Modern Slavery Statement

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Themis has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain. Although Themis does not currently reach the turnover threshold at which it is required by law to publish a modern slavery statement, we believe in public disclosure by all organisations of the efforts they have taken to tackle this crime. We encourage others to do the same.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Themis has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Business

Themis is a specialist financial crime technology firm headquartered in the United Kingdom but with operations in other countries. We do not currently meet the reporting requirement threshold of £36 million turnover set out in the UK Modern Slavery Act, however we have chosen to publish this statement in order to demonstrate our commitment to tackling his important issue.

Themis helps clients identify and manage their specific financial crime risks, through a combination of innovation, insight and intelligence. Financial crime is a very real and evolving problem. Not only is the scale of illicit activity in the trillions of £s, but the impact on all of our businesses, the economy and society is profound. As part of our work addressing financial crime we have a strong workstream dedicated to tackling modern slavery and human trafficking.

At the beginning of 2020 Themis began a year long research project in partnership with the UK Independent Anti -Slavery Commissioner and the TRIBE Freedom Foundation, which looked at the links between the financial services sector and modern slavery. Over the course of one year the team undertook detailed research and conducted virtual roundtable events as part of our industry outreach programme. We reached out to over 3,000 individuals and organisations, hosted 18 virtual roundtable discussions, attracting over 700 participants to our live webinars. The key objectives of the project are to raise awareness of the issue and to contribute towards a change in approach and culture at the top of financial services organisations. We believe that if companies are to change their attitudes towards modern slavery,

the tone needs to be set at the top. The culmination of the research project was a report highlighting the links to modern slavery, the current trends, and a call to action for industry leaders. The report was launched on 18th January 2021.

Throughout 2021 our focus turned to a new phase of work in partnership with the UK Independent Anti-Slavery Commissioner, Unseen, and the UK Modern Slavery Training and Delivery Group. On 29th March 2022, the UK Independent Anti-Slavery Commissioner, the UK Modern Slavery Training Delivery Group and Themis launched an Anti-Slavery Digital Learning course in partnership with AllianceBernstein, RedCompass Labs and Unseen.

This is part of a UK government led campaign to ensure all 70,000+ Financial Institutions across the UK get the same threat intelligence concerning MSHT as well as a suite of practical tools and resources that they can employ to enhance their controls as part of a whole system response.

It is a free to access course that financial institutions and other professionals and directors can take to help them understand their potential linkages to MSHT. Users can either take the course directly from the Learning Management System here. Or, companies can take the SCORM package and put it on their own LMS to aid internal distribution. Our request is that business leaders make this a mandatory course for all of their staff at all levels of the organisation. To date, together with our partners, we have reached out to over 100,000 individuals, with further outreach activities planned for the coming months.

Our Policies

We have set ourselves the target of developing and implementing the following internal policies to ensure that we are conducting business in an ethical and transparent manner:

  • Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.

  • Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

  • Code of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.

We are a signatory to the United Nations Global Compact and support the objectives of the ten principles. The UN sustainable development goals, including goal 8 and target 8.7 thereof, are reflected in our company balanced scorecard.

Our Suppliers & Due Diligence

Themis conducts due diligence on all suppliers, clients and associates before working with them. In particular, our focus is on the following areas:

  • Culture & Strategy:

    • We believe that Senior Management has an important role to play in setting the tone with regards to modern slavery across the organisation, and embedding approaches to detect and disrupt the practice.

    • At Themis addressing modern slavery and raising awareness of the crime is a core part of our work. The CEO chairs the financial services working group of the UK Modern Slavery Training Delivery Group, a government led initiative to deliver modern slavery training across the industry.

    • We have established a not-for-profit multi-year research project in partnership with the UK Independent Anti-Slavery Commissioner, to raise awareness and change attitudes towards modern slavery in the financial services industry.

    • We are asking CEOs of all financial institutions in the UK to stand together against MSHT, by putting MSHT firmly on their Board or Senior Management agenda.

    • Business leaders should set the tone across the organisation by signalling that MSHT is an important risk to be integrated into all decision making.

    • Board members should be fully cognisant of the commitments they have made towards the UK Modern Slavery Act 2015 and understand the contents of the statements they sign off to comply with this.

    • Wherever possible, MSHT elements should be incorporated into existing risk assessments and due diligence processes across the business. At every significant decision point or gateway, MSHT issues should be considered alongside other business critical factors.

    • Leaders should encourage a culture of transparency with regards to the identification of cases of MSHT within the organisation, its supply chain and business relationships. Publicly identifying such risks demonstrates that monitoring systems are effective and encourages greater awareness of and engagement with the issue.

Monitor & Report:

  • We are committed to monitoring our own exposure to modern slavery and human trafficking risk on a regular basis through the actions described above. We believe in transparency and will report on our progress in this annual statement and in our annual Impact Report. We also communicate with our stakeholders by sharing regular updates on our business activities, and publishing thought leadership pieces on the topic of modern slavery, in the form of white papers, blogs, news articles, live webinars and recorded podcasts (all of which can be found here).

  • Within our business operations, we have a range of policies and procedures in place to ensure that our staff are protected against any potential abuses. This year we have committed to rolling out our company whistle blower policy, internal complaints procedure, and stakeholder engagement plan. Our procurement policy outlines the steps we take to conduct supply chain due diligence, including mandating our suppliers to provide information about their MSHT approach, framework and controls via the Themis Risk Assessment tool.

  • In addition to the processes we have in place to manage our own business, we work in a range of ways to support others identify and manage potential risks associated with modern slavery.

    • In particular, companies should map and monitor the direct risks of modern slavery in their day to day activities by performing a risk assessment of staff, suppliers, and business partners.

    • Procurement departments should review recruitment processes of manpower suppliers and ensure the same is carried out across the supply lines of partner organisations.

    • Companies should prioritise areas of geographical and sector risk across their supply chains for particular monitoring.

    • Companies should report publicly any cases or suspected cases of MSHT identified in the supply chain, and their intended remedy.

  • Detect & Disrupt:

    • As a financial crime tech firm, our goal is to reduce the global impacts of financial crime by helping firms identify, monitor and manage the specific risks they are exposed to. We are not ourselves a financial institution and so do not process or manage client money. However we do have client fees coming through our accounts and so conduct customer due diligence on our clients using a risk based approach.

    • Through our client work and public engagement we provide support and tools for financial institutions to integrate modern slavery into their financial crime management frameworks.

  • Invest & Engage:

    • We conduct enhanced due diligence checks on all those seeking to invest in our business. We utilise sources including sanctions data, global PEP lists as well as specific adverse media queries to ensure firms and individuals investing in Themis have no identifiable links to financial crime.

    • We encourage investment companies to incorporate MSHT elements into any enterprise wide Human Rights Due Diligence framework, to ensure a joined-up approach across all functions and levels of the organisation.

Our High Risk Areas

As a financial crime tech business with a limited supply chain, we believe our risk to directly or indirectly enabling modern slavery to be low. Our core business involves rapid assembly of large and complex data sets and where this is outsourced to others, these providers may potentially not comply with the appropriate standards. To manage this risk, we ask all of our suppliers to complete the Themis Rating so we can assess their anti-financial crime controls, including those relating to MSHT. Where we find supplier procedures to be lacking, we offer advice on how to implement change.

We also have a wholly owned subsidiary in the UAE. We commit to undertaking due diligence to ensure that any migrant workers we might employ through our UAE business have been recruited fairly.

Our MS Performance Indicators

We are committed to supporting the achievement of the United Nations Sustainable Development Goals (SDGs), a number of which relate to combating modern slavery. We have set out the following commitments in the company balanced scorecard.

  • The principles of UN SDG 16 “ Promoting justice and the rule of law” underpin all the work we do at Themis. Our goal is to reduce the global impacts of financial crime, including modern slavery.

  • We have a commitment to contribute to the eradication of exploitation of individuals and natural resources through the establishment of the Themis Charitable Trust, which will support victims of exploitation and abuse (in line with SDG 8, target 8.7)

  • Through public private partnerships we aim to promote awareness and understanding of modern slavery (in line with SDG 17)

Training & Awareness

Addressing modern slavery is a core area of work and as such our entire team is fully aware of the risks associated with this crime. Over the past year we have conducted a series of events aimed at raising awareness of understanding of modern slavery among our partners, clients and the wider general public. We are also developing a digital learning course that will be freely available to all financial services professionals in the UK. We have also written numerous articles and blogs published ourselves and by others. We are constantly considering new and innovative ways to shed light on this issue and enhance understanding across our industry.

Signed by Dickon Johnstone, CEO on 1st July 2022

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