Our Slavery & Human Trafficking Statement

                                                                                           
Our Business
The Retirement Bridge Group consists of Retirement Bridge Investments Ltd and several subsidiary firms who own and administer various portfolios of equity release home reversion plans. A full list of our group companies that this statement applies to can be found on our website www.retbridge.co.uk under the ‘About Us’ tab. By references to “Retirement Bridge”, “we”, “us” and “our” we mean all the firms that form the Retirement Bridge group of companies. 

Overview 
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. As an ethical organisation, we have no appetite to accept non-compliance with our legal and regulatory obligations. We have no wish to trade with, support or work with any business which is involved in slavery or human trafficking in any way, however remotely or indirectly. 

We have a zero-tolerance approach to modern slavery of any kind within our operations and are committed to taking all reasonable steps to ensure that there is no modern slavery or human trafficking in our business or supply chains. 

Operating in the equity release sector, and in the United Kingdom only, we do not consider ourselves in an industry with a high risk of modern-day slavery. However, we take our obligations seriously as the following sets out.

Supply Chain Risk
We source goods and services from a relatively small number of suppliers predominantly UK based including: 
  • I.T. including telephony & equipment;
  • Office accomodation & supplies;
  • Legal services;
  • Property services;
  • External funding partners.
We monitor the on-going performance of our key suppliers. In the event of our selecting new suppliers or when engaging with other firms. For example, for business development or similar projects, we will have regard for their:
  • Reputation and history;
  • Knowledge and experience; 
  • Quality of services provided to us where for example we are renewing existing or entering new or additional arrangements;
  •  Quality of services provided to other customers we are aware of;
  • Legal and regulatory standards, such as any history of prosecution, enforcement action or similar;
  • Financial stability and commercial record.

People Risk
In terms of recruitment, we verify the identification and address history of all new candidates for employment. As part of this, we undertake background screening and a ‘standard’ Disclosure Barring Service (DBS) check. This screening activity can be repeated at intervals. We do not place particular reliance on the use of temporary agency staff. Where such staff are engaged, confirmation from the agency they have undertaken appropriate background checks on the candidate is sought. 

Product Risk
The plans we have provided and manage are only available through UK financial advisers who must be authorised and regulated by the UK financial services watchdog, the Financial Conduct Authority (FCA). The product involves an older age group whose main residence must be in the UK. Customers were supported by independent solicitors when first entering the plan.

We carry out periodic ‘Certificate of Occupancy’ checks in which customers are required to confirm their continuing residence and declare any additional occupiers.  Property Inspections are also undertaken at either 2 or 3 yearly intervals which make use of photographic evidence of the property internally and externally. These mechanisms help us verify that customers are abiding by the plan terms and conditions including that properties are being used appropriately and lawfully.

When a plan ends and we are making arrangements to sell the property, UK based independent estate agents and solicitors are engaged to support us, including in the verification of buyers. 

Our Policies
We have policies in place designed to promote the ethical standards we expect of our staff and provide them with a platform to raise to raise concerns. These include, but are not limited to, our Conflicts of Interest Policy and our Whistleblowing Policy. In addition, our Preventing Financial Crime Policy covers matters including Modern Slavery & Human Trafficking. These policies, which are reviewed at intervals, are made available to relevant staff who are required to confirm they have read and understood them.

Awareness
We provide our staff with training relevant to them. During 2020, to help raise awareness of the subject, our staff completed a specific training module about Modern Slavery. In 2021 we signed up to the Government’s Modern Slavery Statement register where this Statement is now published. 

The business reviews its risks at regular intervals. The result of our most recent assessment did not identify any concerns here. 

Responsibilities
Our board of directors has overall responsibility for the approval of key policies relating to financial crime prevention and this Slavery & Human Trafficking Statement.

Conclusions
Taking all the above in to account we consider the business operates in a very low risk environment and continues to meet the requirements of the Modern Slavery Act 2015. Furthermore, through our processes and procedures, we have not identified any reason to believe that slavery or human trafficking affects any part of our business either directly or via those suppliers we are engaged with. 

This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015 and constitutes our Modern Slavery & Human Trafficking Statement for the financial year ending 30th September 2021. It has been reviewed and approved by our board 21st October 2021. 


Paul Barber
Chief Executive
Date: 11/10/2021