Statement on Slavery and Human Trafficking

Modern Slavery: where we stand 2016


This statement sets out Personal Touch Financial Services Ltd (PTFS) commitment to preventing acts of modern slavery and human trafficking from within its own business or supply chain. This statement relates to activities during the financial year 1 January to 31 December 2016 and future actions we propose to take.

Organisational structure and supply chains

PTFS is a UK based financial services organisation which is regulated by the Financial Conduct Authority (FCA). PTFS provides financial advice firms with support services for their individual businesses. These services include:

  • Compliance, Risk and Regulation support to ensure delivery of quality advice to end consumers
  • Operational support to ensure consumers receive high-quality products that are tailored to their needs
  • Technology support to streamline the customer journey and deliver great customer experiences
  • Business and adviser development support to ensure financial advice firms remain informed and can support consumers’ holistic requirements

We work with a range of suppliers and have identified a supplier as someone who is paid for goods or services (GAAP UK). We mainly work with; directly authorised financial advice firms, appointed representative financial advice firms and outsourced services for a range of activities, including payroll. Prior to any new third party suppliers engaging in business activities with PTFS, a robust due diligence check is carried out.

Relevant policies

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free we have reviewed our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues.

Our workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls. These policies include: Whistleblowing policy and our employee handbook. 

Relevant processes and support available to employees

  • Recruitment / Agency workers policy: PTFS uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. The organisation also has a robust vetting process which establishes potential candidate’s eligibility to work in the UK, along with at least five years employment history.
  • Employee Assistant Program: PTFS offers a free and confidential advisory service which is known as EAP. Employees may use this service to seek advice and guidance on many types of concerns including taking advice regarding legal matters. This is an alternative mechanism employees can use to discuss any concerns they may have regarding modern slavery or human trafficking,
  • Employee Representatives: The employee representatives make employees’ views known to management. They help to strengthen understanding of workplace issues and other business matters, for both management and employees. This helps to create an atmosphere of mutual trust between employees and management and is a further mechanism any employee of PTFS can use to report any potential concerns they have with modern slavery and human trafficking.

Future Steps – 2017

Awareness-raising programme

We are proposing to offer training on modern slavery and human trafficking via our online learning management system (LMS).

The online LMS training covers:

  • how to assess the risk of slavery and human trafficking in relation to various aspects including resources and support available;
  • how to identify the signs of slavery and human trafficking;
  • what initial steps should be taken if slavery or human trafficking is suspected;
  • how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
  • what external help is available, for example through the Modern Slavery Helpline,

The organisation will continue to raise awareness of modern slavery issues by putting up poster infographics across the organisation’s premises. The posters explain to staff:

  • the basic principles of the Modern Slavery Act 2015;
  • how employers can identify and prevent slavery and human trafficking;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation;
  • What external help is available, for example through the Modern Slavery Helpline?


We will review our current employee handbook and add specific content regarding our modern slavery and human trafficking statement and anti-slavery initiatives.

Closing Statement

PTFS are committed to ensuring we conduct our business in an ethical manner and that there is no modern slavery or human trafficking in any part of our business or supply chain.

Executive approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending December 2016.

This has been approved by the organisation’s board of directors, who will review and update it annually.

Correct as of 26/06/2017