Anti-Slavery and Human Trafficking Statement 2016

Alfa Financial Software Limited (“the Company”), a wholly owned subsidiary of Alfa Financial Software Holdings PLC (“Alfa”), is committed to continually improving its practices to combat slavery and human trafficking.  Alfa and the Company has zero tolerance of modern slavery in all its different forms both in its business and in its supply chain.

This is the Company’s first Modern Slavery Statement in response to the Modern Slavery Act 2015 (the ‘Act’) and this statement sets out the steps taken or to be taken by Alfa and the Company to prevent modern slavery and human trafficking in its business and supply chains.

Introduction

The term modern slavery is broad and considers someone to be in modern slavery if they are in forced labour, servitude, slavery, human trafficking, debt bondage, forced or servile marriage, descent based slavery and child exploitation. It is a global and growing issue. No sector or industry is exempt from the potential for modern slavery. Alfa has zero tolerance of modern slavery in all its forms and has a responsibility to understand the risks in its business and supply chain and manage those risks accordingly.

This is Alfa’s first modern slavery statement following the introduction of the Modern Slavery Act 2015 and is made pursuant to section 54(6) of the Act and constitutes the Company’s anti-slavery and human trafficking statement for the financial year ending on 31 December 2016. Alfa aims to be transparent about its approach to modern slavery and this statement outlines its approach to tackling modern slavery where it can.

Our business and organisational structure  

Alfa is a leading developer of mission critical software for the asset finance industry, operating across more than 12 countries and with more than 250 employees as at 31 December 2016. Alfa’s global annual turnover was £73.3 million in the year ended 31 December 2016.  The Company is a fully owned subsidiary of Alfa, which is listed on the premium segment of the London Stock Exchange and is the only company in the Alfa group which has revenues in excess of £36 million for the year ended 31 December 2016.

Modern slavery and human trafficking policies and framework

As a software company, Alfa does not have an extensive range of local or international suppliers where modern slavery or human trafficking would generally be a material risk and none of our suppliers are key to the business’ success. However, Alfa is committed to acting ethically and with integrity in all of its business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking does not take place anywhere in the business or supply chains.  The Alfa policy to this effect is included in the Code of Conduct, Ethics, Anti-corruption and Bribery policy.  Alfa is currently in the process of reviewing the anti-slavery systems and controls to:

• Identify, assess and monitor potential risk areas in the supply chains; and
• Mitigate the risk of slavery and human trafficking occurring in the supply chains.

We are also now reviewing how we engage with our network of suppliers to ensure that they will comply with the requirements of the Act. Alfa’s Whistleblowing Policy also encourages its employees to speak up and report any wrongdoing. This review may lead to revisions to already existing policies setting out Alfa’s approach to being inclusive and diverse, employee well-being; and, employee consultation and engagement.  Alfa is also working to update the procurement process and policy to describe the approach it takes to managing modern slavery in its supply chain and to set out its expectations of its supply chain partners.  Alfa is focusing on reviewing the supply chains for the UK business primarily, as this falls within the definition of the Act, although Alfa also has operations in the US, Europe, Australia and New Zealand.  Alfa does not believe that it currently operates in jurisdictions where the risk of modern slavery and human trafficking is specifically high. Following this review and in the second modern slavery statement, Alfa will endeavour to extend the review throughout the global operations.

Our Anti-slavery Policy, which is included in our Code of Conduct, Ethics, Anti-corruption and Bribery policy, reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due diligence processes for slavery and human trafficking  

As part of our initiative to identify and mitigate risk Alfa has increased its focus on modern slavery within its wider business operations, and will continue to do so during 2017.

We have in place systems to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers.

During 2017 we will undertake a risk assessment of the top supplier expenditures which will involve a review of the industries and products / services that Alfa buys from.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in the supply chains and to the business, Alfa will be providing updates on this to the relevant personnel within procurement.

Alfa’s effectiveness in combating slavery and human trafficking  

Alfa understands that it has a responsibility to continue to assess and mitigate the risk of modern slavery in the long term. While Alfa continues to make progress in this area, future developments will be to understand the nature of that risk, establish policies and begin to implement controls to manage any risk that arises. It is expected that the nature of the risk may change over time and ongoing vigilance will be required.

To understand the effectiveness of these efforts to ensure modern slavery does not exist within any of the Alfa business activities, in 2017/2018

Alfa aims to:

• Investigate modern slavery risks as identified and put in place corrective actions in response to these risks in its business or supply chain as appropriate;
• Extend the modern slavery training to all Procurement professionals; and
• Monitor government and other large companies’ perspectives on and approaches to modern slavery and actively consider their applicability to Alfa.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement for the financial year ending 31 December 2016.