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Anti-Slavery & Human Trafficking Statement 2017

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1. Introduction

This statement sets out the ongoing commitment of Peel Hunt (“we”, “our”), which encompasses all entities within the Peel Hunt group, including Peel Hunt LLP and Peel Hunt Inc., to ensure that

-  modern slavery and human trafficking is eradicated; and
-  Peel Hunt is transparent and diligent relating to the people and entities it does business with.

Being a partnership goes beyond our structure to the way we do business. It’s a principle that defines the relationship between departments and, above all, with our clients. Conducting our business with integrity, openness and professionalism, part of which encompasses our commitment to ensuring Peel Hunt and its supply chains are free from modern slavery and human trafficking, is not only in the best interests of our clients but of all our stakeholders. This leads to long-term successful client relationships. With no pressure to chase short-term revenues, we are focused on building our business for the long term. Consequently, we provide impartial advice without the need for compromise.

As an independent corporate broking, advisory and trading house focusing on mid & small-cap companies, we offer corporate broking, advisory, research, sales and trading services to clients. Our trading services encompass market making in all UK listed instruments, both equity and fixed income; domestic and international trade facilitation; and market access technology. We strive to offer the best execution service.

In conducting the activities above, Peel Hunt engages a number of suppliers and employs over 200 staff in both London (located at Moor House, 120 London Wall, London EC2Y 5ET) and New York (located at 295 Madison Avenue, Suite 904, New York; NY 10017-7757). It is these members, employees, suppliers and the associated “supply chain” that we are focusing on in our efforts to remain free from modern slavery and human trafficking.

Steven Fine
Chief Executive
September 2017

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our anti-slavery and human trafficking statement for the financial year ending 31 March 2017.

2. Our supply chains

Peel Hunt’s supply chains include, but are not limited to:
-  Suppliers of IT hardware and software;
-  Payroll;
-  Building space and facilities;
-  Legal, accountancy and other professional intermediaries;
-  Suppliers of financial market data and news services;
-  Suppliers of transaction related services and infrastructure; and
-  Other office supplies.

3. Our policies on slavery and human trafficking

Peel Hunt has a zero tolerance approach to slavery and human trafficking, and as such we are committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business.

This statement and our internal policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery or human trafficking is not taking place anywhere in our supply chains.

We also have in place robust compliance policies (including those covering ethical behaviour, conduct and whistleblowing) designed to promote ethical and compliant behaviours as well as encourage and to protect anyone who wishes to raise concerns about wrongdoing within our business.

4. Due diligence processes for slavery and human trafficking

Peel Hunt’s recruitment processes are transparent and reviewed regularly. We communicate directly with candidates to discuss job opportunities and to confirm the details of any offer made. We have robust procedures in place for the vetting of new members or employees and ensure that we are able to confirm their identities and that they are paid directly into an appropriate, personal bank account.

Peel Hunt has implemented processes to ensure, as far as is reasonably practicable, that our supply chains adhere to our expectations in respect of their workforce. If we discover that any of our staff have been complicit in slavery or human trafficking, we will take appropriate disciplinary action. We review our existing suppliers on a regular basis and are committed to work only with organisations who share our values to assist in the eradication of slavery and human trafficking.

As part of our review and reassessment process, Peel Hunt will now review the controls undertaken by our suppliers and are in the process of requiring, from all our suppliers, an annual statement of their commitment and actions taken to eliminate modern slavery and human trafficking.

Peel Hunt performs in depth analysis into country risks on an annual basis and we are conscious that imported products or services sourced from outside the UK or European Union (or any country that we consider as high risk) are potentially more at risk of slavery or human trafficking. If products or services have to be sourced from such locations, we will look to perform enhanced due diligence of these suppliers and look to gain extra comfort where they can demonstrate a commitment to human rights and fair working conditions, for example by way of certifications such as Social Accountability certification SA8000.

Peel Hunt will not work with any organisation that has been found to have been knowingly involved in either human trafficking or modern slavery.

5. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, Peel Hunt provides training to our staff as part of their induction and provide refresher training as appropriate.

Peel Hunt requires our suppliers to adhere to the same and to provide training to their staff and suppliers and providers to equivalent standards.

6. Our effectiveness in combating slavery and human trafficking

Peel Hunt’s senior management shall take the responsibility for implementing the systems and controls outlined in this statement and shall provide adequate resources and investment to ensure that slavery and human trafficking is not taking place within the organisation or within its supply chains.

Peel Hunt will continue to monitor and review our policy relating to slavery and human trafficking. If we become aware of any breaches of the policy, we will investigate and take such steps as are necessary to ensure that the risk of further breaches occurring is minimised.

Following a review of the effectiveness of the steps taken in 2016/2017 to ensure that there is no slavery or human trafficking in our supply chains, Peel Hunt intends to review all of our supplier contracts and seek to include clauses relating to slavery and human trafficking in their contracts.