Modern slavery statement

This statement on slavery and human trafficking is published on behalf of the CFC Group and its subsidiaries (‘CFC’) for the 2020/2021 financial year, pursuant to s54 of the Modern Slavery Act 2015 (‘the Act’).

CFC is committed to conducting our business responsibly and ethically, including ensuring that our supply chains are free from slavery and human trafficking.


This statement covers the activities of CFC, which is headquartered in London, with licensed trading entities operating in Brussels, New York and Austin. CFC currently employees over 350 staff. 


Whilst CFC sells its products and services worldwide, it does not make use of supply chains which are traditionally susceptible to an enhanced risk of slavery or human trafficking, such as factories, other entities involved in manufacturing, or business sectors which are reliant on a high degree of human labour.

Given the nature of CFC’s business, we consider the risk of modern slavery in our supply chains low. However, we remain vigilant to this risk, and have in place several policies and procedures to ensure we do not knowingly do business with a company involved in any form of modern slavery or human trafficking.


As part of our commitment to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business, we maintain policies and procedures to support this commitment including:

Outsourcing Policy: setting out our approach to outsourcing, as well as the due diligence which must be undertaken before CFC outsources any aspect of its business to a third party. As part of the due diligence process, CFC checks all potential service providers for financial soundness, sanctions and adverse media, and continually monitors providers on a regular basis.

Whistleblowing Policy: setting out the manner in which our staff and business partners can report any concerns relating to the activities of any CFC Group company or anyone involved in its supply chains, including circumstances which may give rise to a risk of human trafficking or slavery.

Recruitment and Remuneration Policies: setting out the rights in which all our staff enjoy, including fair and reasonable wages, the right to a safe working environment, and appropriate holidays and provisions for sickness.

Risk Management Policy: CFC’s approach to effective risk management is outlined in its Risk Management Policy. Any existing or emerging modern slavery risks will be captured as part of the risk management cycle, with mitigants.


CFC continuously reviews its risks in relation to modern slavery and human trafficking, both as an employer and as a purchaser of outsourced services, to identify measures we can take as a business to prevent modern slavery occurring in our business and supply chain.

We intend to take the following steps during the 2020/2021 financial year:

  • Develop and release to employees a Code of Conduct outlining the ethical standards that all employees of CFC are expected to adhere to, to ensure CFC operates responsibly and ethically.
  • Review and refresh our current outsourcing policy and supplier due diligence process to ensure we are taking effective steps in ensuring modern slavery is not supported within our supply chains.


The Board of CFC will review this statement annually.