Modern Slavery Policy

Policy Last Updated: 23rd November 2023

This document outlines our Modern Slavery policy, subject to annual review. If you have any questions, please contact us.

Introduction

This policy applies to Velasco Limited, with its Registered Office at 301 The Tea Factory, Office 319, St Peter’s Square, Fleet Street, Liverpool L1 4DQ (referred to as ‘the Firm’), authorised and regulated by the Financial Conduct Authority (Firm Reference Number: 839005). Our regulatory information can be found here.

The information herein pertains to the financial year 2023/24.

Organisational Structure

The Firm is governed by a board of directors, and its operational labour is conducted in the North West of England.

Definitions

For the Firm, modern slavery includes human trafficking, forced labour under threat and duress, employer control through abuse, dehumanisation, and physical restraint.

Commitment

The Firm recognises its responsibility to combat modern slavery, committing to compliance with the Modern Slavery Act 2015. This involves continuous internal and supply chain practice reviews.

The Firm refrains from associating with organisations, both domestically and internationally, that support or engage in slavery, servitude, or forced labour. The Firm ensures its labour adheres to UK employment legislation.

Supply Chains

Primary supply chains involve legal services provision. The Firm’s offices in Liverpool and remote work facilitation contribute to its professional services.

Potential Exposure

The primary risk of slavery and human trafficking lies in lower-paid positions within the office infrastructure. Although exposure is limited, the Firm takes stringent measures to prevent such practices in its operations and those of its suppliers.

Impact of COVID-19

The COVID-19 pandemic did not elevate the risk of modern slavery. The Firm, maintaining consistent suppliers, swiftly implemented remote work, ensuring employees’ access to the grievance procedure and full pay during isolation.

Steps

The Firm conducts due diligence to prevent slavery in its operations and supply chains. Future steps may involve supplier contract reviews, risk assessments, impact evaluations, action plans, and staff training on modern slavery.

Key Performance Indicators

The Firm sets Key Performance Indicators (KPIs) to measure its effectiveness in preventing modern slavery, with regular reviews to assess sufficiency.

Policies

The Recruitment Policy supplements the Firm’s position on modern slavery.

Slavery Compliance Officer

Terence Ware serves as the Slavery Compliance Officer, addressing concerns related to modern slavery and ensuring compliance with the Firm’s obligations.

This statement aligns with Section 54(1) of the Modern Slavery Act 2015 and is subject to annual review.