Modern Slavery Statement

For the financial year ending 05/04/2025
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This statement is made in compliance with section 54 of the Modern Slavery Act2015.

‍Introduction
‍Thrive by Blackfinch is committed to preventing acts of modern slavery and human trafficking within its business and supply chains. Transparency and ethical conduct are central to how we operate, providing assurance to our clients, partners, and members that we act responsibly and with integrity. This statement is made in compliance with section 54 of the Modern Slavery Act 2015 and outlines the steps taken by Thrive by Blackfinch to prevent modern slavery and human trafficking across our operations and supply chain. 

‍Organisational Structure
‍Thrive by Blackfinch is a UK-based financial wellbeing platform focused on pensions, benefits and financial education. We operate under our own governance framework and supplier oversight, proportionate to our business model and risk profile. We work with as mall number of UK partners and suppliers, including technology, pension and professional service providers. Our supply chain is straightforward and not complex, which we assess as presenting a low risk of modern slavery or human trafficking.

‍Governance andPolicy
‍Thrive by Blackfinch maintains a comprehensive framework of policies designed to uphold ethical business practices. These include our Anti-Bribery and Corruption Policy, Data Protection Policy, and Modern Slavery Statement. We expect all employees, contractors, and suppliers to comply with these policies and to report any concerns relating to unethical conduct or human rights violations. All policies are reviewed annually to ensure they remain current, relevant, and aligned with both regulatory expectations and Blackfinch Group standards. 

‍Risk Assessment and Due Diligence
‍Thrive by Blackfinch operates within the UK financial wellbeing and pension sector, which is considered low risk for modern slavery and human trafficking. Our business model involves a limited number of suppliers, primarily regulated professional service providers and technology partners. We do not engage with suppliers based in countries where labour laws are weak or not enforced. Before engaging with any new supplier or partner, we conduct appropriate due diligence to assess ethical standards and identify potential risks. This process includes reviewing their human rights and labour policies, recruitment and subcontracting arrangements, and overall governance practices. Where concerns are identified, we work directly with the supplier to address and resolve issues. If such engagement is unsuccessful, we will terminate the relationship. Our approach ensures that all suppliers meet our ethical and compliance expectations, supporting our commitment to prevent modern slavery in our operations and supply chain.

‍Training,Awareness and Continued Development
‍We are committed to ensuring that all Thrive employees are fully informed about human rights and modern slavery issues and are able to recognise potential risks and indicators of unethical practices. Thrive by Blackfinch provides regular training on a range of legal and compliance matters, including employees’ obligations under the Modern Slavery Act 2015. This training helps to embed awareness across the business and ensures that our people understand how to identify, escalate, and respond appropriately to any concerns. We will continue to review and strengthen our training and awareness programmes, ensuring that both our employees and our suppliers maintain high standards of ethical conduct and remain vigilant in preventing modern slavery and human trafficking within our business and supply chains.  

‍Looking Ahead
‍In the year ahead, Thrive by Blackfinch will continue to strengthen its oversight of supplier due diligence and maintain rigorous controls to manage potential risks. We will also review our internal training and awareness programmes to ensure that our team remains well-informed and engaged in upholding our ethical standards. 

‍Statement Approval
‍This statement was approved by the Board of Directors of Thrive by Blackfinch on [Insert Date] and will be reviewed annually.

‍Signed,
[Insert Name]
[Insert Title]
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Thrive by Blackfinch