Introduction & Organisational Structure
Reclaim Fund Ltd (‘the Company’ or ‘RFL’), was incorporated on 13 August 2010 and commenced operations on 28 March 2011. RFL is recognised by Government as a Non-Departmental Public Body and is wholly owned by Her Majesty’s Treasury. It is authorised and regulated by the Financial Conduct Authority, operates independently with an appointed Board and Executive, and is non-profit-making (company no 07344884).
The principal activity of RFL is that of the collection and management of dormant asset monies. The Dormant Assets Acts 2008 to 2022 (‘The Acts’) enables those financial institutions and publicly listed companies, that choose to participate (‘participants’), to transfer money from their dormant financial products to the Company for surplus funds to be distributed by RFL to The National Lottery Community Fund and then onwards to good causes across the UK. The Acts also ensure that the right of original owners to reclaim their money is protected in perpetuity by transferring the individual’s claim against their original asset provider to RFL.
Whilst pursuing our Purpose and Mission, we are committed to combating slavery and human trafficking and will take all reasonable measures to ensure a strong ethical framework is in place.
Risks are regularly reviewed by our Executive Risk Committee, Audit and Risk Committee and Board. Our policies are embedded into our governance and are reviewed regularly. The following policies reflect RFL’s approach to the Modern Slavery Act:
- Modern Slavery
- Procurement & Outsourcing
- Ethics, Equal Opportunities, Diversity & Inclusion HR Processes and Policies
The Slavery & Human Trafficking Statement which forms part of our Modern Slavery policy, is reviewed and approved annually by the Board and is signed by our CEO, who is the Accounting Officer for RFL.
Due Diligence & Risks
RFL’s supplier management approach involves categorisation of our key and other suppliers; the frequency and depth of monitoring and review of each supplier is dependent upon this categorisation and is explained in our Supplier Relationship Management Plan, which forms part of our Procurement & Outsourcing Policy and associated Manual.
As a recently onboarded Non-Departmental Public Body (NDPB) of Government, RFL has commenced utilisation of Crown Commercial Service (CCS), the government’s central purchasing body for the majority of current and future procurements. In these scenarios a proportion of reliance is placed on CCS and their ability to provide assurance that the selected suppliers comply with the Modern Slavery Act.
RFL has a relatively small number of suppliers and service providers and as a result has adopted a 2-tier approach tier 1 being those suppliers who publish a modern slavery statement and tier 2 being those who do not.
- Tier 1; We review annually the Modern Slavery statements published by our suppliers to establish whether their stated approach meets the terms of the Modern Slavery Act. We notify our suppliers that a review of their statement has taken place and provide them with our own. We provide our suppliers with the opportunity to disclose reported incidents and update us with any further steps they are taking in relation to Modern Slavery within their business.
- Tier 2; For these suppliers, RFL will communicate explaining that we comply with the Modern Slavery Act, provide them with our own Slavery and Human Trafficking Statement and request confirmation of their own compliance.
Any instances of non-compliance will be assessed and remedial action taken, initially engaging with the supplier to resolve any issues within an agreed timescale. If this is not resolved to RFL’s satisfaction, then the contract with the supplier will be terminated and a different supplier sourced.
Modern Slavery mitigation including consideration of ethical approaches/practices is part of the Tendering and Contract process undertaken for any new suppliers. RFL’s suppliers are risk assessed regularly and the key/higher risk suppliers are subject to additional monitoring, including addressing Modern Slavery. These activities can include regular face to face reviews and adverse media monitoring.
RFL takes its responsibilities as an employer very seriously as demonstrated by its Living Wage, We Invest in Wellbeing and Investors in People accreditations. Our HR policies and procedures underpin this approach and we work closely with all related parties to ensure we continue to meet the objectives of the Modern Slavery Act.
RFL is working on enhancing its Modern Slavery approach and statement, and looks to identify priority risks for inclusion in the statement for the next financial year.
We measure and record the results of our Modern Slavery Act related risk assessments on an annual basis; this includes Key Performance Indicators for Key Suppliers. In the period 1 January 2021 to 31 March 2022, our suppliers have not reported any identified instances of slavery in their supply chain or operations.
Connected with RFL’s status as an NDPB, this year RFL has had a specific focus on procurement and outsourcing and recognises the need to include additional progress goals to measure the effectiveness of its modern slavery activities and is producing KPI’s for the period 1 April 2022 to 31 March 2023.
We remain committed to combating slavery and human trafficking and will continue to monitor progress in relation to the new ‘Modern Slavery (Amendment) Bill’ to implement any required changes and improvements within our processes.
We roll out annual mandatory training to all our employees including Modern Slavery, Whistleblowing and Equality & Diversity. All RFL team members completed and passed this training between 1 January 2021 and 31 March 2022. Additional specialist training is provided to the relevant members of staff. RFL will continue to monitor training needs in relation to the ongoing development of our Modern Slavery Policy and Statement and address accordingly.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and refers to the financial year ending 31 March 2022. This statement was presented and approved by the RFL Board on 6 July 2022.
Signed by Adrian Smith
Chief Executive and Accounting Officer Reclaim Fund Ltd
6 July 2022
Please click here to download a PDF of our statement.