The UK Modern Slavery Act 2015 requires commercial organisations supplying goods or services with the UK to publish a Modern Slavery statement setting out the steps taken during the previous financial year to ensure that there is no modern slavery taking place in their own business or in any of their supply chains.

This statement is made in pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and sets out the steps that Martello Financial Services (Martello Financial Services Limited) has taken during the previous financial year to ensure that there is no modern slavery taking place in our businesses or in any of our supply chains.

Martello Financial Services is committed to compliance with the provisions of the Act, and is opposed to any form of slavery, servitude, forced labour or human trafficking.

About Martello Financial Services

Martello Financial Services is headquartered in London, UK. The company was incorporated in 2009. Martello Financial Services is a specialist firm of financial services professionals providing a range of expert witness, dispute resolution, advisory, investigative and electronic disclosure services globally.

Steps in the core business to address Modern Slavery

Martello Financial Services’s values are the essence of our identity and they support the vision, drive, culture and conduct within the business. The values are:

  • Professionalism
  • Attention to detail
  • Independence
  • Integrity

The employee handbook summarises the principles of honest and ethical conduct that Martello Financial Services expects every employee to know and follow. These duties state that a working environment free from harassment and where all staff are treated, and treat others, with dignity and respect, will be provided. The company also states a commitment to equality of opportunity in employment, with aims of ensuring that all employees and job applicants are treated fairly and equally, supporting the company’s objective of providing a working environment that is free from all forms of discrimination.

All Martello Financial Services employees are required to read the Employee Handbook and confirm that they will adhere to the policies and practices when they join the company, and annually thereafter.

Martello Financial Services has a robust recruitment policy that includes conducting checks confirming eligibility to work in the UK and other countries in which we operate to safeguard against human trafficking or individuals being forced to work against their will.

Martello Financial Services encourages its employees to report any issues or concerns they may have about potential ethics violations or other potentially illegal conduct, which may include modern slavery/human trafficking. Employees can report concerns in a confidential manner.

Steps taken in our Supply Chain

Martello Financial Services’s supplier/client relationships are based on lawful, efficient and fair practices. We expect our suppliers to obey the laws that require them to treat workers fairly and provide a safe and healthy work environment. Martello Financial Services will not knowingly use any supplier that uses forced, prison or indentured labour.

Martello Financial Services conducts due diligence on key suppliers/clients. This includes an online search to check the organisation’s reportable offences through a proprietary third-party assessment and risk mitigation tool or a background check vendor. Over the past year, key third-party suppliers/clients that were not previously checked have been assessed through the assessment and risk mitigation tool.

Future Plans

Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains, we intend to take the following further steps to combat slavery and human trafficking:

  • Martello Financial Services will develop and implement specific training regarding the Modern Slavery Act for employees responsible for client engagement;
  • Martello Financial Services will conduct a review of our supplier/client contract language for inclusion of statements regarding our expectations to help prevent modern slavery and human trafficking;
  • Martello Financial Services is developing an Anti-Slavery policy to be included in our employee handbook that will set out our stance on modern slavery and human trafficking, and explain how employees can identify instances of this and where employees can go for help; and
  • Martello Financial Services will continue to review our key suppliers/clients that are contracted with us through the assessment and risk mitigation tool.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Martello Financial Services’s modern slavery statement for 2019.

This statement has been approved by the board and management of Martello Financial Services. Michaela Manning, Chief Compliance Officer, has been authorised to sign this statement on behalf of Martello Financial Services.

Michaela Manning, Chief Compliance Officer

For and on behalf of Martello Financial Services.

Last Updated: 4th December 2020