Modern Slavery Act Statement

Bradburys Global Risk Group is committed to operating to the highest possible legal and ethical standards. As part of this commitment, and as a responsible business, we have a moral duty to operate beyond compliance.

We continue to review and strengthen our approach to human rights issues, including modern slavery, to ensure that our stakeholders are working together to eradicate modern slavery and human trafficking and we focus on working with long-term strategic partners that demonstrate the same standards in compliance with all applicable anti-slavery and human trafficking laws to ensure that human rights abuse plays no part in our business or within our supply chain.

This statement, in compliance with the Modern Slavery Act 2015 sets out the steps which have been taken during the financial year ending 31 January 2023 and should be read alongside the company’s Corporate Responsibility and Sustainability initiatives, Code of Ethics and Human Rights Policy.

Bradburys Global Risk Group Limited is a global security risk management company with operations across multiple time-zones. As of 31 January 2023, the company has approximately 1,100 staff, partners, contractors and temporary workers providing services across multiple industries.

We recognise that certain industry sectors and regions present a greater risk of exploitation than others and we believe that our supply chain falls within such sectors and regions.

We employ thorough due diligence employment verification processes to prevent any illicit practices associated with slavery and human trafficking within our business and supply chains, including but not limited to:

• Identity verification
• Address verification
• Right-to-Work
• Financial checks
• PEPs & global sanction
• Online presence & adverse media
• Historical employment verification
• Reference verification
• Document verification
• Biometric identity
• Anti money laundering (AML)
• Digital Identity Trust Framework

We view supplier adherence to ethical and legal practices as an integral part of our business operations and adopt a stringent stance against modern slavery, pledging to conduct our business affairs and relationships with utmost ethics and integrity.

We expect all suppliers, regardless of size, spend or geographical location to adhere to our legal, ethical, environmental and employee-related standards as set out in our Supplier Code of Conduct and Sustainable Procurement Policy which form part of our supply chain management process which sets out clear statements around maintaining a responsible supply chain and not condoning any illegal or unethical behaviour by our suppliers, contractors or partners in line with our commitment to the UN Guiding Principles Reporting Framework.

We identify, assess and address risk to our supply chain including those related to human rights issues including modern slavery and human trafficking and our standard supplier terms provide us with the right to terminate contracts and agreements by written notice to a supplier with immediate effect if the supplier commits a material breach which is irremediable or, if such breach is remediable, fails to remedy that breach within a period of thirty days after being notified to do so. Being in breach of any applicable law (including the Act) would, in our view, amount to a material breach of our Supplier Code of Conduct.

Suppliers participating in the company’s procurement process are required to respond to a range of questionnaires surrounding ethical and legal obligations, including human rights, ethics and conduct, anti-corruption, diversity and corporate social responsibility. As part of this process – compliance towards labour and modern slavery are evaluated. In addition to the due diligence and submission of responses to our questionnaires, suppliers are also required to submit varying supporting evidence by way of documents, industry accreditations and references in support of their business operating practices.

Once a supplier is deemed to meet our criteria, they are then required to strictly adhere to our Supplier Code of Conduct and Sustainable Procurement Policy (or equivalent standards) as part of the procurement contract. This ensures that:

Suppliers and their subcontractors respect the rights of their employees and comply with all relevant legislation and laws within the country in which they operate;

Suppliers and their subcontractors abide by all relevant legislation and laws relating to the elimination of slavery and human trafficking and adhere to the same minimum standards set out in the Supplier Code of Conduct;

Suppliers permit Bradburys Global Risk Group Limited to perform annual compliance assessments to ensure compliance with our Supplier Code of Conduct and suppliers are expected to actively audit and monitor their own processes and procedures regarding the aforementioned code.

We acknowledge the scope and scale of our business and the impact it makes on our clients, our people, and society and we commit to continual monitoring and assessment of our standards and benchmark our approach against regulatory requirements, policy, industry peers and available guidance.

We are dedicated to establishing and enforcing robust systems and controls to prevent any occurrence of modern slavery within its UK business operations or across its supply chains.

We are committed to respecting and upholding internationally recognised human rights and are a global participant in the United Nations Global Compact which aims to align worldwide business strategies and operations with universal principles on human rights, labour, environment and anti-corruption. As such, we are guided by the United Nations Global Compact’s Ten Principles and the UN Sustainable Development Goals (SDGs) and have access to the UN Global Compact’s country-specific resources, activities, digital platform and tools and we issue an annual Communication on Progress upholding our commitment to the Ten Principles.

The company’s Managing Director, Andrew Blount, has overall responsibility for the Modern Slavery Act Policy and for ensuring that all those under the company’s responsibility are in alignment with it. Our Management teams have day-to-day responsibility for implementing the policy, monitoring its use and effectiveness to ensure that control systems and procedures are effective and sustainable in tackling modern slavery and human trafficking within our business and supply chain.

For the next financial year, we aim to focus on the following areas:

1. Introducing a supplier and vetting portal via third party technology so that we can analyse data from a variety of sources in order to assess the suitability of potential suppliers and to flag modern slavery and human trafficking issues that arise with existing suppliers.

2. Review existing policy and practice for supply chain workers and engage with suppliers to, where necessary, improve grievance and reporting processes within our supply chain.

3. Consider the implementation of Key Performance Indicators (KPIs) relating to supplier due diligence, management, training and awareness and reporting in respect of modern slavery and human trafficking along with measures taken should a supplier fail to achieve their KPIs.

4. Implement a whistleblowing hotline hosted by a third-party provider to ensure that we offer reassurance to employees that they will not be subjected to any retaliation or disadvantage as a result of reporting unethical practices.

This statement has been approved on behalf of Bradburys Global Risk Group Limited.

Andrew Blount
Managing Director
Bradburys Global Risk Group Limited