This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 ("Act") and constitutes atomos's slavery and human trafficking statement for the financial year ending December 2023 and has been approved by the company boards.
atomos' structure
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's 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 policies
Our existing staff policies include a Modern Slavery Policy, which sets out our key controls including due diligence and contractual requirements for our suppliers where appropriate.
In addition, our Policies such as our Whistleblowing Policy, 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;
- on a risk based basis as part of our due diligence we will require potential key suppliers and outsourcers to disclose the measures taken to comply with their Modern Slavery Act obligations;
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.
Monitoring
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, managed by the Enterprise Risk Manager.
atomos's whistleblowing procedures are designed to facilitate reporting if atomos staff wish to raise concerns.
Training
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.