Slavery and Human Trafficking Statement for the year ending 31 March 2023
Introduction
The UK Modern Slavery Act 2015 (the “Act”) requires businesses to state the actions they have taken during the financial year to ensure modern slavery is not taking place in their operations and supply chains.
Pursuant to section 54(1) of the Act, this statement refers to the financial year ending 31 March 2023 and sets out the steps taken by Rigby Capital Limited (Rigby Capital) to prevent modern slavery and human trafficking in our own supply chains. Rigby Capital is a subsidiary of Rigby Group (RG) Plc which has published its own statement under the Act which is available at www.rigbygroupplc.com. Rigby Group (RG) plc is the holding company of several different divisions, comprising the Rigby Group.
Our Commitment
Rigby Capital’s mission isto empower our customers and partners to improve their business models and performance, thanks to our sustainable financial solutions. We are committed to the principles of the Act and to the abolition of modern slavery and human trafficking. This is commitment is underpinned by our values.
We are committed to supporting our customers and partners on a daily basis to provide the solution best suited to their needs:
- Trust – trust is the ultimate marker of our humanity and ethics. It is integral to the consideration we have for all people, be it our employees, customers or partners
- Unity – we create strong and lasting relationships with our employees, partnersand customers
- Daring – we have a desire for innovation and action
- Agility – being able to adapt and be flexible is crucial
- Positivity – we are a constructive, friendly and caring company and we seek the best for our employees, customers and partners
Our values drive our approach and strategy in all aspects of our business. We do not tolerate any activities within our business or wider supply chain which could encourage or facilitate modern slavery, human trafficking, forced labour, child labour or any other form of unethical or illegal labour.
Business Structure
Rigby Capital is a subsidiary within the Technology division of Rigby Group (RG) plc. We operate in the UK and have a sister company (Rigby Capital SAS) operating in France to provide funding solutions to our customers and partners for all types of business equipment. We have a tight-knit team that brings the organisation close to employees and customers whilst providing an agile and highly responsive decision-making structure.
Rigby Capital’s Operations and Supply Chains
Rigby Capital has grown significantly since its inception in 2014 and, with an experienced team, has created an agile and successful business that has an impeccable track record and long-established supplier relationships. Thisenablesusto offer world class, bespoke funding solutions which unlock value for our customers. With such a fast-moving and evolving business we must be acutely aware of the many different facets of our operations and be alive to the challenges we face within each individual supply chain.
We have collaborative relationships with many different vendors and partners as well as strong connections with finance partnersmeaning our various supply chains and stakeholders are diverse. The key areas are labour, materials, goods and equipment. We actively encourage and require our partners and vendors to also operate in such a way that respects human rights and the dignity of all people. On the basis that the majority of our supply chain is based in the UK, we do not consider that the countries from where are supplies are sourced are high-risk from the perspective of modern slavery and human trafficking.
Proactive steps to prevent modern slavery
Driven by our values, we strive to create close and fruitful working relationships with all our customers, partners, suppliers and employees which are based on trust. To provide the reliable and innovative services we offers, we ensure that the suppliers we work with are aligned to our values and we focus on relationship-management.
Our approach to modern slavery is acombination of our values and ethos together with the application of policies and procedures, employee training, risk assessment and due diligence.
Policies and Procedures
Rigby Capital has developed and maintains our own policies and procedures on key matters. The policies and procedures reflect our values and the importance we place on matters such as modern slavery and human trafficking. Our key policies which demonstrate our position on modern slavery include our Supplier Code of Conduct, our Employee Code of Conduct, our Anti-Slavery Policy and all our Funder master funding contracts contain applicable provisions.
We have not received any reports of nor discovered any instances of slavery or human trafficking within our supply chains. However, were any to arise, the board of directors would take the matter very seriously and act swiftly to audit the supplier (where an allegation only is made) and / or terminate any operations with the supplier (where such practices are proven) with immediate effect. Reporting on such matters would happen at our company level and would also be reported through Rigby Group’s Audit, Risk and Remuneration Committee (further information in our Risk Assessment section below).
All our staff are appraised of all new policies and procedures as soon as they are released, with regular training sessions and workshop events (in person and via video calls) planned in when required.
Risk Assessment
We assessthe potential modern slavery risks associated with our supply chainsby considering a number of factors as part of our wider business strategy. We consider the geographic location of our suppliers as well as noting the higher risk sector in which we operate. We understand that the financial sector is considered a higher risk sector with respect to modern slavery and therefore have strict and engaged processes in place when choosing suppliers to work with our company.
We continue to work with our contractors, suppliers, business partners and other third-party suppliers or businesses to ensure that they are open and transparent in their activities and are compliant with the Act.
The Rigby Group has established a Rigby Group Audit, Risk and Remuneration Committee which, in addition to the management of both internal and external audit processes and financial reporting, has a strong focus on risk management. Rigby Capital has nominated an Enterprise Risk Owner to participate in the Risk Committee which meets at least once a year to identify and document key enterprise risks which are then reported to the Risk Committee for discussion with the shareholdersof the Group. Rigby Capital currently already has robust risk management procedures in place but welcomes the furtherance of the top-down commitment to this important area. To the extent any concerns or risks regarding modern slavery are identified these will be dealt with the utmost priority and measures will be implemented to eradicate any such risks to the extent possible.
Due Diligence
In addition to our usual “know your customer” checks we also carry out the following modern slavery specific checks when onboarding new suppliers and/ or reviewing our existing suppliers:
- carry out financial due diligence;
- confirm company details with applicable registers;
- carry out IR35 assessments;
- map the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
- evaluate the modern slavery and human trafficking risks of each new supplier;
- use https:/ /www.modernslaveryregistry.org, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
- use approved recruitment agencies or accredited umbrella companies when recruiting temporary labour for internal and operational requirements.
Future steps to prevent modern slavery in our supply chains
We understand that risks of modern slavery are dynamic and can change quickly.
We will continue to monitor the modern slavery risk by way of policy, risk assessment, training and due diligence and will seek to measure the effectiveness of steps taken to minimise such risk on a regular basis.
During the course of the next financial year, Rigby Capital will work on the following objectives relatingto modern slavery which will be assessed and measured at the end of the next financial year:
- to review Rigby Capital’s current business objectives to ensure they do not make the supply chain vulnerable to slavery and human trafficking;
- to extend the supplier onboarding process to include additional questions on anti-slavery practices;
- to consider whether a supplier auditing process would be appropriate for Rigby Capital.
We reiterate that issues of such severity as slavery and human trafficking are of great importance to our company, the Rigby Group and to the owners, each of which continues to encourage and promote a safe, fair and honest workplace for its employees, customers, partners and those of its suppliers.
This statement was approved by the board of Rigby Capital Limited.
Signed:
John Taylor
Director
Rigby Capital Limited
Dated: 15th May 2023