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— Governance

Modern Slavery Statement

Finnerve Ltd · Updated August 2026 · v2.0

Scope and voluntary nature

This statement is published voluntarily. Finnerve Ltd falls below the £36M turnover threshold that triggers the obligation under section 54 of the Modern Slavery Act 2015, and is therefore not legally required to make it.

We publish it because our clients are regulated entities that audit their supply chains, and because we believe the standard of respect for human rights should not depend on the size of a company. This statement covers Finnerve Ltd and its group entities, including Finnerve S.A.C. (Peru) and Finnerve Chile SpA.

Our structure and supply chain

Finnerve is a consulting, BPO, SaaS, application-outsourcing and systems-integration firm serving the financial sector. The parent is based in the UK, and we maintain operations in Spain, Peru, Chile, Mexico, Colombia and Panama.

Our supply chain is made up principally of:

  • Cloud and technology infrastructure providers.
  • Software licensors and technology partners.
  • Independent consultants and specialist subcontractors.
  • Professional services (legal, tax and audit).
  • Corporate services (offices, travel and IT hardware).

Risk assessment

The risk of modern slavery in our direct operations is low. Our activity relies on qualified professionals, with formal contracts, remuneration above the applicable minimum wage, and full freedom of movement and to terminate the employment relationship.

Nevertheless, we identify a residual but real risk at two points in the supply chain:

  1. Hardware manufacturing. IT equipment comes from global supply chains with known exposure in mineral extraction and in assembly stages.
  2. Facilities-management services (cleaning, security and maintenance), where subcontracting is common and can reduce visibility over working conditions.

Our policies

  • The Code of Ethics and Conduct prohibits forced and child labour and extends that requirement to our suppliers.
  • The supplier KYC/AML policy embeds compliance with the Modern Slavery Act 2015 as a contractual clause.
  • The staff KYC/AML policy requires identity and right-to-work checks.
  • The whistleblowing channel (speakup@finnerve.com) is open to our suppliers’ workers and is protected under the Public Interest Disclosure Act 1998 (PIDA).

Due diligence

We apply a due diligence process proportionate to risk:

  • Pre-onboarding screening of every new supplier.
  • Contractual clauses requiring compliance with labour and human-rights law, with immediate-termination rights in the event of breach.
  • Preference for suppliers that have their own modern slavery statement or recognised labour certifications.
  • Re-evaluation on any material corporate, regulatory or reputational change.
  • Immediate escalation to the Compliance Officer, with precautionary suspension of the relationship, on any indication of a breach.

Training

Mandatory induction for every new joiner includes the Code of Ethics and the whistleblowing channel. In addition, the procurement and supplier-management teams receive specific training on supply-chain risk indicators, including forced-labour indicators.

Key performance indicators (KPIs)

We measure the effectiveness of these measures through:

  • Percentage of active suppliers with a human-rights clause in their contract.
  • Percentage of critical suppliers with documented due diligence.
  • Number of labour-condition reports received and average resolution time.
  • Percentage of staff who have completed the mandatory training.

Next steps

  • Extend the due-diligence questionnaire to all critical suppliers, not only new ones.
  • Add labour-traceability criteria to hardware purchasing.
  • Publish the KPIs in this statement from next year.

Approval

This statement has been approved by the Board of Directors of Finnerve Ltd and is reviewed annually.