Modern Slavery

1. Purpose

This document defines the 2sms policy with regard to termination or change of employment responsibilities.

2. Scope

This document applies to 2sms as defined in the ISMS Scope Document.

3. Background

2sms aims to protect the company’s interests in respect of the requirements of the Modern Slavery Act 2015 (UK)


The Trafficking Victims Protection Act of 2000 (Pub. L. 106-386), as amended (TVPA), and the Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime (the Palermo Protocol). (US)

4. Responsibility

The CEO is responsible for maintaining this policy and the related procedures.

5. Policy

A.7.3.1 Modern Slavery Act.

Introduction Limited and its subsidiary 2sms LLC, (“2sms”) strives to be a distinctive specialist bank and asset manager driven by a commitment to our core philosophies and values. We are committed to the ten principles of the United Nations Global Compact which relate to human rights, labour, environment and anti-corruption and we support the international agenda to abolish human trafficking, slavery, forced and child labour.

Part of this pledge entails compliance with relevant regulation and policy. We are therefore committed to addressing the requirements of the UK Modern Slavery Act 2015 (the “Act”) and ensuring that our supply chain is compliant with the regulations prescribed therein. We acknowledge the undertakings in the Act and endeavour to create a culture of transparency with regards to the supply of goods and services to us.

This statement is made pursuant to section 54 of the Act and constitutes 2sms’s modern slavery and human trafficking statement, as required by the Act.

Organizational Structure

2sms has undertaken an investigation of its corporate structure and business practices and determined that our international subsidiary does carry on business, or part of a business, in the UK. Accordingly, these non-UK subsidiaries are subject to the Act and are therefore included from the ambit of this statement.
2sms Group in its entirety remains committed to the highest standards of integrity and ethical behaviour.

Supply chains and due diligence procedures

We are committed to ensuring that our supply chain is free of any slavery and/or human trafficking. We intend to govern all current and future third party relationships with these slavery issues in mind. We will not knowingly support and/or do business with any suppliers who are involved in slavery.
Due diligence procedures will be required to assess the nature and extent of our exposure to the risk of slavery. In order to fulfil our obligations under the Act, 2sms will:

  1. Request information regarding third party supplier’s working practices and require the relevant supplier to confirm that it is aware of, and complies with, its obligations under the Act.
  2. Communicate to potential new suppliers that we have a zero tolerance policy with regards to slavery.
  3. Provide training to relevant stakeholders on slavery and our obligations under the Act.
  4. Include reference to, and compliance with, these slavery supply chain issues in our supplier engagement process, supplier audit procedures and contractual arrangements with third party suppliers.
    Through the above mentioned processes, we aim to identify any slavery risks and are able to investigate and eradicate such risks.

Training and policies

Training is fundamental to raising awareness of these slavery issues. We have therefore identified relevant online training which is intended to provide an understanding of slavery and our obligations under the Act. Such training will be rolled out to key stakeholders, who will be identified by our Group Legal team.
Furthermore, as part of our commitments under the Act, we have developed an internal policy which is available to all of our employees in the UK and which provides further guidance on how to identify, manage and report such risks.

Approval procedure

This statement, which will be reviewed annually and updated as required, has been reviewed has been approved by our Board of Directors.


We reiterate our ongoing commitment to the Act and its underlying principals.

6. Corrective Actions

Any required corrective actions identified by the 2sms Management team will need to be fed into the process for non-conformity, corrective action and continual improvement.

7. Effectiveness of Policy

It is the role of the CEO to assess the performance and effectiveness of this policy annually.

Scroll to Top