Charities Trust Modern Slavery Statement
This Statement sets out Charities Trust’s actions to understand all potential modern slavery and human trafficking risks related to its business and to ensure steps are maintained to prevent slavery and human trafficking as defined in The Modern Slavery Act 2015. This Statement relates to actions and activities from May 2017 to April 2018. Charities Trust has a zero-tolerance approach to modern slavery and human trafficking and are fully committed to preventing these in its corporate activities and ensuring there is transparency across the entirety of the business.
As part of our initiative to identify and mitigate risk (including in relation to that of human trafficking and slavery) we operate a range of Policies, which serve to address the requirements of The Modern Slavery Act 2015.
Our Policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective due diligence and contractual compliance across the business. Relevant policies include:
- A dedicated Modern Slavery Policy – this Policy was recently reviewed and details in full, in conjunction with this Statement, our commitment to ensure that all risks associated with modern slavery and human trafficking are minimised.
- Supplier Compliance Policy – this Policy details the step we take in Charities Trust, to ensure that the suppliers we contract with meet their legal obligations. We monitor such contracts by internal controls and audits.
- Charity Screening Policy – this Policy notes our Due Diligence and Know Your Client/Donor processes, which in turn, reduces the risk of modern slavery and human trafficking occurring in our business relationships. This area has been identified where most impact can be made in terms of modern slavery and human trafficking by continuing to implement this Policy and our processes in the Due Diligence and Know Your Client/Donor landscape.
- Code of Conduct for Trustees, Staff Guide and Employee Awareness Policy – Our Code, Guide and Policy for Charities Trust makes clear to Trustees and employees respectively, the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee and Trustee ethical behaviour when conducting business.
- Whistleblowing Policy – At Charities Trust we encourage all of our employees, contractors and clients through this Policy, to report any concerns related to the direct activities, or the supply chains of, the business; including any circumstances that may give rise to an enhanced risk of slavery or human trafficking under the Act. Our whistleblowing procedure is designed to make it easy to make disclosures, without fear of retaliation. This Policy was recently reviewed with a dedicated Governance and Compliance Manager acting as the point of contact for such concerns, which would come under the remit of the Policy. To date, no concerns relating to modern slavery and/or human trafficking have been noted.
- Recruitment Policy – At Charities Trust, we use only specified, reputable employment agencies to source labour and always verify the practices of any new agency before accepting workers from that agency. All employees and contractors are subject to a DBS and Pre-Employment check.
- Safeguarding Policy - Our Safeguarding Policy sets out the legislative requirements to provide a duty of care promote positive well-being and provide a clear process for escalating concerns to protect the welfare of individuals. This Policy was recently reviewed with a dedicated Governance and Compliance Manager acting as the point of contact for such concerns, which would come under the remit of the Policy.
- Training Policy – At Charities Trust we encourage all staff to undertake regular training in line with their role; some of which is mandatory across the business and some of which is niche for certain departments/individuals with certain responsibilities. For the last number of years, modern slavery has featured in our training log. We are currently developing our 2019 training programme, where modern slavery will again feature and we are exploring other modules for staff to complete.
- Financial Crime Compliance Policy – this Policy was reviewed in December 2018, includes a section on Modern Slavery, and invites the reader to view our full Policy in this area. The Financial Crime Compliance Policy notes a dedicated Governance and Compliance Manager has oversight in this area, including that of Modern Slavery, Anti-Money Laundering, Due Diligence, Whistleblowing, Anti-Bribery & Corruption and Fraud.
- Risk Register – Charities Trust holds a full Risk Register, which documents all Risks across the whole of the business (including that of Modern Slavery), and what current and proposed mitigation is taking place to ensure the business is best protected.
Charities Trust is a one-site business operating in Liverpool, UK and a registered charity (registration number 327489), regulated by the Charity Commission and a Limited Company by Guarantee (company registration number 2142757), and regulated by Companies House. We are a leading donations management organisation committed to growing charitable giving since 1987. We offer a wide range of services to help our clients raise millions of pounds for good causes, easily, safely and tax effectively.
Our supply chains and supplier adherence to the values of Charities Trust
At Charities Trust, we expect the highest standards of conduct and probity throughout our supply chain, requiring all of our people to act with integrity and honesty. Our procurement processes include standard enquiries about modern slavery and trafficking and we examine our supply chain using our dedicated quality assurance functions including internal audit, supply chain management, legal and risk assessment. In turn, our suppliers expect us to evidence our commitment to the requirements set out in the Act in a similar way, which we provide when requested.
Charities Trust will continue to work with suppliers and contractors to ensure that they meet these standards and comply with the requirements of the Act. We will monitor such contracts with these and review if necessary.
Under Charities Trust’s business model, we will process payments for clients to pay registered charities, which we assess based on risk. As part of this procedure, a due diligence programme is undertaken to ensure that our legal obligations are met. Charities Trust delivers the necessary resources to ensure that risk is minimised through our Due Diligence and Know Your Donor/Client processes in line with our Charity Screening Policy when dealing with charity beneficiaries.
What we do
As part of our commitment to preventing modern slavery and human trafficking Charities Trust have:
- Maintained online training covering The Modern Slavery Act. Staff are required to complete training on the Act, including how to identify and escalate any concerns in line with our Modern Slavery Policy. The Governance and Compliance Manager will ensure that all staff complete this module as part of the 2019 training programme.
- Continue to review and develop relevant policies, processes and internal controls in place to support our commitment to mitigate risks of modern slavery across our organisation.
- Have a single point of contact in the business in this area, who co-ordinates policies, processes, training and education.
Charities Trust will review and update if necessary (at a minimum once a year), this Statement annually to meet the requirements of The Modern Slavery Act 2015. Our Modern Slavery Policy and Statement will be measured for effectiveness by recording KPI reports that fall under their remit by the Governance and Compliance Manager who will report to Board through the Executive Team. The Policy and Statement will be reviewed to reflect public policy and legislative changes.
This Statement is made pursuant to Section 54(1) of The Modern Slavery Act 2015 and constitutes our slavery and human trafficking Statement for the financial year ending 2018.
This Statement has been agreed by the Board of Directors and by Linda Minnis, Chief Executive of Charities Trust.