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THEO TOPCO LIMITED MODERN SLAVERY STATEMENT FOR THE FINANCIAL YEAR ENDED 31ST DECEMBER 2019

1. Introduction
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Theo Topco Limited and its subsidiaries (“Key Group”) slavery and human trafficking statement for the financial year ending 31 December 2019.

Whilst we consider the risk of the existence of slavery and human trafficking within our business or supply chains to be very low we are committed to combatting modern slavery in all its forms. We take a zero tolerance approach to modern slavery.

2. Our Business
Key Group is a leading financial services group providing products and services for those in or approaching retirement including equity release, annuities and estate planning.

Key Group is made up of a number of trading divisions including:

Key – whose primary business is the provision of equity release advice but who also has business lines in the arrangement of non-advised annuities and estate planning.

The Equity Release Experts – who provide whole of market equity release advice.

more 2 life – a lifetime mortgage lender accepting business via intermediaries only, whose products are funded by third party funders.

AIR Group – offer a range of services which include a sourcing system for equity release and retirement lending products to help equity release advisers support their customers and their business.

As a Group we aim to employ the highest ethical and professional standards and always to comply with all local laws and regulations applicable to our business; it follows that Key Group is absolutely committed to preventing slavery and human trafficking in its corporate activities and supply chains.
A risk assessment for the potential of slavery and human trafficking within our business and supply chains is evaluated by the nature of our business and our approach to governance, we therefore consider the risk is very low. However we aim to periodically review the effectiveness of the relevant policies and procedures that we have in place.

3. Our Supply Chains 
We source goods and services from a variety of suppliers including:
• IT – software and hardware
• Telephony 
• Office accommodation and supplies
• Professional services such as marketing, legal etc.
• External funding partners
As part of our initiative to identify and mitigate risk we conduct due diligence on potential suppliers, impose obligations on those suppliers in relation to (among other things) compliance with law, and take reasonable steps to monitor their compliance with those obligations. Our Facilities team only select contractors/companies affiliated with/accredited by trading bodies such as the Contractors Health and Safety Scheme (CHAS), and such suppliers must complete a Supplier Audit Evidence document in which we request amongst other policies, a copy Modern Slavery statement where available.

We conduct all business with integrity and are committed to acting professionally and fairly in all our business dealings and relationships. 

Our procurement activities take place in the UK and our contractors and suppliers are predominantly UK based, although a minority are based in the EU and one of our funding partners is based in the U.S. Some of our suppliers subcontract work or rely on recruitment agencies to supply permanent or temporary staff. Whilst we consider that the risk is very low, we recognise that no supply chain can be considered entirely risk free.

4. Our Policies
Our Corporate Social Responsibility Policy reflects Key Group’s commitment to acting ethically and with integrity in all our business relationships. Key Group’s Company Handbook contains a Grievance Procedure, Personal Harassment Policy and a Whistleblowing Policy aimed at giving our colleagues a platform to raise concerns of any wrongdoing or poor working practices. This extends to human rights violations, including modern slavery. All such reports will be fully investigated and appropriate remedial action taken.

5. Our Progress
We believe that there is a low risk of slavery and human trafficking within our operations. Any potential risk is mitigated as a result of our policies and procedures, the controls built into our business operations and the knowledge, skills and behaviours of our colleagues. These are clear performance indicators by which we can measure our effectiveness. In addition, we have processes in place to encourage the reporting of concerns and protect whistle-blowers.

In 2019 we:

• Continued to raise a general awareness of the topic amongst our colleagues via the Key Group Annual Training, encouraging colleagues to report concerns and providing assurance that such concerns will be acted upon.
• Continued to engage with our key suppliers to verify that they have taken appropriate steps to ensure there is no slavery or human trafficking in their business or supply chains.
• Did not receive any reports of incidents or allegations of slavery or human trafficking within our business or supply chains.
In 2020 we will continue to reinforce this message throughout Key Group. In addition we will:

• Review and update our Corporate Social Responsibility policy to enhance documentation on our approach to suppliers and ethics.
• Draft and Implement a Recruitment policy which outlines how the risk of modern slavery is mitigated during the recruitment process.
• Review our Supplier Audit Evidence document to gain clear confirmation from small companies without a Modern Slavery statement of their commitment to these standards.
• Continue to engage with our key suppliers to verify that they take appropriate steps to ensure that there is no slavery or human trafficking in their business or supply chains.
• Act promptly where a compliance breach has been identified, feedback lessons learnt and work to minimise the risk of this occurring again.
We will continue to build on this progress over future years.
This statement is approved by the Key Group Audit, Risk & Compliance Committee and will be reviewed at least annually.

Simon Thompson
Key Group CEO

 

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