Modern Slavery & Human Trafficking Statement

Introduction

This statement seeks to outline Bower’s commitment to combat modern slavery risks through the practices we adopt and the systems we have in place. The statement pertains to the calendar year ending 31st December 2022.

In line with our Corporate Social Responsibility Policy – and to illustrate our dedication to following transparent and ethical business practices – we have published our annual Modern Slavery and Human Trafficking Statement. We have done so with a view to providing more information on the measures we are taking to fight against such unethical and immoral practices.

Like any responsible organisation, Bower has a zero-tolerance approach towards modern slavery. We take active steps to ensure no activities relating to slavery or human trafficking are present in either our corporate operations and/or within our supply chains.

About our organisation

Bower Wealth offers financial advice to individuals, families, and businesses.

Our policies

Creating this document is just one of the measures we are taking to combat modern slavery.

We will also be:

• Complying with all national laws that relate to ethical employment and trading
• Operating sourcing and buying policies that are fair to all parties
• Identifying and evaluating specific areas of risk with regards to slavery and human trafficking activities, whether relating to or responding to product-, company- or geographical-based concerns
• Ensuring our procurement processes are designed to identify supplier concerns in risk areas
• Conducting supplier audits or assessments where necessary to evaluate potential and existing suppliers in relation to their modern slavery policies Ensuring supplier relations are designed to support improved product/service traceability
• Engaging frequently with our suppliers to gain a thorough understanding of their own practices and ensure they too are in line with the goals of this Statement
• Engaging frequently with our suppliers to ensure they are aware of pertinent slavery and human trafficking issues
• Improving our own knowledge of modern slavery practices so we are better positioned to identify and eradicate them

We understand that our biggest exposure to modern slavery is in our product/service supply chains. New supplies and/or sites are subject to due diligence checks, and we expect to undertake compliance audits upon the establishing of new agreements and at suitable periodic intervals throughout our relationships with these companies.

We will expect the following from our suppliers:

• To never employ anyone below the minimum age for employment
• To never use force, bonded, compulsory or trafficked labour
• To not hold anyone in slavery or servitude, be they adults or children
• To allow their workers to leave their roles after providing suitable notice
• To never make their workers pay to secure their jobs
• To always supply clear, written information on their employment conditions before they start work
• To always ensure wages meet or exceed legal standards in the appropriate country
• To always ensure working hours comply with national laws
• To treat all their employees with respect and dignity
• To apply the above standards to their own business activities and ensure they are adhered to by their own supply chains

How will we measure compliance?

In order to assess the effectiveness of our modern slavery measures, we expect to review the following key performance indicators on a regular basis:

• Staff training levels
• Number of slavery incidents reported in the supply chain (currently 0)

We want to raise general awareness of modern slavery topics amongst staff and stakeholders. We provide information to inform our staff:

• How to identify the signs of slavery and human trafficking
• How to assess the risk of slavery and human trafficking in relation to various aspects of our business, and the businesses of our suppliers
• How to report – and escalate – suspected malpractice within our organisation
• What steps should be taken if our business is suspected to be in breach of our anti-slavery policy
• What steps should be taken if suppliers are found to not implement anti-slavery policies
• What external help and support is available

What resources are available to staff?

We recommend that our staff familiarise themselves with the work and policies of the below organisations:

Modern Slavery Helpline: https://www.modernslaveryhelpline.org/

Gangmasters and Labour Abuse Authority: https://www.gla.gov.uk/

Stronger Together: https://www.stronger2gether.org/.