Modern Slavery Act Transparency Statement

Our Slavery and Human Trafficking Statement

This statement sets out what steps we, DST Financial Services International Limited and DST Financial Services Europe Limited ("DST FS"), have taken during the financial year ending 31 December 2017 to ensure that slavery and human trafficking did not occur within any part of our own business or supply chains.

Slavery and human trafficking are abuses of a person’s freedoms and rights. We are totally opposed to such abuses in our direct operations, our indirect operations and in any of our supply chains. Building on our existing policies, we have embraced the requirement to publish an annual slavery and human trafficking statement. This will allow us to share our efforts against slavery and human trafficking and improve and measure our success each financial year.

Our business and supply chains

We are a leading provider of investor and policyholder outsourcing solutions to the European domestic, cross border, liquidity and equity markets. DST FS employs approximately 5,000 people.

We use a vast range of suppliers, ranging from network, software and hardware providers to catering and waste disposal services. Some of these products and services we use in our own business and some we use as part of what we sell to our customers. Approximately 850 suppliers sell to us.

Like most organisations, our suppliers use their own suppliers and our supply chain is therefore large and complex. As a result, we focus our attention on companies that supply high value products or services, or business critical suppliers – key suppliers that DST FS would struggle or fail to operate without.

For further information about what we do please refer to the “About Us” section on our website.

Policies and procedures

DST FS is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking. In keeping with our commitment to act with integrity in all our business dealings, many of our existing policies and procedures are relevant to ensuring that there is no slavery or human trafficking in our supply chains or any part of our business. To this end, our relevant policies and procedures include:

  • Ethics and Standard of Conduct policy;
  • Code of Conduct;
  • Equal Opportunities and Dignity at Work policy;
  • Procurement Code of Conduct;
  • Recruitment and Selection policy;
  • Employment Screening policy;
  • Corporate Social Responsibility policy;
  • Supplier Due Diligence
  • Whistle Blowing policy; and
  • Anti-bribery policy.

We provide guidance, education and training to support employee understanding of expected behaviour, particularly in respect of their business decisions. If employees have concerns, we encourage them to raise them directly with their line manager or Human Resources, however, if they are not comfortable doing this we have a whistle-blowing policy and anonymous telephone line which employees can use to raise any issues. We will focus on helping people understand and identify slavery and human trafficking risks, and remind them how they can report any concerns they may have.

All our policies and procedures are underpinned by our core values and our High Five Corporate Goals, including to embrace risk management and compliance.

We are always reviewing and updating our policies and procedures and we continue to strengthen certain sections of them to include more explicit and/ or implicit references to combatting slavery and human trafficking, where necessary.

For ease of reference brief summaries of the key policies listed above are detailed below:

Recruitment and selection

We only use specified, reputable employment agencies to source labour and always verify the practices of any new agency before accepting workers from that agency. All employment agencies supplying temporary workers are subject to due diligence checks and all temporary workers are subject to the same level of background checks as permanent DST FS staff, with the exception of criminal record checks.

Employment screening

All offers of employment at DST FS are subject to completion of satisfactory background checks. The honesty and integrity of our staff is of paramount importance. The background checking process consists of the following:

  • Proof of eligibility to work in the required country;
  • Employment references (last 5 years);
  • Verification of educational and professional qualifications;
  • Criminal record check (Basic Disclosure);
  • Credit check; and
  • Proof of residence.

Procurement Code of Conduct

We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour.

Corporate Social Responsibility

We endeavour to act responsibly in the way we conduct our business. Our vision and strategy for Corporate Social Responsibility is aligned to our business goals and company strategy to make sure that we meet the needs of employees, customers and shareholders. We actively look for opportunities to improve the environment and to contribute to the wellbeing of our employees and the communities in which we work.

Supplier due diligence

We undertake due diligence when taking on new suppliers, and regularly review our existing suppliers. The level of due diligence we carry out depends on how we initially evaluate a supplier. Risk profiling helps us focus our efforts where they are most needed. For example, suppliers may present a higher risk of slavery or human trafficking because of where they are based or the type of product or service they provide.

We carry out due diligence on all medium and high risk suppliers. All high risk suppliers are subject to a more detailed review which may, for example, include auditing the supplier. In light of the Modern Slavery Act, we reviewed how suppliers are categorised as low, medium or high risk. If we consider, based on our risk profiling, that a supplier presents a higher risk of slavery or human trafficking then that supplier will be categorised as high risk and will be required to answer further questions regarding, amongst other things, its labour practices.

We regard suppliers as our partners and work with them to achieve our policy requirements in the delivery of our products and services, taking into consideration ethical and environmental considerations.

Factors that are considered as part of supplier due diligence for medium and high risk suppliers may include, as appropriate, employee training and personal development, pay and benefits, workplace climate, use of legal labour, community impact and the impact on society and relevant legislation (including relevant anti-bribery and modern slavery requirements).

Terms and conditions

We updated our Terms of Agreement (UK) to include a provision on Anti-Slavery and Human Trafficking. This provision obliges a supplier to comply with the Act and to maintain its own adequate policies and procedures to ensure such compliance.

Our terms and conditions can be found at https://www.dstsystems.com/disclosures/terms-and-conditions

Further steps

We intend to review and, where appropriate, build on the above steps year on year to combat slavery and human trafficking. We will continue to follow the steps set out above (or similar) and we will collaborate with suppliers to ensure that they hold the same values that we hold against slavery and human trafficking.

We have set-up a cross functional team to look at how we address modern slavery and human trafficking, now and in the future. This team includes representatives from legal, HR, procurement and compliance. Longer term, we will look at ways of measuring the effectiveness of the steps we have taken as an organisation.

Board approval

This slavery and human trafficking statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 for and on behalf of DST Financial Services International Limited and DST Financial Services Europe Limited for the financial year ending 31 December 2017.

This statement has been approved by the board of directors of DST Financial Services International Limited and DST Financial Services Europe Limited. It will be reviewed and, where necessary, updated annually.