This statement is made pursuant to section54, Part 6 of the UK’s Modern Slavery Act 2015 (the Act). The statement sets out the steps that Rimes has taken and our commitment to improving our practices to ensure that slavery and human trafficking is not taking place in our supply chains or any parts of our business. The Act and our publishing of this statement is intended to help clients and suppliers to make better, more informed choices about the products and services they purchase and the companies they support or with whom they do business.
Rimes is committed to acting ethically and with integrity in all its business dealings and relationships and ensuring that it is not involved, directly or indirectly, in the commission or facilitation of modern slavery and human trafficking, or any additional offences set out in the Act. Rimes also expects its staff, business partners and supply chains to apply the same high standard, and to take reasonable steps to ensure other parties they do business with maintain the same high standards.
We are a global provide of investment data services. We have approximately 400 staff and operate in 10 countries worldwide. Our staff in this context include our employees and any contractors engaged by us on a full time basis.
Our Supply Chains
We are a business-to-business organization and we enter into individual contracts with each of our clients to provide bespoke services to them.
The obtain and procure goods and services from various suppliers and business partners, predominantly based in the USA, EU, UK, and to a lesser extent, Asia-Pacific. Our key supplies are data provides, along with information technology (including information security) suppliers, office providers and suppliers providing marketing, financial, legal and compliance services.
Our Policies on Slavery and Human Trafficking
Rimes is committed to ensuring that it is not involved, directly or indirectly, for any reason, in the commission or facilitation of modern slavery and human trafficking. Our Code of Conduct reflects our commitment to acting ethically and with integrity in all our business relationships, to implement effective controls and processes, and apply a risk-based approach in seeking reasonable assurance that our business partners and/or supply chains are not involved in the commission or facilitation of modern slavery or human trafficking.
Our Code of Conduct includes a whistleblowing policy which encourages and empowers our staff to identify and disclose details of any suspected modern slavery or human trafficking, either within our business practices, or within the business practices of our business partners or in any of our supply chains.
Our Code of Conduct is available to our staff using our intranet sites and staff are encouraged to familiarize themselves with it as part of their employment. Our staff undertake mandatory annual training on our Code of Conduct.
Due Diligence Process for Slavery and Human Trafficking
As part of our initiative to identify and mitigate risk in this area, we carry out appropriate vendor due diligence, taking a risk-based approach when entering into business relationships with partners and suppliers. This may include making requests of prospective suppliers to complete a self-assessment due diligence check, the extent of the checks being proportionate to and dependent on the assessed risk level of the supplier. This self-assessment due diligence compliance check will typically require information relating to that supplier’s compliance with the requirements of the Act (or equivalent legislation in their jurisdiction), including details of any required or voluntary modern slavery statements, its relevant policies and confirmation that it has program in place to ensure modern slavery and human trafficking does not exist in its business or supply chain.
In addition, where a supplier confirms it is required to make its own statement in accordance with the Act, or confirms to us that its does so voluntarily, Rimes will review the content of the statements published.
We have also started to introduce specific contractual obligations relating to the prevention and mitigation of modern slavery risks in our vendor contracts on a risk assessed basis.
Training and Our Staff
To ensure a high level of understanding of the risk of modern slavery and human trafficking amongst our staff, we are introducing dedicated training on the requirements of the Act as part of our compulsory staff induction and onboarding and subsequent compulsory annual compliance training program. This training is intended to encourage our staff to be vigilant to the risks of modern slavery and human trafficking and take action where appropriate and necessary.
Our Human Resources team also have the responsibility to monitor and show that Rimes’ own staff are recruited and treated within the confines of local laws and regulations, and are not a victim of any modern slavery or human trafficking offences arising from their employment.
Targets and Updates
Our key targets for this year are to ensure all our staff have completed the dedicated training regarding the risks of modern slavery and human trafficking and to refine our vendor risk assessment criteria and procedures for storing vendor risk assessments and supporting documentation.
We will update this statement annually to reflect improvements in our processes identified over the year and latest good practice and guidance.
This statement is made pursuant to section 54(1) of the UK's Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement for the financial year ending 31 December 2022.
The statement was approved by the Board of Directors and has been signed on behalf of the Board by Donal Smith, Chariman.