Modern slavery is a serious crime and a violation of fundamental human rights. Modern slavery can occur in any business section and it takes various forms such as slavery, servitude, forced and compulsory labour and human trafficking. All of which have the deprivation of a person's liberty to exploit them for personal or commercial gain in common.
We have a zero-tolerance approach to modern slavery and are committed to taking effective steps to prevent modern slavery within our supply chain and business. We ensure that Smart acts ethically and with integrity in all of our dealings and relationships by implementing effective and transparent systems and controls. We maintain the same standard for our suppliers, contractors and other business partners.
Smart has not identified any instances of modern slavery in its business or supply chain in the past 12 months.
Smart Pension Ltd is a technology company providing its Keystone Platform to Financial Institutions for the management of retirement savings, as well as being the funder for the Smart Pension Master Trust which is one of the largest auto enrolment/workplace pension master trusts in the UK.
Smart Pension Group has offices in the UK, USA, Poland, Spain and Dubai employing over 350 employees.
Our zero-tolerance approach to modern slavery is communicated to suppliers, contractors, third parties and business partners at the outset of our business relationship with them as part of our supplier due diligence and take-on process.
Smart expects its suppliers to conduct their affairs in an ethical way including avoidance of modern slavery. Due diligence according to the materiality and nature of the service provided is carried out as part of Smart’s supplier onboarding process governed by the Procurement Operating Policy.
As part of the onboarding process, suppliers of goods and services to Smart are required to confirm that they:
Smart has a full range of policies in support of its global compliance activities. The following policies directly support Smart’s commitment to preventing modern slavery.
Smart assesses and manages the risk of modern slavery through its Risk Management Process including in relation to its own employment practices and those of its third-party suppliers and partners.
Smart provides training on preventing modern slavery to all new employees including contractors. This training is repeated on an annual basis. All employees follow Smart’s code of conduct requiring them to behave ethically at all times. Smart maintains an anonymous third-party whistleblowing service and encourages employees to raise any concerns through this or internal channels.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and approved by the Group Risk and Compliance Committee on 6 December 2024 and signed by the Director of Risk & Assurance on behalf of the Board of Directors. For more information please contact the Risk and Assurance team at riskandassurance@smart.co.