MODERN SLAVERY STATEMENT
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (the ‘Act’) and sets out the steps the Titan Wealth Group[1] (‘TWG’) has undertaken, and will continue to take, to ensure modern slavery or human trafficking is not taking place within our business or supply chain. We have prepared this statement based on our understanding of the definition of ‘modern slavery’ – a term which encapsulates slavery, servitude, forced or compulsory labour and human trafficking.
Our Position
At TWG, we are committed to becoming a leading responsible business, which means putting responsible and sustainable decision making at the heart of everything we do. As such, we are committed to operating in a responsible and ethical manner, and ensuring the relationships we have with all our stakeholders adhere to high standards, including clients, partners, employees, shareholders and suppliers. We will not tolerate or condone the abuse of human rights (including modern slavery) in any part of our business. We are committed to identifying and minimising the risk of slavery or human trafficking in all parts of our supply chain.
Our Business
The Titan Wealth Group is a discretionary fund management/wealth and asset management business providing high-quality execution and administration to the asset and wealth management sectors in the UK. There are Titan Funds domiciled in Ireland and the United Kingdom. Titan is a signatory to the United Nations supported Principles for Responsible Investment, a voluntary framework for incorporating environmental, social (including modern slavery) and governance (“ESG”) issues into investment and ownership decisions. As part of a bottom-up investment research process, Titan considers a range of factors that might affect a company’s intrinsic value, which can include ESG issues. Titan’s research on ESG factors informs decisions not to invest as much as it informs decisions to invest.
Risk of Human Trafficking and Slavery
TWG does not tolerate modern slavery or human trafficking and takes a risk-based approach to its supply chain. The nature of our business means that the Titan Group do not have complex supply chains and do not procure material services from suppliers in high-risk countries. Our suppliers are predominantly regulated financial and professional service companies, including banks, data service providers, accountants and law firms. The Titan Group also have suppliers of equipment and maintenance and support services for our office locations. Given the professional nature of our business, the Titan Group have a low risk of modern slavery or human trafficking existing within our business operations and supply chains
Steps Taken
The Titan Group believe that they undertake appropriate due diligence in relation to new suppliers and expect suppliers, and their supply chains, to comply with all relevant legislation and regulations in the countries in which they operate or which are otherwise applicable to them. The Titan Group also has a Whistleblowing Policy, which provides employees a clear path to report issues and concerns. The policies of the Titan Group are periodically reviewed and, where necessary, will be updated to reflect the Titan Group’s continuing commitment to ensuring that modern slavery and human trafficking are not present in their supply chain.
Policies in relation to slavery and human trafficking
- All employees receive a copy of our Equal Opportunities Policy, which makes it clear we oppose all forms of discrimination or victimisation
- Our Bullying and Harassment Policy also sets out our approach in relation to allegations of harassment and/or bullying. Harassment, in general terms, is defined as unwanted conduct affected the dignity of people in the workplace. It may be related to age, sex, race disability, religion, nationality or any personal characteristics of the individual and may be persistent or an isolated incident
- Our Whistleblowing Policy is in place that enables employees (including temporary or permanent employees, contractors, agency workers, interns and those on work experience) to raise any concerns they may have about illegal or improper behaviour by anyone connected to TWG, without fear of victimisation, discrimination or disadvantage. We provide annual training to employees on the whistleblowing process and how to make a disclosure.
In addition to the above policies, we offer our employees the opportunity to seek independent and impartial advice via confidential telephone and email counselling services provided through our employee assistance programme, should they wish.
CONCLUSION
This statement will be reviewed annually and updated as required. It has been reviewed by key stakeholders and was approved by the Board of directors of Titan Wealth Holdings and all TWG Boards in June 2023.
[1] This statement has been made on behalf of Titan Wealth Holdings Limited, Global Prime Partners Limited, Titan Wealth Solutions Ltd, Titan Asset Management Limited, Titan Investment Solutions Limited, Cardale Asset Management, Haibun Wealth Limited, Goldsborough Wealth Limited for the financial year ending 31 March 2023.