Introduction from the Group Chief Financial Officer
This statement relates to Property Information Exchange Limited, and its subsidiaries, PSG Connect Ltd, PSG Client Services Ltd & PSG Financial Services Ltd (the Group/Our/Us/We) and, specifically, the Group’s requirement to prepare an annual statement concerning anti-modern slavery compliance.
This statement relates to actions and activities of the Group during financial year 1 January 2019 to 31 December 2019.
This statement’s use of the term “modern slavery” has the meaning given in the Modern Slavery Act 2015.
The Group is committed to preventing modern slavery and human trafficking in its corporate activities, and to ensuring that its supply chains and business practices are free from modern slavery and human trafficking.
One element of the Group’s business, under the subsidiary PSG Connect Limited, is carried out through a franchise network. As these franchises operate under the “PSG” brand and Group ethos We require them to follow our supplier due diligence policy and monitor compliance with this.
The Group provides technology solutions to the legal and property sectors and supplies conveyancing searches and due diligence products to support our clients (predominantly law firms) in providing services to their customers. Our IT and finance functions operate from Reading and the operations, franchising and HR base is in Barnsley.
In addition, we have smaller operational bases in 6 satellite offices in Bridgend, Hull, Manchester, Plymouth, Bristol and Newcastle.
Our suppliers and customers are based in the United Kingdom save for some IT support provided to Us from a trusted partner in Mangalore, India (and where we have put in place a contract with model clauses for GDPR and provided training to the service personnel) and email services provided from the United States of America.
Our Supply Chains
We have considered the risks for the Group and taking into account the industry sector and predominantly UK based geographical location of our suppliers. We consider that our supply chain operations have a very low risk of being affected or being involved in modern-day slavery activities.
Our supply chain includes Local Authorities and other data/search providers operating in the sector, office stationary providers, IT companies and contractors, recruitment consultants, building maintenance contractors, cleaning contractors, external storage, kitchen supplies and waste disposal.
We have updated our supplier due diligence checklists to incorporate assessment of modern slavery compliance and have plans to include self-certification and other checks to improve this (see below). Where suppliers are required to make their own modern slavery statements in accordance with the Act, We monitor the content of the statements published. Where possible, We build long standing relationships with local suppliers and customers and make clear our expectations of business behaviour.
Our Business, Workers and Employees
The Group’s ‘company handbook’ contains the Group’s Whistleblowing Policy and provides all workers in the business with guidance on how concerns can be communicated. Concerns about suspected modern slavery can be reported by workers in this way without fear of retribution.
We have now produced an Anti-Modern Slavery Policy, which has been distributed to all staff.
The Executive Management team and all managers are responsible for compliance in their respective departments and for their supplier relationships.
All Directors have been briefed on the subject and managers responsible for, or involved in, supplier relationships have a high-level understanding of the risks of modern slavery and human trafficking in Our supply chain and Our supplier requirements. Our Group Compliance Director ensures that training is current. Our HR Director ensures new starters are made aware of the Anti-Modern Slavery Policy.
As part of Our improvements to supplier due diligence We shall require suppliers to self-certify that they adopt a procedure to undertake due diligence on their own suppliers. We consider that this is sufficient to be limited to “one- up” due diligence on the next link in the chain.
We are now working to ensure all suppliers complete a “Supply Chain Feedback Form” to confirm receipt of the PIE Group Modern Slavery Policy and confirm their Zero Tolerance stance with regards to Modern Slavery. Further they must confirm they will adopt, as a minimum, the principles outlined in the PIE Group Modern Slavery Policy. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Companies slavery and human trafficking statement for the current financial year.
This statement for Financial Year ending 31 December 2019 was approved by the Executive Management Team of Property Information Exchange Limited on 29th January 2020.
Roy Hastings, Director and Chief Financial Officer