Modern Slavery Statement

1. Voluntary publication of this statement

Section 54 of the Modern Slavery Act 2015 requires certain commercial organisations carrying on business in the United Kingdom, supplying goods or services and having annual group turnover of £36 million or more to publish an annual slavery and human trafficking statement.

Astute Finance is not currently required to publish a statement under section 54.

Nevertheless, we have chosen to publish this statement voluntarily because we believe transparency, responsible business practices and respect for human rights should form part of the standards expected of any organisation, regardless of whether a statutory reporting threshold applies.

As our business develops, we will keep our obligations under the Modern Slavery Act and other applicable legislation under review.

2. About Astute Finance

Astute Finance provides specialist business process outsourcing and intermediary services, principally to organisations operating within the financial services sector.

Our services may include:

• lead generation;
• customer acquisition support;
• lead verification and qualification;
• customer communications;
• administration;
• data processing;
• back-office operations;
• customer support;
• compliance and data-protection processes;
• referral and intermediary services; and
• other outsourced business support.

Our business depends upon people, technology providers, contractors, suppliers and business partners working together to deliver services effectively and responsibly.

3. Our approach to modern slavery

We do not knowingly tolerate any form of:

• forced or compulsory labour;
• human trafficking;
• servitude;
• child labour;
• debt bondage;
• coercion or threats relating to work;
• withholding of passports or identity documents;
• unlawful restriction of workers' freedom;
• exploitative recruitment practices; or
• other forms of labour exploitation.

We expect individuals working for Astute and organisations providing services to us to be treated fairly, lawfully and with dignity.

4. Our people

People are central to Astute Finance's business. We seek to ensure that employment, contracting and subcontracting arrangements are entered into voluntarily and on clear terms.

Individuals working for or on behalf of Astute should understand:

• the nature of their role or engagement;
• the work they are expected to perform;
• the basis upon which they are paid;
• the principal terms governing the relationship; and
• their ability to end the relationship in accordance with the applicable agreement and law.

We do not knowingly permit:

• workers to be charged improper recruitment fees as a condition of obtaining work;
• identity documents to be unlawfully retained;
• workers to be threatened or coerced into remaining in an engagement;
• misleading representations concerning pay or working arrangements; or
• practices intended to prevent an individual from freely leaving an engagement.

5. Our supply chain

As a service-based business, Astute Finance does not operate the type of physical supply chain associated with manufacturing or product distribution.

Our principal supplier and business relationships may nevertheless include:

• independent contractors and subcontractors;
• recruitment providers;
• outsourced service providers;
• technology and software providers;
• telecommunications providers;
• cloud and data-hosting providers;
• professional advisers;
• training providers;
• compliance suppliers;
• office and facilities providers;
• lead-generation businesses;
• introducers and referral partners; and
• other organisations supporting our services.

We recognise that modern-slavery risks can occur within service industries as well as physical supply chains. These risks can be greater where services involve labour-intensive activity, subcontracting, recruitment intermediaries or work performed across different countries and jurisdictions.

6. Risk assessment

We take a proportionate, risk-based approach to assessing our business relationships. Areas that may present an increased modern-slavery risk can include:

7. Due diligence

Astute Finance undertakes proportionate due diligence when establishing and managing appropriate supplier and business relationships. Depending on the nature and risk of the relationship, this may include:

• verifying the identity of the organisation;
• understanding the services being provided;
• considering the jurisdiction from which services will be delivered;
• identifying whether subcontractors or other intermediaries will be used;
• reviewing relevant policies and contractual arrangements;
• asking further questions where concerns arise;
• imposing appropriate contractual standards;
• monitoring issues identified during an ongoing relationship; and
• reviewing the relationship if material concerns arise.

We may request further information or evidence where appropriate.

8. Lead generators, introducers and referral partners

Astute Finance may work with lead-generation organisations, introducers and other referral partners as part of the services we provide.

Our due diligence relating to these organisations can cover several areas, including data protection, compliance and the circumstances in which their services are delivered. From a modern-slavery perspective, we may consider matters such as:

• the location from which services are provided;
• the use of employees, contractors or subcontractors;
• whether additional outsourced providers are involved;
• relevant workforce practices;
• the transparency of the organisation's operations; and
• any information giving rise to concerns about exploitation.

Data-protection and lead-provenance due diligence is a separate compliance process, but both form part of our wider approach to responsible business relationships.

9. Our expectations of suppliers and partners

We expect organisations working with Astute Finance to:

• comply with applicable labour and employment law;
• prohibit forced and compulsory labour;
• prohibit human trafficking;
• prohibit unlawful child labour;
• treat workers fairly and with dignity;
• avoid exploitative recruitment practices;
• provide appropriate working conditions;
• investigate credible concerns about worker exploitation;
• maintain appropriate oversight of their own subcontractors; and
• cooperate with reasonable enquiries relating to modern-slavery risks.

Serious concerns or repeated failure to meet appropriate standards may affect our willingness to establish or continue a commercial relationship.

10. Recruitment and engagement practices

Where Astute Finance recruits or engages individuals directly, we aim to operate transparent recruitment and onboarding processes. We do not knowingly permit practices involving:

• payment of improper recruitment charges by workers;
• confiscation of passports or identity documents;
• threats or coercion;
• debt bondage;
• deliberate misrepresentation of working arrangements; or
• unlawful restrictions preventing an individual from ending their employment or engagement.

Where recruitment or labour is provided through another organisation, we expect that organisation to operate to equivalent standards.

11. Training and awareness

We recognise that awareness is important in identifying potential indicators of exploitation. Individuals with relevant responsibilities, including those involved in recruitment, management, procurement, supplier onboarding, compliance, and oversight of outsourced services, are expected to remain alert to potential concerns and escalate them appropriately.

We will keep the need for additional formal training under review as our business and supplier network develop.

12. Raising concerns

Employees, contractors, suppliers, business partners and other individuals are encouraged to report concerns about suspected modern slavery or exploitation connected with Astute Finance or one of our business relationships.

Warning signs may include circumstances where a person:

• appears unable to leave their employment freely;
• is subject to threats, violence or coercion;
• has had identification documents withheld;
• appears controlled by another individual;
• has incurred excessive recruitment-related debt;
• is required to work in abusive or unsafe circumstances;
• appears to have been trafficked; or
• may otherwise be working involuntarily.

Concerns will be treated seriously and sensitively.

13. Responding to concerns

Where a credible concern is identified, Astute Finance will consider the circumstances and determine an appropriate response. This may include:

• obtaining additional information;
• conducting further due diligence;
• raising the matter with the relevant supplier or business partner;
• requiring remedial action;
• suspending activity;
• terminating a commercial relationship;
• escalating the matter to senior management;
• reporting matters to relevant authorities where appropriate; or
• cooperating with an external investigation.

Our response will take account of the welfare of any potentially affected individuals. We recognise that immediately terminating a supplier is not necessarily the safest response in every situation if doing so could increase the risk to affected workers.

14. Monitoring and continuous improvement

Astute Finance will keep its approach to modern slavery under review. We may consider matters such as: concerns raised, due-diligence findings, supplier or partner issues, corrective actions requested, business relationships suspended or terminated following serious concerns, changes to supplier-onboarding processes, staff awareness, and opportunities to strengthen our controls.

We regard the prevention of modern slavery as an ongoing process rather than a one-off exercise.

15. Responsibility

Senior management has overall responsibility for promoting appropriate ethical standards within Astute Finance. Individuals responsible for recruitment, supplier relationships, compliance and operational delivery are expected to identify and escalate relevant concerns.

Modern-slavery prevention forms part of our wider approach to: ethical business conduct, responsible outsourcing, supplier due diligence, effective governance, and long-term responsible business relationships.

16. Our continuing commitment

Although Astute Finance is not currently required to publish a modern slavery statement under section 54 of the Modern Slavery Act 2015, we have chosen to make our position publicly available as part of our commitment to responsible and transparent business practices.

We will keep this statement and our procedures under review as Astute grows and as the nature and complexity of our supplier and business relationships develop.