Anti-Slavery and Human Trafficking Statement
For the Financial Year Ending 31st December 2018
This statement sets out the steps that Sharps Pixley have taken to prevent slavery and human trafficking in its supply chains and in other parts of its business.
We are a leading UK Bullion Dealer. Our business in the UK forms part of the Degussa family.
Sharps Pixley London office is the hub for many global and European clients.
OUR POLICIES AND ETHOS
Sharps Pixley does not permit, condone or otherwise accept any form of slavery and/or human trafficking (as defined in the Modern Slavery Act 2015) by its employees, subcontractors, contractors, agents, partners or any other organization, entity, body, business or individual with whom we engage or do business.
As a signatory of the U.N. Global Compact, we support internationally accepted principles regarding human rights, labour standards, the environment and anti-corruption, including the United Nations Declaration and core ILO conventions.
We encourage all our employees, customers and other business partners to report to the Sharps Pixley management, legal or compliance teams any concerns they may have regarding our direct activities or our supply chains. This includes any circumstances that may give rise to increased risk of slavery or human trafficking.
If Sharps Pixley suspects any slavery and human trafficking by an associated party, we reserve the right to report such suspicions, provide appropriate information to the relevant authorities and to suspend or terminate any associated engagement, business arrangement or contract.
OUR SUPPLY CHAIN
Sharps Pixley source from a number of suppliers across the world with the majority of this spend concentrated in the UK. We also use smaller suppliers in our client work, who provide photography, production work, market research operations and other marketing support services.
We work with a network of affiliates and partners across the European region to serve clients where we do not have a physical presence. We conduct due diligence when considering new firms for addition to our affiliate network and are closely engaged with the clients they serve on our behalf so that we would be made aware of any concerns regarding the affiliates’ work.
RISKS IN OUR SUPPLY CHAIN AND STEPS TAKEN TO ASSESS AND MANAGE THE RISK
While Sharps Pixley, as a professional services firm, may have a low risk of slavery or human trafficking within our business activities, we have established a broad policy approach to reflect our commitment to principles-based behaviour and delivering on societal and operational responsibilities.
Sharps Pixley specifically requires suppliers to comply with the Modern Slavery Act 2015 in contracts where appropriate. In our standard terms with suppliers, we require suppliers to confirm they have not committed an offence under anti-slavery laws, are not under investigation for such an offence, are not aware of circumstances in their supply chain that could give rise to an anti-slavery offence and have effective controls in place to ensure compliance with anti-slavery laws.
OUR EFFECTIVENESS IN ENSURING THAT SLAVERY AND HUMAN TRAFFICKING IS NOT TAKING PLACE
We know that maintaining high standards of conduct is not achieved solely by good intentions. It is achieved by clarity in articulating our mission and values to both our employees and stakeholders. Our abide by the following core commitments:
– We are committed to honesty, transparency, and fair dealing;
– We ensure business activity aligns with the interests of all stakeholders: clients, employees, and parties with whom we interact; and
– We strive to model best practice in all areas of our business. We do not violate legal obligations.
As we believe there is not a significant risk of slavery or human trafficking in our business, we do not have any key performance indicators specific to this area. However, we monitor and review business practices which mitigate slavery or human trafficking risk including a continuous programme of training for our employees.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Sharps Pixley’s anti-slavery and human trafficking statement for the financial year ending 31 December 2018.
The CEO of Sharps Pixley has considered and approved this statement on 6th December 2018.