Modern Slavery Statement

Sovereign Group Modern Slavery Statement 2022

Introduction

The Sovereign Group is a leading independent provider of corporate, private client and retirement planning services, with a presence in over 20 jurisdictions around the world. We have over three decades of experience in managing corporations and estates with complex structures in multiple jurisdictions. We pride ourselves on the exceptional breadth and depth of our technical knowledge and are fully committed to maintaining compliance and always promoting ethical conduct.

We also provide the support to maximise opportunities and achieve long-term sustainability. This includes asset management, accountancy, payroll, foreign property ownership, residency, immigration and citizenship, insurance, yacht and aircraft registration, as well as specialist tax advice.

We hold over 30 professional licences to act as corporate service provider and/or professional trustee from the jurisdictions in which we operate around the world. To obtain these licences, Sovereign has demonstrated its financial stability, its probity, the professional competence and integrity of its staff and the robustness of its systems.

Organisational Structure

The Sovereign Group Ltd is a private limited company that is incorporated in the Isle of Man. It owns and operates a number of subsidiary companies in Africa, Asia, Europe, the Middle East, Gibraltar, Guernsey and Isle of Man, as well as the United Kingdom. Each of these subsidiaries is a separate legal entity. The Sovereign Group, via its subsidiary companies, employs over 500 people worldwide.

This statement is published pursuant to Section 54 of the UK Modern Slavery Act 2015 on behalf of The Sovereign Group Ltd and its affiliated businesses.

Policies in relation to Modern Slavery or Human Trafficking

The Sovereign Group Ltd (‘Sovereign’) is committed to combatting slavery and human trafficking and to ensure that this does not take place in any part of our business or our supply chains. Sovereign’s staff are predominantly professionally qualified individuals who are employed directly by a subsidiary. Our policies ensure the fair treatment of our staff around the world.

As a professional services business, we comply with all relevant laws and regulations in the jurisdictions in which we operate. We have robust policies and procedures in place to combat the risk of any part of our business being exposed to money laundering, terrorist financing, bribery and corruption.

We also have policies and procedures in place to ensure that the culture within Sovereign is one of lawful and ethical behaviour, openness, trust and integrity. Many of our employees are members of professional organisations and are themselves subject to professional codes of conduct.

Business and Supply Chains

As a professional services business, our most significant risks in relation to modern slavery are in our supply chain. We source from a number of different suppliers providing us with a large range of products and services from stationery to ICT technology hardware and various services from software and consulting to cleaning, security and facilities management.

Sovereign is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

The core values that underpin Sovereign’s business culture are: “Listening, understanding, planning and delivering”. Such values outline the expectation Sovereign has for its employees’ behaviours with colleagues, other subsidiary companies, our customers and our suppliers of products and services around the world.

Risk Assessment and Due diligence

Sovereign has zero tolerance for slavery and human trafficking. To ensure all those in our supply chain and / or contractors comply with these values, we have put in place a supply chain compliance programme as follows:

A. Products and services

• Customer and member base – We will always complete due diligence and have extremely high ‘Know Your Customer’ standards built into our processes and control framework.
• Assets and investments – We have high standards of due diligence across all new assets proposed by members for inclusion in their investment portfolios.
• Business partners – We ensure all strategic partners meet the highest ethical standards and will take contractual enforcement where we identify any modern slavery practice.

B. Corporate operations

• Managed and offshore services – Where any work is outsourced, we will ensure appropriate controls are in place.
• Recruitment – We will only operate with ethical recruitment agencies and complete due diligence on all new hires to our organisation.
• Employment – We have robust employment policies that protect our employees from unfair treatment and promote a fair and inclusive workplace.

C. Corporate supply chain

• Office equipment and products – We will only procure office equipment, ICT hardware and electronics from suppliers with the highest ethical standards.
• Cleaning, security and facilities management – We will only procure cleaning, security and facilities management services from suppliers with the highest ethical standards.
• Catering, hospitality and entertainment – We will only procure catering, hospitality and entertainment services from suppliers with the highest ethical standards.

Training and Awareness Raising

All our employees complete a Modern Slavery Act learning course such that they understand the United Kingdom Modern Slavery Act 2015, how it is applied in practice and their role in escalating any areas of concern.

Goals and Key Performance Indicators

Sovereign uses a number of Key Performance Indicators to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains. These include logging complaints received via our whistle blowing policy, or through other channels. To the date of this statement, Sovereign has identified no instances of modern slavery or human trafficking.

This statement is made pursuant to section 54(1) of the United Kingdom Modern Slavery Act 2015 and constitutes Sovereign’s slavery and human trafficking statement for the financial year commencing 1st June 2021 and ending 31st May 2022. It was approved by the board on 8 February 2022.

Gerry Kelly,
CEO of The Sovereign Group Ltd