Modern slavery policy

(v1.1, February 2023)

Statement of commitment

At Saltus, we are fully committed to ensuring that all of our business activities comply with the relevant legislation, and that stringent policies and practices are in place to prevent any workers from being abused or exploited. We will ensure that we work to prevent slavery and human trafficking in all of our business activities, and with our partners and other associated third parties.

Organisation structure

Saltus is an independently owned financial planning and discretionary investment management house. We are dedicated to providing a high-quality service for private clients, trusts, and smaller institutions.

The employers and primary trading vehicles of the Saltus group are Saltus Partners LLP and Saltus Financial Planning Limited which are authorised and regulated by the Financial Conduct Authority and incorporated in England & Wales.  The group grows through acquisition and therefore has other legal entities within the group structure which over time are aligned into the primary trading vehicles.  The Group has approximately 200 staff, all of whom are based in the UK.  The Group’s clients are primary based in the UK and most of the Group’s operations are conducted from the UK.  The group has a Guernsey based subsidiary, Saltus (Channel Islands) Limited, and has Guernsey incorporated holding entities.

Policies in relation to slavery and human trafficking

Saltus has a number of policies in place designed to facilitate the commitments made within this policy. These ensure that we have appropriate measures in place to comply with the relevant legislation and to prevent slavery and human trafficking. These include, but are not limited to, our policies regarding anti-bribery, Corporate Social Responsibility, equality and diversity, ethics, fraud, bullying and harassment, and whistleblowing.

Due diligence processes

We only utilise reputable and compliant sources to recruit, and carry out pre-employment checks on all of our people to ensure they have the right to work and are thereby protected by the relevant employment legislation. We acknowledge our obligations under the Equality Act 2010 and work with all of our staff to ensure that they understand the Act and abide by its terms.

We do not employ or contract any workers who would be considered to be ‘child workers’. Young workers may be permitted to undertake work experience with us, but would be afforded the same rights and treatment that we extend to all staff, partners and contractors.

While we cannot directly control working conditions within our suppliers and partners, we will ensure that all prospective partners or suppliers are subject to stringent checks via a standard procedure. We will not hesitate to terminate our relationship with any suppliers or partners who are found to have treated workers in a manner inconsistent with any of our own internal policies and standards.

Risk assessment and management

Our Risk Committee meets regularly to assess risks across the business. Any potential for any exposure to modern slavery is raised via the Risk Committee and is assessed before an appropriate recommendation for action to mitigate the risk is taken. Where a supplier or third party provider is assessed by the Risk Committee to be high risk in respect of the risk of exposure to modern slavery, an alternative supplier will be sought.

Key performance indicators

Key performance data is obtainable from our Risk Register in regards to the effectiveness of the steps being taken within the organisation to prevent modern slavery and human trafficking.

Training on modern slavery and trafficking

All Saltus staff are made aware of our Modern Slavery Policy as they join the organisation. As part of their onboarding training, we ensure they understand the importance of this policy, the reasons for it to be in place, and the actions they should take if they have reason to suspect that there is any evidence of exposure to modern slavery in any business activities connected to Saltus. We encourage an open and transparent two way feedback culture with our people, to ensure that staff are able to speak up without fear of recrimination.

Review process

This policy is reviewed annually before being presented to the Executive Committee of Saltus for formal partner sign off.

Policy approval

This policy was approved by the Executive Committee of Saltus on 15 February 2023.

Jon Macintosh, Managing Partner