incuto - Modern Slavery Statement

incuto Limited (“incuto”) is a UK based technology company providing financial services solutions to financial service companies also based in the UK. The incuto team are directly employed by incuto Limited and benefit from incuto Limited policy and procedures on working policies and conditions.

Operating within the UK to incuto business principles which prohibit any form of forced labour and using incuto to source products in compliance with the incuto’s Supply Chain Sustainability Policy, forced labour risks within incuto and how it conducts business or in its supply chain is minimal. Any significant forced labour risk will lie in the incuto supply chain where they are managed by the procurement policy and associated due diligence operated by incuto Ltd. This policy holds suppliers to labour standards which prohibit any form of forced labour and ensures compliance by a risk based due diligence approach based on the location of the supplier activity and its location. incuto reserves the right not to do business with any supplier if we find any violation of the policy.

Our ethical code

incuto adheres to a common set of Business Principles, these guidelines govern our day-to-day activities and apply to all employees and suppliers. They detail our general principles of honesty, trust, and respect for the law, integrity, and human rights.

On issues of human rights, we are clear that:

  • We respect the principles of the UN Universal Declaration of Human Rights, as well as the declarations of the International Labour Organization.
  • We promote equal opportunities and we treat all individuals fairly and impartially, without discriminating with regard to race, colour, nationality, ethnicity, religion, gender, sexual orientation, civil status, age, disability, or family responsibilities.
  • We do not tolerate, either directly or indirectly, any type of child labour, forced labour, threats, coercion, abuse, violence or intimidation in our work environment.
  • We respect our people ́s right to belong to the trade union of their choice and we do not tolerate any type of retaliation or hostile action towards those people who participate in union activities.

Training

All employees including the incuto team must complete a mandatory training course on our Business Principles. This training reflects the importance we place on respecting our ethical code.

Confidential facility

If anyone has any concerns about compliance with our Business Principles - or just wants to ask questions, get advice, or raise issues – there is a confidential help facility available to all employees.

Supply chain management

incuto is in a strong position to influence and impose our high ethical standards on our supply chain and incuto benefits from both the supply chain management and due diligence undertaken by incuto.

Due diligence

incuto’s due diligence approach include desk reviews of policy and process.

Due diligence may be carried out both before we sign contracts with suppliers and during a contract’s term.

incuto stands ready to address problems identified by due diligence by refusal to sign an agreement (in the pre-contract stage), the imposition of an improvement plan, or in a serious case the termination of an agreement.

In 2017, there were no identified instances of slavery or trafficking within our supply chain.

incuto welcomes the transparency brought by the Modern Slavery Act 2015 and the pressure it will bring to reduce modern slavery risks across UK business and their supply chains and will closely monitor the issue and report on our activities in subsequent statements.

Andrew Rabbitt Chief Executive Officer Signature

Andrew Rabbitt, Chief Executive Officer - incuto Limited