SLAVERY AND HUMAN TRAFFICKING ANNUAL STATEMENT
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes the Company’s (as defined below) slavery and human trafficking statement for the financial year ending March 31, 2021 (the “Relevant Term”). This statement was approved by the Board on September 10, 2021. It will be reviewed (and where necessary, updated) on an annual basis.
EnTrust Global Ltd. (the “Company” or “we”), is a private company limited by shares incorporated in England and Wales. For the Relevant Term, the Company oversaw its affiliates or branches in Hong Kong, Beijing, Korea and Singapore. The Company is engaged exclusively in the business of investment management and distribution.
Under section 54 of the Act, commercial organisations that supply goods or services, carry on business in the United Kingdom and meet the annual turnover threshold of at least £36m from the provision of goods and services must publish an annual slavery and human trafficking statement. Modern slavery takes various forms, such as slavery, servitude, human trafficking, as well as forced and compulsory labour, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. It is a crime and a violation of fundamental human rights.
The Company considers, given the nature of the services that we offer, that the risk of involvement in modern slavery and human trafficking is low. However, we have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems to ensure that modern slavery and human trafficking are not taking place anywhere in our own business or supply chain. This commitment is communicated to all suppliers, contractors, business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
The Company has a robust recruitment and onboarding process with multiple checks built in to ensure all individuals employed by the Company have the right to work in the United Kingdom, are paid a fair salary in compliance with all relevant rules and regulations, and are not subjected to human trafficking or forced labour.
We maintain a reputation for conducting our business activities in the highest ethical and professional manner. All employees are expected to comply with EnTrust Global’s Code of Conduct which sets out basic principles designed to guide our employees, officers and directors. All employees, officers, and directors must conduct themselves in accordance with this Code and seek to avoid even the appearance of improper behaviour.
Our commitment to creating and sustaining a diverse workforce is absolute and sustaining a work environment where our people feel comfortable bringing their full selves to work and are empowered to reach their full potential is a priority. We emphasise fair treatment of people, as demonstrated by our anti-discrimination and conduct-related policies. Relevant policies are reinforced through regular diversity and inclusion training.
We pride ourselves on our reputation for conducting our business activities in the highest ethical and professional manner and we expect our suppliers to adhere to these same standards and principles. The Company’s supply chain includes the following types of third-party suppliers (many of which are also independently subject to the provisions of the Act):
As part of its initiative to identify and reduce the risk of slavery and human trafficking occurring within our supply chain, the Company:
The Company uses the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
The Company operates in line with the United National Principles for Responsible Investment which provides a voluntary framework for incorporating environmental, social and governance (“ESG”) principles in investment decision making practices.
We continue to look for ways to improve on the above actions to ensure that robust, effective, proportionate and focused processes are in place to identify and rapidly address the risks of slavery wherever they occur in or business or supply chains.