All Financial Services firms (large and small) and all their team members, partners and supply chains have an extremely important role to play in the prevention and elimination of modern slavery and human trafficking.
At Green Swan we are not only happy to play our part in this global challenge - we are proud to do so.
Although Green Swan does not fall within the scope of the Modern Slavery Act obligation criteria. However, the board confirmed that we will continue to make an annual statement and take relevant action in line with the requirements of the legislation.
Green Swan has zero-tolerance toward slavery and human trafficking and does not accept modern slavery in any form. In our operations and supply chain, we work with partners and suppliers to ensure compliance with the UK Modern Slavery Act 2015 (“the Act”).
Green Swan was founded to be the UK leading specilist in dormant funds management, charitable donations & and compliance remediation for FCA regulated businesses.
Green Swan does not provide services to or invest in organisations that use power to systemically promote public behavior that is harmful to individuals, groups or society as a whole. Green swan acknowledges that these are real, yet hidden, issues in our society and, in a time of compounding crises, are likely to rise over the coming years.
Green Swan is committed to protecting human rights, preventing modern slavery and human trafficking by continuously improving its systems, controls and improving our employees’ understanding of these important issues. Green Swan works with charities, government agencies, regulators, and law enforcement to help identify and tackle modern slavery and human trafficking in the communities and environment it operates in.
This is Green Swan's first Statement on Modern Slavery and Human Trafficking, published in accordance with the Modern Slavery Act 2015. This statement refers to the financial year ended 31 March 2023 and details the approach taken to identify and prevent modern slavery and human trafficking across our business operations and supply chain.
1.0 Who We Are
For the year ending 31 December 2024 (the year), Green Swan & Green Swan Financial has been preparing its services and submission to the FCA for an EMI license.
Green Swan's head office is in London, with a business continuity office in Lymington. Our purpose is underpinned by our values www.greenswancompliance.com
All Board members have a detailed understanding of the market and regulatory frameworks in which Green Swan operates and are screened for conflicts of interest and relationships with companies that do not meet its values and ethics. The Board undertakes an annual review of conflicts of interest authorisations.
2.0 Our Supply Chains
Green Swan is committed to developing business relationships with high quality suppliers and partners who themselves are committed to operating under ethical standards and values equivalent to the Bank’s own, including in the fair treatment of customers, employees and other stakeholders. Green Swan predominantly utilises services from third-parties located in the United Kingdom, United States and Europe.
To tackle trafficking and slavery in the supply chain Green Swan:
-Exercises skill, care and diligence when considering new material outsource providers and material vendors. This includes examining suppliers’ policies and frameworks to ensure they are aligned with Green Swan’s ethical standards and values.
Incorporates anti-slavery obligations into agreements - including specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children - with suppliers where relevant and on a risk-assessed basis.
-Adopts a risk-based approach in identifying, monitoring and assessing suppliers who are at a greater risk from instances of modern slavery / or human trafficking, and take appropriate mitigating actions.
- Performs due diligence and relationship oversight in line with its Supplier & Outsourcing Policy and Third Party Management Procedure, ensuring vendors meet the Bank’s expectations on an ongoing basis.
- Periodically share its supply chain guidelines and policies with partners.
The Board of Directors (supported by the Audit and the Risk Committees) sets the control environment throughout the firm, including the appetite and tolerance levels in respect of outsourcing and third party risk management.
3.0 People
Green Swan is committed to providing a workplace culture that reflects its values of fairness, equity, inclusion, compassion and non-discrimination. Green Swan is also committed to conducting business with honesty and integrity in an open and transparent manner where all employees feel like they are able to report their concerns.
Green Swan Whistleblowing Policy details a robust process that is in place to enable concerns of wrongdoing to be escalated in a confidential manner so that the necessary investigation, remediation actions and reportings and/or notifications can take place. Green Swan has partnered with an independent whistleblowing charity helpline and developed a solution that allows employees to anonymously raise any whistleblowing concerns.
Green Swan operates regular, anonymised employee engagement surveys on matters such as reward and diversity and inclusion to ensure employees have a voice. Key themes arising from the results of these surveys are discussed with the Board.
All employees undergo compulsory pre-employment background checks before joining Green Swan to ensure they are suitable for the role they have applied for. These checks, some of which are carried out by a specialist independent screening provider, include identity checks, financial crime checks, reference checks, right to work checks, criminal record checks and, if applicable, education and professional qualification checks. Employees are also subject to annual checks, and if applicable, visa checks to ensure they remain suitable for their role. All new hires undertake mandatory training on modern slavery and human trafficking, economic crime, conduct risk and anti-money laundering. Specialist teams, such as the risk and compliance team and customer service team, undertake additional training including on customer due diligence, complying with sanctions and fighting fraud.
Green Swan is an equal opportunities employer and ensures fair and full consideration of applications for employment from all people regardless of their age, gender, ethnicity, race or disability. Green Swan is committed to ensuring that its employees are paid fairly and Green Swan aims to attract and retain the best people from a diverse gender, social and ethnic background.
4.0 Customers and Partners
Green Swan carries out due diligence on all of its customers; personal, business and sole traders. Controls are built into its app to ensure the customer being onboarded fits within the Bank’s risk appetite. Green Swan adopts a proactive approach to identifying suspicious activity, and where necessary takes appropriate measures for customer accounts where such activity is flagged.
5.0 Policies
Green Swan has policies in place to prevent modern slavery and human trafficking.
Modern Slavery PolicyThis documents Green Swan’s approach to identify, assess and manage the risks posed by modern slavery and human trafficking. In addition, it demonstrates Green Swan's commitment to preventing slavery and human trafficking in its business and supply chains and clearly establishes expectations for its employees, agency staff, suppliers.
Supplier and Outsourcing Policy This defines Green Swan's approach to supplier management and outsourcing, to ensure that suppliers and outsourced partners meet Green Swan's expectations and comply with regulatory requirements.
Staff Handbook and Code of Conduct This applies to all employees and fixed-term contractors. The Code represents our commitment to how its employees work and conduct themselves. Green Swan strongly believes in acting in an ethical way and expects everyone it works with to uphold its values and principles in all that Green Swan says and does, as well as upholding all external legal and regulatory requirements and Green Swans' policies and procedures.
Whistleblowing PolicyThis sets out Green Swan's commitment to a culture of openness, transparency and accountability where colleagues feel safe to raise concerns, and to comply with whistleblowing laws and relevant regulatory expectations. The Board Audit Committee monitors the number of incidents raised through Whistleblowing channels on a regular basis.
Green Swan's also has in place multiple financial crime compliance policies, which detail its approach to anti-money laundering, bribery and corruption, market abuse and sanctions. Green Swan’s financial crime function monitors and reports any suspicious activity detected using Suspicious Activity Reports to be notified to the National Crime Agency.
6.0 Looking Ahead
Green Swan is continually looking to improve its Modern Slavery Statement year on year, including reviewing and developing its policies and procedures relating to modern slavery and human trafficking. The Board receives quarterly updates on any matters related to modern slavery and will continue to escalate any issues to the Board where necessary.
Green Swan is also committed to building on its employees’ understanding of modern slavery and human trafficking by providing them with tailored information through its induction and refresher training programmes, including for Directors. Green Swan will also continue to strengthen its relationships with its external suppliers and partners, by continuing to engage with them on matters relating to modern slavery and human trafficking and ensuring their ethics and values meet Green Swan's expectations.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015
The Board
Dec 2023
.