This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 ("Act") and constitutes atomos' slavery and human trafficking statement for the financial year ending December 2022 and has been approved by the company boards.
atomos is the trading names of both Atomos Investments Limited (No: 2041819, FRN: 122588), and Atomos Financial Planning Limited (No: 3879955, FRN: 193503), both of which are authorised and regulated by the Financial Conduct Authority and registered in England and Wales. Registered offices: 2nd floor, 5 Hatfields (alto), London, SE1 9PG.
atomos is a leading provider of wealth and investment management services to private clients, professional advisers, charities, corporates and institutions.
Our business and supply chains
atomos has assessed the impact of the Act on its business and the changes required to its policies and processes.
atomos has a relatively straightforward supply chain. Our suppliers are typically professional advisers and consultants and suppliers of regulated services (such as investment management), IT, back-office administration services and other office equipment and services.
The majority of atomos' supply chain is based in the UK. Being regulated atomos considers it has a low risk of modern slavery or human trafficking within its business operations and supply chain.
Nevertheless, we understand the importance of combatting modern slavery and human trafficking and are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
Our existing staff policies include a Modern Slavery Policy, which sets out our key controls including due diligence and contractual requirements for our suppliers.
In addition, our Policies such as our Whistleblowing Policy, Supplier Code of Conduct, Outsourcing Policy and Anti-Bribery & Corruption Policy reflect our commitment to acting ethically and with integrity in all our business relationships.
Supplier due diligence
As part of the atomos Outsourcing Policy and related due diligence processes, where appropriate for the appointment of suppliers we will:
- as part of our appointment process make suppliers aware that atomos does not tolerate modern slavery practices in its supply chain.
- require potential key suppliers and outsourcers to disclose the measures taken to comply with their Modern Slavery Act obligations.
- include appropriate contractual terms governing the supplier's compliance with the Act.
- we require all new suppliers to enter into our Code of Conduct which sets out our requirements on matters such as modern slavery, this document forms part of our legally binding contracts with suppliers.
Suppliers who are unable to satisfy atomos as regards their compliance with the Act will not be appointed. We will not knowingly do business with suppliers who are involved in modern slavery.
Our outsourcing and due diligence processes ensure suppliers are risk assessed and categorised appropriately, including the identification, mitigation, and management of potential risks, including those related to modern slavery and human trafficking. This includes the enhancement of key supplier information, which is obtained and recorded, ensuring the appropriate ownership of supplier relationships.
Our Risk Manager, along with our Finance, Operations, Compliance and Legal teams, and senior managers in the relevant business areas are responsible for procurement and will manage concerns and ensure they are appropriately escalated and reported to our boards. Any identified risks will be recorded and monitored on atomos’s key risk reports.
atomos's whistleblowing procedures are designed to facilitate reporting if atomos staff wish to raise concerns.
Appropriate training will be considered for key staff as necessary, to enable those staff to understand our obligations under the Act and to recognise and mitigate the risk of modern slavery.
We reiterate our ongoing commitment to Act.
All staff are required to attest at commencement of employment and annually thereafter that they have read and understood our modern slavery policy.