Modern Slavery Act
2nd December 2019
Modern Slavery Statement:
Pursuant to section 54 of the Modern slavery act 2015, this statement outlines Millbank FXs approach to modern slavery and human trafficking, which is due to be rolled out in effect of 1st January 2020.
Millbank FX is committed to preventing slavery and human trafficking in its corporate activities.
This statement covers the activities of Millbank FX Ltd
Millbank FX is an international foreign exchange institution, covering the retail foreign exchange industry. We operate in the United Kingdom, the Netherlands and currently employs over 15 people.
Millbank FX operates a number of policies which reflect our objectives to act ethically and in line with our legal and regulatory obligations with regard to our employees, customers and our business relationships.
Modern slavery and human trafficking policy
· Whistleblowing policy The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact Protect (independent whistleblowing charity) on 0203 117 2520 or email them on firstname.lastname@example.org
· Employee code of conduct The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour.
We organise these standards under four principles with clear lines of individual responsibility.
o Customers-we treat customers fairly;
o Conduct-we act with integrity in our dealings;
o Colleagues-we are respectful to each other and value the contribution of others
o Compliance-we comply with the code, our policies and procedures.
Millbank is not in an industry with a high risk of modern day slavery, a risk based approach has been adopted to review supply chains that fall within industries that carry a high risk of modern day slavery. In conducting appropriate due diligence, Millbank assesses its suppliers across a number of key risk areas, at the on-boarding stage. Millbank seeks assurances (where appropriate) from our suppliers that they are complying with applicable laws and regulations including laws relating to minimum wages, working conditions, overtime, child, labour and other applicable labour and environmental laws. This allows us to select suppliers to work with us who adhere to appropriate standards.
Training and Awareness:
Millbank FX is focused on raising awareness of the policies listed above with colleagues. A key part of our slavery and human trafficking strategy is to promote cultural change through training each year.
· Delivered online training modules on modern slavery to all staff.
· the basic principles of the Modern Slavery Act 2015;
· what external help is available, for example through the Modern Slavery Helpline.
This statement was approved on 02.12.2019 by the organisation’s board of directors. Benjamin Wilson & Matheu Crisp who review and update it annually.