the initial steps to be taken if modern slavery or human trafficking is suspected
- how to escalate potential modern slavery or human trafficking issues to the relevant parties within the group
- the external help available (as above)
Our Anti-Slavery and Human Trafficking Policy reflects the group’s commitment to acting ethically and with integrity in all business relationships, implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our organisation, or supply chains.
This statement has been approved by the group’s board of directors and non-executive directors, who will review and update it annually.
Ian Mattioli MBE
Chief Executive Officer