Modern Anti Slavery Policy



This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 2018-2019.


The statement sets down International Compliance Solutions Ltd. commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.


Organisational structure and supply chains


This statement covers the business activities of International Compliance Solutions Ltd which are as follows:


The company provides risk management and regulatory compliance services to financial services firms in the UK, Europe and Internationally.


The Company currently operates in the following countries:


UK with reach to a number of jurisdictions where our clients are based.


The following is the process by which the Company assesses whether particular activities or countries are high risk in relation to modern slavery or human trafficking: the business operates a risk based approach to entering relationships, regardless of jurisdictions, where even countries considered to be low risk, are treated in a case to case basis.


High Risk Activities


We only provide services to financial services firm, thus the risk of modern slavery is low.


Responsibility for the Company’s anti-slavery initiatives is as follows:


1.1 Policies: Sally Bustos is responsible for creating and reviewing policies. The process by which policies are developed is risk based and in light of our activities, client’s needs, operations, countries, etc

1.2 Risk assessments: Alex Bustos, MD is responsible for risk assessments in respect of human rights due diligence:

1.3 Sally Bustos is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.




To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all staff to receive face to face training.




The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.


The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:


2.1 Whistleblowing policy - the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.

2.2 Code of Conduct - The Code of Conduct sets down the actions and behaviour expected of employees when representing the Company.

2.3 Corporate Social Responsibility (CSR) Policy - The Company’s CSR policy summarises how we work with local communities.



Due Diligence Processes for Slavery and Human Trafficking


The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes KYC and Sanctions check and evaluating the modern slavery and human trafficking risks of each new relationship.


Performance indicators


The Company uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including staff to have completed training on modern slavery.


This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The boar of directors endorses this policy statement and is fully committed to its implementation.


This Modern Slavery and Human Trafficking Statement has been approved and authorised by:



Alex Bustos






April 2018




Alex Bustos