The Modern Slavery Act 2015 (the “MSA”) seeks to address the role of businesses in
preventing modern slavery from occurring in their supply chains and organisations.
1. What is our Policy?
1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes
various forms, such as slavery, servitude, forced and compulsory labour and human
trafficking, all of which have in common the deprivation of a person's liberty by
another in order to exploit them for personal or commercial gain.
1.2 Our values include dedication to maintaining an honest and ethical practice that
is built upon integrity and an unwavering commitment to do the right thing. We are
committed to conducting our business and all our relationships based on integrity
and without modern slavery. We are also committed to ensuring there is
transparency in our own business and in our approach to tackling modern slavery
throughout our supply chains, consistent with the disclosure obligations under the
2. This Policy applies to all employees (fulltime, part-time and temporary and
including when on secondment), officers and directors of Tangency Capital Services
Ltd. (collectively, we, us, our or TCS), as well as agents, distributors, contractors and
suppliers when acting on our behalf (each a Company Representative).
2.1 This Policy does not form part of any employee's contract of employment and we
may amend it at any time.
3. Who is responsible for this Policy?
3.1 Our Board of Directors has overall responsibility for overseeing that this Policy
complies with our legal and ethical obligations prohibiting modern slavery and that
Company Representatives comply with this Policy.
3.2 The Chief Operating Officer has primary and day-to-day responsibility for
implementing this Policy, monitoring its use and effectiveness, dealing with any
queries about it, and reviewing internal control systems and procedures to check
they are effective in countering modern slavery.
3.3 Management at all levels are responsible for making arrangements for those
reporting to them understand and comply with this Policy and are given adequate
and regular training on it and the issue of modern slavery in our business and supply
4. Every Company Representative has personal responsibility for complying with all
applicable anti-slavery laws and regulations and this Policy.
5. What does compliance with this Policy involve?
5.1 The prevention, detection and reporting of modern slavery anywhere in our
business and supply chains is the responsibility of all those working for us and under
our control. Company Representatives must avoid any activity that could lead to a
breach of this Policy.
5.2 Likely conflicts with this Policy, whether current or future, must be notified as
soon as possible to the Chief Operating Officer. Company Representatives are
encouraged to raise concerns about any issue or suspicion of modern slavery in any
parts of our business or supply chains of any supplier tier at the earliest possible
5.3 If any Company Representative is unsure about whether a particular act, the
treatment of workers more generally or their working conditions within any tier of
TCS’ supply chains constitutes any of the various forms of modern slavery, they
should raise it with their line manager (where applicable) or the Chief Operating
6. We aim to encourage openness and will support anyone who raises genuine
concerns in good faith under this Policy, even if they turn out to be mistaken. We are
committed to ensuring that no one suffers any detrimental treatment or retaliation as
a result of any good faith report he or she makes to us about modern slavery. Any
Company Representative responsible for retaliating against individuals who in good
faith report known or suspected violations of this Policy to us will be subject to
disciplinary action, including dismissal where appropriate.
7. What communication and training is available to support this Policy?
7.1 Training on this Policy, and on the risks of modern slavery, forms part of the
induction process for individuals who work for us, and regular training will be made
available as necessary.
7.2 Company Representatives should be willing to discuss openly modern slavery
with our suppliers, contractors and business partners to check that they are aware of
this Policy and, as required by this Policy, about the measures which they
themselves are taking to reduce their modern slavery risks.
7.3 When entering into new supplier arrangements, we will, adopting a proportionate
risk-based approach, seek to ensure that our own standard anti-slavery clause or
similar appears in all supply contracts or that the supplier is aware of the MSA. The
clause obliges suppliers to confirm their adherence to this Policy and accept our right
(where practicable) to audit their anti-slavery activities and their own relationships,
both routinely and at other times. Where it is not practicable to negotiate this clause,the relevant supplier should be notified about TCS’ commitment to eradicating
modern slavery under this Policy.
8. What are the sanctions for breaches of this Policy?
8.1 TCS will take appropriate disciplinary and other action against any Company
(A) authorises or participates directly, and in certain circumstances, indirectly, in
actions breaching this Policy or any applicable anti-slavery laws or regulations;
(B) fails to report a breach of this Policy or any applicable anti-slavery laws or
regulations or withholds information concerning a breach they either know about or
should have known about;
(C) exhibits a lack of diligence and awareness about conduct that would constitute
such a violation;
(D) retaliates or attempts to retaliate, directly or indirectly (or encourages or attempts
to encourage others to do so), against someone who in good faith reports a breach
of this Policy or applicable anti-slavery laws or regulations to us; or
(E) knowingly files a false report of a breach of this Policy or applicable anti-slavery
laws or regulations.
Disciplinary and other action is dependent on the nature and severity of the violation,
up to and including termination of employment or the business relationship with TCS.
9. What about our MSA statement?
9.1 Where the turnover of us and our subsidiaries (if any) is or exceeds £36 million in
total annually, we will publish a MSA statement in accordance with s54, MSA.
Dated: June 14, 2023
This Policy may be revised from time to time.