Modern Slavery Statement

Modern Slavery Act 2015 (“MSA”)

Tenet Group Ltd and Subsidiaries (“Tenet”) Slavery and Human Trafficking Statement for the Financial Year ending 30 September 2016

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that we have taken, and are continuing to take, to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern Slavery encompasses slavery, servitude, human trafficking and forced labour. We have a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings, and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Business

Tenet is a UK based company which operates a Financial Services Network through its subsidiary companies, TenetConnect Limited, TenetConnect Services Limited and TenetLime Limited, all of which are authorised and regulated by the Financial Conduct Authority.

We authorise individuals and corporate bodies to act as our Appointed Representatives in accordance with the Financial Services and Markets Act 2000.

We are a service business within the financial services sector, providing amongst other things compliance and back office support to our Appointed Representatives, who are authorised by us to provide financial advice and recommend financial products to retail customers within the United Kingdom.

Our Supply Chains

Our supply chains include suppliers of IT, telephone and office equipment, hotel conference facilities, insurance brokerage, professional services from our lawyers, accountants and other advisers.

Our suppliers are predominantly from the United Kingdom, Europe and the United States of America. We have determined that we are in a low risk industry as are the vast majority of our suppliers; therefore we do not consider the risk of modern slavery within our supply chain to be a significant risk.

Due Diligence Processes for Modern Slavery and Human Trafficking

We shall use our reasonable endeavours to ensure that slavery or human trafficking is not taking place in our supply chains by reviewing all relevant current and future suppliers to ensure that they comply with the Modern Slavery Act 2015.

Through our procurement process we will seek assurance from all relevant suppliers about their anti-slavery and human trafficking policies, and whether they are taking steps to prevent slavery and human trafficking in their respective business and supply chains; this action will be undertaken by reviewing their Modern Slavery Act 2015 statements. We will not support or engage suppliers where we are aware of slavery or human trafficking in such suppliers’ business or supply chains or where a supplier has failed to give us the requisite assurances.

Policy and Training

In 2017 we will be implementing an Anti-Slavery and Human Trafficking Policy which will apply to all persons working for or with any Tenet company, including but not limited to those in the capacity of employee, contractor, agency worker, temporary staff, agents, external consultants and suppliers.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and supply chains, we will be providing training to all relevant staff involved in the procurement of goods or services so they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

Our Working Practices

We allow all individuals who work or provide services to us the right to freely choose employment and the right to associate freely with other individuals. We offer an environment which is free from harassment and unlawful discrimination.

We ensure that our working practices are in accordance with the Equality Act 2010 and all employment legislation. We do not engage in forced or involuntary labour and have a zero tolerance approach to the same, meaning we do not tolerate any of our suppliers engaging in such conduct.

This statement is made under section 54(1) of the Modern Slavery Act 2015 and constitutes Tenet’s slavery and human trafficking statement for the financial year ending 30th September 2016.

This statement has been approved by Tenet's Board of Directors and will be reviewed annually.

Signed by
MG Signature

Martin Greenwood
Chief Executive Officer

Date: 28th February 2017

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