ANTI-SLAVERY AND HUMAN TRAFFICKING STATEMENT

This document was last updated on the 20th December 2024.

1. Introduction

Modern slavery continues to be a priority for 4most to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain.

2. Organisation’s business and structure

4most (Europe) Limited is a global credit risk analytics and actuarial consultancy.  We are part of the 4most Group and have our head office in England. Our ultimate parent company is Sandcastle Holdco Limited.

We have subsidiaries based in each of Ireland, India, Netherlands and the UAE.

The 4most Group has over 250 employees worldwide and a global annual turnover for the year ending September 2024 of c.£36m.

If you would like to find out more about our business, please click 4most | Redefining Global Consulting.

3. Our supply chain

In the 23/24FY, the 4most Group had no documented cases of modern slavery.

Our supply base is comprised of suppliers in the professional service sectors such as legal, tax, accounting, property, recruitment, marketing and suppliers of IT software and office equipment.  Our suppliers are mainly located in the UK. However, we have some professional advisors in the other countries we operate in.

We consider our sector and the type of services we purchase to be low risk.

4. Our policies

We have the following policies in place relevant to modern slavery, which we continuously review and update:

• Sustainable Purchasing Policy. This policy is to ensure the buying practices of 4most are effective, transparent, fair and in line with all applicable laws and regulations.
• Business Partner Code of Conduct. This code builds upon these principles by ensuring that our supply chain partners adhere to ethical labour practices, environmental sustainability, and social responsibility.
• Employee Code of Conduct. This policy establishes clear expectations for the conduct of our employees. It underscores the importance of fair labour practices, non-discrimination and the prohibition of any form of exploitative labour.
• Whistleblowing Policy. This policy is to encourage staff to report suspected wrongdoing as soon as possible and provide staff with guidance as to how to raise these concerns.

5. Preventing modern slavery in our business

We have a dedicated compliance team, which consists of involvement from the following departments:

• Compliance
• Legal
• Human resources
• Finance
• Operations

At the start of every supplier relationship, we undertake due diligence on the supplier, so we know who is working for us, or on our behalf. Our due diligence checks include KYC, PEP, sanctions screening and adverse media.  We use an intelligent search company to continually monitor our suppliers.  Enhanced due diligence is also undertaken on those suppliers in high-risk countries or where there are unknown circumstances associated with the supplier, beneficial owner or wider business relationship or transaction.

All suppliers are required to confirm compliance with our Business Partner Code of Conduct or demonstrate compliance in another way.

We make concerted efforts to foster responsible relationships with our suppliers.  For example, every supplier has a 4most relationship manager who is responsible for ongoing relationship management.

In addition, in September 2024 we introduced a new Sustainable Purchasing Policy.  All suppliers are to be selected in accordance with this policy.

Together, these practices are designed to:

• Establish and assess areas of potential risk in our business and supply chains.
• Monitor potential risk areas in our business and supply chains.
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
• Provide adequate protection for whistleblowers.

6. Our effectiveness in combating slavery and human trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• Percentage of suppliers that have been subject to our due diligence checks (target 100%).
• Percentage of suppliers that have signed and agreed to adhere to our Business Partner Code of Conduct or have their own equivalent (target 100%).

7. Further steps

Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:

• Embed our new Sustainable Purchasing Policy within the business.
• Include explicit anti-slavery and human trafficking clauses in our contracts with suppliers.
• Provide comprehensive compliance and ethics training to our staff at the start of their employment and annually thereafter.
• Additional KPIs:
  • Percentage of employees trained on issues relating to slavery and human trafficking (target 100%).
• Regularly update and strengthen our internal policies related to modern slavery and human trafficking.
• Regularly review and update this statement highlighting achievements and areas for improvements.

8. Accountability

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes the 4most Group’s slavery and human trafficking statement for the financial year commencing 1 October 2023 and ending 30 September 2024.

This statement was approved by the Board of Sandcastle Holdco Limited on 18 December 2024.

If you have any comments on this statement or would like to report any matter relating to it, please email legal@4-most.co.uk.