This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (UK) for the financial year ended 31 December 2023 in respect of Apex Group Limited and its subsidiaries (“Apex”).
Apex is committed to combating the risk of modern slavery or human trafficking within its business and supply chains. The Apex Corporate Social Responsibility Charter establishes our belief in respecting human rights, and this is reinforced by the Apex Group Business Values which centres on caring and the promotion of respect in our activities.
1. Our business
Apex Group Limited is a private limited company incorporated in Bermuda and is the holding company for the Apex group of companies, which has subsidiaries across 50 countries in the Americas, Europe, the Middle East, Africa and Asia Pacific. We offer a single source solution to enable us to deliver an extensive range of services across the value chain. We offer a wide range of services including fund services, digital onboarding and bank accounts, depositary, custody, super ManCo services, business services including HR and payroll and ESG ratings and advisory services.
We are proud to be one of the largest providers of financial services but this isn’t the only measure of our success; we strive to be a responsible corporate citizen, focused on making a difference to our people, our planet and our society.
Our ability to do good begins with our people, our greatest asset, and through them we know we will make a real difference to the world around us. As we grow as a business, so too does our drive to have an influence; to make the world a better place, to preserve our planet for future generations and to positively impact our people.
2. Our supply chain and due diligence
As a financial services company we have a limited supply chain and operate in an industry with a low risk of modern slavery. Nevertheless, Apex recognizes that the risk of slavery or human trafficking may exist in any supply chain. Therefore, Apex has committed to take adequate actions and put in place mitigants to reduce such risk.
As part of new supplier due diligence, Apex requests a copy of the supplier’s anti-slavery and human trafficking statement and/or policy, which is expected to extend to the supplier’s sub- contractors. Potential Apex suppliers are also asked to confirm that they:
- Have not committed or been notified that they have been placed under investigation for any offences relating to human trafficking and/or slavery;
- Are not aware of any circumstances within their supply chain that could give rise to an investigation or a prosecution; and
- Will comply with the Modern Slavery Act 2015 and other global legal standards relating to human trafficking and/or slavery.
3. Our effectiveness in combatting slavery and human trafficking
Apex supports the fundamental principles of human rights, such as those adopted in the United Nations’ Universal Declaration of Human Rights. We believe that upholding these principles is an important component of our culture and values. Our commitment to fair, ethical, and responsible business practices is central to our way ahead.
We have a number of internal policies that reflect our zero-tolerance approach to modern slavery, our commitment to ethical business behaviour and slavery free supply chains. Our whistleblowing policy allows employees to highlight issues they come across, which could include matters such as supplier ethics and behaviours.
4. Training and vendor management
Individuals who are procuring services on behalf of Apex must undertake training in relation to modern slavery.
As part of our vendor due diligence process potential vendors have to confirm that they comply with the Modern Slavery Act 2015 and other legal standards relating to human trafficking and/or slavery, and make certain other confirmations about their supply chain and any previous investigations or offences committed relating to human trafficking and/or slavery.
5. Plans for the next financial year
Apex remains committed to combatting the risks of modern slavery and human trafficking in our supply chain.
- We intend to use 18 October (Anti-Slavery Day) to create awareness of the issue of modern slavery, and raise awareness to all Apex employees;
- We intend to review and update our modern slavery statement and policy; and
- We will review the modern slavery training on our new training platform.
6. Approval
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Apex Group Limited’s slavery and human trafficking statement for the financial year ended 31 December 2023.
Approved by the board of directors on 17 October 2024 and signed on behalf of Apex Group Limited by Peter Hughes, CEO.
