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UK Modern Slavery Act and
California Transparency in Supply Chains Act
Statement

DISCLOSURE REQUIREMENTS UNDER THE UK MODERN SLAVERY ACT 2015 AND CALIFORNIA
TRANSPARENCY IN SUPPLY CHAINS ACT 2010 FOR THE FISCAL YEAR 2017

 

UK MODERN SLAVERY ACT 2015 (“UK ACT”)

This statement is made pursuant to Section 54, Part 6 of the UK Act and sets out the steps Medici Firma is taking to ensure that slavery and human trafficking is not taking place in its supply chains or any parts of its business. Medici Firma Corporation. (together with its subsidiaries, “Medici Firma” or the “Company”) is a global leader in Institutional Investment Advisory.

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT 2010 (SB 657) (“CALIFORNIA ACT”)

Under the california Act, companies of a certain size doing business in the State of california are obligated to disclose their efforts to eradicate slavery and human trafficking from their direct product supply chains for the goods that they offer for sale.

COMPANY DESCRIPTION

Medici Firma, is global investment and advisory company putting allied property first.

COMPANY DISCLOSURE

Medici Firma strives to achieve and maintain the highest possible standards of corporate integrity and ethical behavior. The Company takes the issues of slavery and human trafficking very seriously and will continue doing its part by responsibly managing its supply chain in an effort to eradicate human trafficking and slavery. Medici Firma does not endorse any form of modern slavery in its operations or in its supplier networks. The Company takes a number of steps with respect to verification of its supply chain and certification of materials to ensure suppliers are operating in an ethical manner, including the following:

1. Verification – Medici Firma expects that its suppliers will conduct their businesses in a lawful manner and in compliance with high standards of integrity and ethics. In order to establish guidelines for such standards, Medici Firma has established a Supplier Code of Conduct. The Supplier Code of Conduct requires supplier compliance with important legal, ethical, behavioral and other requirements. Specifically, the Supplier Code of Conduct states that suppliers must not support, promote or engage in the practice of slavery or human trafficking, and it requires suppliers to comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Medici Firma suppliers are further expected to take reasonable and necessary steps to help ensure that their sub-contractors and sub-suppliers conduct business in compliance with the Supplier Code of Conduct. Suppliers are expected to promptly take corrective action to address any deficiencies identified with respect to compliance with Medici Firma’s Supplier Code of Conduct. In the Supplier Code of Conduct, slavery, human trafficking and child labor are specifically prohibited. If a supplier is found to be in violation of the Supplier Code of Conduct, Medici Firma will take prompt, remedial measures to address the violation. Medici Firma reserves the right to terminate its relationship with any supplier for failure to comply with the Supplier Code of Conduct.

2. Audits – While Medici Firma performs routine audits of its suppliers, it does not currently have a specific policy or process requiring specific or routine audits to evaluate compliance with prohibitions against trafficking and slavery in supply chains. To the extent that Medici Firma suspects or receives notice that a supplier is involved in these activities, Medici Firma will conduct an inquiry, or third party audit if warranted, and take appropriate action as required by law.

3. Certifications – Medici Firma requires its suppliers to represent and certify, by acceptance of the Company’s purchase order terms and conditions, that in providing goods and services under the purchase order, the supplier has complied and will comply with all applicable federal, foreign, state and local laws, rules and regulations, including, without limitation, all anti-slavery and anti-human trafficking laws.

4. Accountability – Medici Firma has established a Code of Business Conduct and Ethics, which applies to all Medici Firma personnel, including officers, directors and employees (including full-time, part time temporary and contract employees) (collectively, “Team Members”). Medici Firma expects its business partners and contractors to share the general principles stated in the Code of Business Conduct and Ethics. These general principles require Medici Firma Team Members to comply with all applicable laws and regulations, including but not limited to those relating to human trafficking and slavery. The Medici Firma Code of Business Conduct and Ethics specifically calls out child labor, forced labor (slavery) and human trafficking. The Code of Business Conduct and Ethics explains that if a Team Member needs guidance on a legal or ethical question or has witnessed or has knowledge of an illegal or unethical activity, he or she should consult with or report the matter to his or her manager, supervisor or the Compliance Office or via the Compliance Hotline. All reports of alleged violations will be investigated by Medici Firma. Disregard or deliberate ignorance of the law, failure to report known or potential violations and/or failure to cooperate in an investigation will not be tolerated and may lead to disciplinary action, including termination of employment.

5. Training – All Team Members are trained on the Code of Business Conduct and Ethics. The Code of Business Conduct and Ethics requires Team Members to comply with all applicable laws and regulations, including but not limited to those relating to human trafficking and slavery. Team Members who have direct responsibility for supplier management are also trained on the Medici Firma Supplier Code of Conduct. The Supplier Code of Conduct informs suppliers that Medici Firma will take prompt, remedial measures to address any violations.

Medici Firma strives to continuously improve its programs and practices to ensure compliance with applicable laws and regulations and the Company’s high ethical standards, and to meet the expectations of its customers, shareholders, associates and other stakeholders.

MFBG

Medici Firma Board of Governors.