Modern Slavery Statement

THE TOPCO LIMITED MODERN SLAVERY STATEMENT FOR THE FINANCIAL YEAR ENDED 31ST DECEMBER 2018

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 2018.

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.

more2life– 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 later life advisers support their customers and their business.

Primetime Retirement (closed to new business) – a provider of fixed term drawdown plans - a SIPP (self-invested personal pension) packager providing customers with access to multiple deposit takers.

As a Group we aim to employ the highest ethical and professional standards and always 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.

Due to the nature of our business and our approach to governance, we assess that there is a very low risk of slavery and human trafficking in our business and supply chains. 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.

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 wider 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 staff 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 staff. In addition, we have processes in place to encourage the reporting of concerns and protect whistle-blowers.

In 2018 we:

Continued to raise a general awareness of the topic amongst our staff via the Key Group Annual Training, encouraging staff 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 2019 we will continue to reinforce this message throughout the Key Group. In addition we will:

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