Our Slavery & Human Trafficking Statement


Introduction
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. As an ethical organisation we have no appetite to accept non-compliance with our legal and regulatory obligations. We have no wish to trade with, support or work with any business which is involved in slavery or human trafficking in any way, however remotely or indirectly.
 
Our Business
The Retirement Bridge Group is made up of a number of firms operating from Newcastle Upon Tyne and is both the largest home reversion plan provider and the largest home reversion plan administrator in the UK. A full list of those companies that this statement applies to can be found on our website www.retbridge.co.uk under the ‘About Us’ tab. By references to “Retirement Bridge”, “we”, “us” and “our” we mean Retirement Bridge Group Ltd and the firms that form the Retirement Bridge group of companies.
 
We have a zero-tolerance approach to modern slavery of any kind within our operations and are committed to taking all reasonable steps to ensure that there is no modern slavery or human trafficking in our business or supply chains.
 
We do not consider ourselves operating in an environment with a high risk of modern day slavery. That is because the risks should be viewed in the context in which we operate:
 
  • We operate only in the United Kingdom (UK) and the types of home reversion plan we provide and manage apply to properties located only in the UK;
  • The plan is only available through UK financial advisers who must be authorised and regulated by the UK financial services watchdog, the Financial Conduct Authority (FCA) and involves an older age group whose main residence must be in the UK;
  • Customer identification is undertaken & declared by these financial advisers and by the transacting lawyers as per the Joint Money Laundering Steering Group (JMLSG) Guidance;
  • Customers are represented by an independent solicitor when first taking out the plan;
  • We use a relatively small number of suppliers to support our business almost all of whom are based in and operate in the UK. Two suppliers, specifically the parent entity of our database provider and our cyber insurance provider are based in the United States. Both operate globally. We have appropriate contracts for service in place and have not identified any evidence to believe that slavery or human trafficking exists here.  
    We have policies in place which cover matters including but not limited to the prevention of financial crime and which refer to Slavery & Human Trafficking. These are made available to relevant staff who are required to confirm they have read and understood the policy.
     
    Supply Chain Risk
    We source goods and services from a relatively small number of suppliers covering:
     
  • I.T. including telephony & equipment;
  • Office accomodation & supplies;
  • Legal services;
  • Property services.
Our Outsourcing & Contracts policy sets out the approach we will take to the selection of key suppliers. We will have regard for suppliers:
  • Reputation and history;
  • Knowledge and experience;
  • Quality of services provided to us where for example we are renewing existing or entering new or additional arrangements;
  • Quality of services provided to other customers we are aware of;
  • Legal and regulatory standards, such as any history of prosecution, enforcement action or similar;
  • Financial stability and commercial record.
 
Any contracts we enter in to will make clear all parties must comply with applicable laws and regulations. Key contracts will be reviewed by our Compliance & Risk function, and, if necessary, by external professionals. Our Operations function monitors on-going performance of our key suppliers.
 
People Risk
In terms of recruitment, we verify the identification and address history of all new candidates for employment. As part of this, we undertake background screening and a ‘standard’ Disclosure Barring Service (DBS) check. This screening activity can be repeated at intervals. We do not place particular reliance on the use of temporary agency staff. Where such staff are engaged, confirmation from the agency they have undertaken appropriate background checks on the candidate is sought.
 
Ongoing Plan Administration
Once a plan is entered in to, we carry out periodic ‘Certificate of Occupancy’ checks in which customers are required to confirm their continuing residence and declare any additional occupiers.  Property Inspections are also undertaken at either 2 or 3 yearly intervals (depending on the specific type of plan they hold) which make use of photographic evidence of the property internally and externally. These mechanisms help us verify that customers are abiding by the plan terms and conditions including that properties are being used appropriately and lawfully.
 
Awareness
We provide our staff with training relevant to them. We have processes in place to encourage staff to report concerns including via our Whistle blowing policy. The business reviews its risks at least annually. The result of our most recent assessment did not identify any concerns here.
 
Responsibilities
Our board of directors has overall responsibility for the approval of key policies relating to financial crime prevention and this Slavery & Human Trafficking Statement.
 
Conclusions
Taking all the above in to account we consider the business operates in a very low risk environment and continues to meet the requirements of the Modern Slavery Act 2015. Furthermore, through our processes and procedures, we have not identified any reason to believe that slavery or human trafficking affects any part of our business either directly or via those suppliers we are engaged with.
 
This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015 and constitutes our Slavery & Human Trafficking Statement for the financial year ending 30th September 2019. It has been reviewed and approved by our board 17th October 2019.
 
Paul Barber
Chief Executive
Date: 17/10/2019