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Rockhold Asset Management: Modern Slavery Statement

Adviser Services Holdings Group - Modern Slavery Statement 2025

This statement sets out the steps taken by us to prevent modern slavery.

INTRODUCTION

Together with other companies within our group, we provide authorisation for financial advisers to conduct business, compliance support services, financial processing for financial advisers and, occasionally, financial advice.

Our ultimate parent company is Adviser Services Holdings Limited. All companies within our group are based within the United Kingdom and services are only intended for those within the United Kingdom.

We have a group annual turnover of circa £85m.

We understand the growing issues around modern slavery. No sector or industry is immune and we are committed to being alert to the risks, however small, in our business and supply chain.

Our supply chain consists of:

  • Our financial advisers and their staff;
  • Suppliers of services into offices, for example utility providers, IT platform providers, cleaning companies and providers of office supplies.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies.

Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Our employees are required to understand our policies so they can be vigilant for signs of modern slavery within our supply chain and so that they are aware of how to report concerns.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

We operate within a relatively low risk environment but understand that the highest risk are likely to be with contractors engaged by third parties that we contract with.

We have in place systems to:

  • Identify and assess potential risk areas in our supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains.
  • Monitor potential risk areas in our supply chains.
  • Protect whistle blowers.
  • We have zero tolerance to slavery and human trafficking. Our Anti-Slavery Policy set out the standards that we expect of our suppliers and ourselves. Staff are trained to recognise instances of modern slavery and understand how the issue should be reported and dealt with.
  • We operate within a culture of transparency. Our Whistleblowing Policy is aimed principally at employees and advisers but is available to others working within our supply chains. This encourages staff and others to report any wrongdoing and extends to human rights violations, such as those covered by the Modern Slavery Act.
  • We expect the same high standards from our suppliers as we do from ourselves. We keep our supply chain under review and insert an anti-slavery and human trafficking clause into relevant contracts that we issue.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

We understand that the risks around modern slavery will evolve over time and we will continue our approach to mitigating these in the year ahead.

Michael Couzens, CEO

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31st December 2025. It was approved by the board of directors on 28th November 2024.