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Modern slavery statement

Introduction

Chatham Financial Europe, Ltd (“CFE”) is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chains, and upholding and respecting the UN Universal Declaration of Human Rights, the 10 Principles of the UN Global Compact, and other internationally recognized human rights standards throughout our organization.

Modern slavery includes slavery, servitude, human trafficking, child slavery and forced labour. CFE is committed to acting responsibly, ethically and with integrity in all our business dealings. We believe that addressing modern slavery is essential to our corporate responsibility and to the integrity of the financial services industry.

As part of our compliance with the Modern Slavery Act of 2015, this Statement outlines the efforts we have undertaken related to modern slavery, which include:

  1. Policies and Procedures: Our overarching policies and procedures reflect our purposes and values, guiding all our actions. These policies ensure we serve our clients well and positively impact our communities, while upholding our commitment to ethical practices including the prevention of slavery and human trafficking.
  2. Reporting and Accountability: We encourage the reporting of any concerns or suspected violations of law, including those related to modern slavery, and take prompt action to address any issues identified. Our senior management team is accountable for the implementation and effectiveness of these initiatives.

Structure of the organisation

CFE is a subsidiary of Chatham Financial Corp., the parent company of the Chatham Financial group of companies ("Chatham”). Chatham is the largest independent financial risk management advisory and technology firm. CFE has a team of 90+ employees with main operations in London.

Due diligence and supply chain

CFE supply chains include IT services, hiring, legal services, payroll, accounting, and cleaning services. We review our vendor risk management procedures to consider modern slavery and human trafficking risks, as well as review our vendor agreements to ensure that they are aligned with responsible sourcing.

Risk management and effectiveness

We have assessed our operations and determined that we do not operate in high-risk sectors or locations as our business primarily involves providing financial services in highly regulated environments with stringent oversight. The activities we engage in within our supply chains present a low risk for slavery and human trafficking.

CFE regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chains and business. CFE considers:

  • The nature of the risks inherent to our business
  • Whether our internal policies and procedures explicitly address issues of slavery and human trafficking
  • Our vendor risk management procedures including, where appropriate, slavery and human trafficking controls
  • Our compensation structure compared to the prevailing minimum wage

Our policies on slavery and human trafficking

Chatham’s commitment to making a positive impact on the world is central to our daily operations. As part of CFE’s efforts to combat modern slavery and human trafficking, CFE has established the following policies:

  • Ethical Procurement Policy: This policy describes our expectation of all suppliers and partners to maintain our high standards of ethical conduct and to respect fundamental human rights.
  • Whistleblowing and Grievance Policies: These procedures allow employees and third parties to report any concerns or suspected violations of law, including those related to modern slavery confidentially, and without fear of retaliation.
  • Equal Opportunity and Recruitment Policies: These policies ensure that our recruitment practices are free from exploitation, verifying that workers are legally employed, fairly compensated, and working under acceptable conditions.

Additional engagement on ending slavery

Chatham is proud to have employees who are deeply passionate about ending slavery in our lifetime. In 2015, an employee began participating in the annual fundraising campaign of Dressember, an international movement to raise awareness and funds to fight human trafficking. This fundraiser provides critical help to rescue, protect, and restore the lives of trafficking victims and survivors worldwide.

Since 2015, Chatham employees and the Chatham Financial Foundation – which matches donations made by employees – have continued to raise funds annually in the fight against human trafficking.

Further actions and sign-off

Following our review of our actions and commitments this financial year, we plan to implement the following additional measures:

  • Policy Commitment: Regularly review and update our Modern Slavery Statement to reflect our ongoing efforts, new initiatives, and progress in combating modern slavery and human trafficking.
  • Capacity Building: Provide ongoing support to all employees involved in managing our operations and supply chains, particularly those who may be exposed to modern slavery and human trafficking risks.
  • Monitoring and Reporting: Routinely monitor our efforts to combat modern slavery and human trafficking and ensure accountability through transparent reporting.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes CFE’s slavery and human trafficking statement for the financial year ending December 2023

This statement was approved by CFE’s board on 7 August 2024.