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.
 
Retirement Bridge Group Ltd and the Retirement Bridge group of companies therein undertake various activities linked to the provision and management of home reversion plans (the ‘plan’). In this Slavery & Human Trafficking Statement (the ‘Statement’) we set out how we meet our obligations to prevent modern slavery and human trafficking in our business and supply chains. 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. 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.
 
Our Business
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 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 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 principally based and operating in the UK to support the business. One supplier, specifically the parent entity of our database provider is based in the United States and operates globally. We have an appropriate contract for service in place and have not identified any evidence to believe that slavery or human trafficking exists here.
 
Our Policy Approach
We have a policy framework in place which covers matters including but not limited to the prevention of financial crime, outsourcing, the recruitment of staff and risk management. These are made available to relevant staff who are required to confirm they have read and understood the policy.
 
Supply Chain Risk
Our Outsourcing policy sets out the approach we will take to the selection of key suppliers. We will ensure contracts and agreements will be entered in to which 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 Compliance & Risk function maintain a 3rd Party Contracts & Outsourcing Matrix designed to support the engagement of suppliers to our business including reasons for their selection and due diligence activity undertaken. 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.
 
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 evidenced 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 2018. It has been reviewed and approved by our board 18th October 2018.
 
Paul Barber
Chief Executive, Retirement Bridge Group
Date: 19/10/2018