This page contains annually reviewed statements from Edale UK Management Limited and Edale Enterprises Limited (hereafter Edale).
Terms of business and policies from Edale can be seen at https://edale.co/terms/.
EDALE MODERN SLAVERY ACT
In 2015 new legislation was introduced entitled the Modern Slavery Act 2015. Modern slavery encompasses slavery, servitude, human trafficking and forced labour.
Edale is committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
This statement represents our firm’s slavery and human trafficking statement for the 2020 financial year.
Our organisation and structure
Edale was established in 2014 as a wealth boutique focused on monitoring, managing & caring for financial assets.
Edale is investment adviser to funds and client portfolios as well as offering bespoke services. The firm was launched by practitioners of big firm experts to develop superior products that demonstrate flair and leading edge thinking in niche market segments.
Our business activities cover a wide range of financial products and services.
Responsibility and accountability for the Group’s compliance with the Modern Slavery Act 2015 is ultimately the Board of Directors, however, on a day to day basis, it is the responsibility of our Chief Executive.
The Group works to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We have internal policies in place including our Ethical Code, Recruitment and Whistleblowing policies that demonstrate our commitment to this as an organisation.
Our Modern Slavery Act Statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure our suppliers comply with the requirements of the Modern Slavery Act 2015.
Overall risk for the Group related to Modern Slavery Act compliance is deemed to be low, for the following reasons:
The firm is UK based and operates in the field of financial services;
Our supply chain is limited to goods and services which are required to support an organisation of this nature (e.g. support services and computer hardware + software); and
Use of non-UK based suppliers is extremely limited. Expenditure with third parties is less than £250,000 per annum. 80% of this expenditure is with a handful of partners.
Supplier Due Diligence
We have zero tolerance to slavery and human trafficking. We expect all suppliers to comply with our values.
We endeavour to establish and build long standing relationships with our local suppliers and clearly state our expectations of business behaviour.
In the rare instances where non-UK based suppliers are used, our point of contact is preferably a UK company or branch and we expect these entities to have suitable anti-slavery and human trafficking policies and processes. We expect each supplier to adopt at least ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all members of the supply chain or have systems in place to encourage the reporting of concerns and the protection of whistle blowers.
Since our last statement we continued to manage our processes:
We incorporate modern slavery checks into our new supplier onboarding process;
We have standard contract template to incorporate complying with the Modern Slavery Act 2015;
We review our list of suppliers to identify those that may pose a higher risk in relation to Modern Slavery;
We contacted higher risk suppliers to request policy compliance statements; and
Checks in our ongoing supplier health check process to ensure that this is monitored and regularly reviewed.
Find out about our approach
In accordance with the requirements of the Act, this statement can be found on our website and will be reviewed annually.
Edale is focused on monitoring, managing & caring for financial assets. We care about our world, long-term sustainability and contribution to a greater good. This policy aims to support Edale and its employees in performing their work and decision-making to improve our environment, reduce waste and enhance sustainability.
The below principles for sustainability are based on our code of conduct and guide behaviour in daily work and when making business decisions. We take these principles and other relevant environmental, social and governance principles into consideration when evaluating business risks and opportunities. Edale expects business partners and suppliers to adhere to these principles.
- We are committed to good corporate citizenship
- We are committed to human rights, labour rights and freedom
- We are committed to equal opportunities and diversity
- We are committed to caring for the wellbeing of our employees
- We are committed to ethics, honesty and sincerity
- We are committed to caring for the environment
- We reject bribery and corruption
We achieve these principles by:
- Operate an open door policy allowing employees to raise any concerns with line managers and HR
- Ensure employees are not victimised for coming to line managers and HR on topics they feel important.
- Ensure employee traditions and beliefs are respected, and encourage and promote diversity throughout the organisation.
- Open communication with employees to ensure all other policies are actively exercised.
- Maximise ‘outside of the box’ thinking and offer suggestions as to how any policy or process can be improved.
- Reward employees for hard work and innovative ideas that help in the running of the business.
- Adopting a flexible and agile working method to decrease our requirement for energy with shorter project timescales and operational processes.
For openness, this statement can be found on our website and will be reviewed annually.
We care about our world, long-term sustainability and contribution to a greater good.
To improve our environment and encourage environmental management of our resources we have the following policies.
To minimise waste
- Reduce printing to essential documents and holding only one printer in the office.
- Confidential paper is shredded and recycled through in our community recycling bins provided in the town.
- Recycling all used printer toners, and in turn, use previously recycled toners.
- Encouraging extra layers on staff to reduce heating and energy use.
- Utilising technology to further reduce any operational waste.
- Promote the recycling of waste both internally and amongst customers and suppliers.
Improve our environment
- Conducting the majority of the business electronically via email and system links to reduce printing and produce waste.
- Utilise the best technology to facilitate the most convenient appointments for clients, in order to reduce travel distances and lower emissions.
- Communicate all environmental aims and objectives to employees and external stakeholders.
- Encourage the use of healthy and personally powered travel to the office.
Additionally, to achieve our environmental goals Edale will:
- Build environmental and sustainable considerations into all aspects of our business and projects, with a full brief from the client to make sure that the needs of our end users are met.
- Reduce waste and actively seek opportunities to reuse and recycle material.
- Procure recycled resources, stationery and packaging and purchase fairtrade consumables and seek local suppliers where possible.
- Use energy efficiently.
- Gain & act upon feedback from our interested parties.
- Promote continuous improvement of environmental and sustainable performance.
- Educate and raise awareness of employees in environmental and sustainable issues and the environmental and sustainable effects of their activities.
- Share environmentally friendly reusable or recycled solutions with clients.
- Pass on our principles through our supply chain.
- Consider community activities that support sustainable causes.
- Communicate this policy to those working for Edale and engage in dialogue with our stakeholders regarding our commitment to the environment and sustainability.
- Maintain and review the management system to support the implementation of this policy.
- A commitment to leadership within the fields.
- Grow the business sustainably.
Edale is a progressive forward-looking and responsible organisation that aims to deliver a quality product and service in line with specified customer requirements and pre-determined compliance criteria while at the same time ensuring compliance with applicable legislation.
The below principles for quality control are achieved by the adoption of a system of procedures and smart working methods.
- Supply quality products and services by aiming to exceed the requirements of customers
- To maintain a policy that is appropriate to the purpose and context of the organisation and supports the strategic direction
- Adopt technologies that improve work efficiencies, engage clients, raise standards and create positive sustainable results
Achievement of this policy involves all staff, who are individually responsible for the quality of their work, resulting in a continually improving working environment for all. Through the quality commitment made to our clients before and during engagements, we work to continually improve the quality, skill, and competency of our services supplied. We will monitor our quality performance regularly and set objectives and targets for further improvement.
For openness, this statement can be found on our website and will be reviewed annually.
Duty of care
It is of crucial and vital importance to Edale to conduct its business in such a way that the health, well-being and welfare of all persons involved with, or affected by, our activities are safeguarded.
The duty of care policy is to ensure everyone is aware of their duty of care responsibilities towards their employees and persons affected by our activities.
Everyone has an obligation to perform his duties with a level of active concern, or lack of negligence towards avoidance of possible dangers, mistakes, pitfalls and risks.
Edale is responsible for a safe and secure workplace, free from hazards and situations that endanger our employees’ and persons involved with/affected by our activities. There is both an impact of work on mental and physical health as well as of mental and physical health on work. Furthermore, employee’s health and wellbeing can have a direct effect on work health, safety and business performance. We acknowledge that optimizing health and
welfare increases personal and team performances and diminishes failure costs.
- Promotes and encourages our employees to be healthy, fit for their jobs and motivated to perform.
- Ensures that our employees are well prepared with relevant and reliable (travel) health-promoting information, so they have appropriate knowledge to handle problems and assessing health, safety and
- Facilitates access to medical assistance and information, providing the employee with appropriate information on health and health related issues.
- Restates and actively monitors our social care and our focus on wellbeing of our employees.
- Takes signals of employees seriously, especially in understanding of exposure in case of crises and/or incidents.
Explanation of terms:
- Health: State of complete physical, mental, and social well-being, and not merely the absence of disease or infirmity. Health is a dynamic condition resulting from a body’s constant adjustment and adaptation in
response to stresses and changes in the environment for maintaining an inner equilibrium.
- Safety: Relative freedom from danger, risk, or threat of harm, injury, or loss to personnel and/or property whether caused deliberately or by accident. Having the opportunity (knowledge and resources) to watch
over one’s personal safety.
- Welfare: Availability of resources and presence of conditions required for comfortable living/working. Ensure circumstances that encourage employees to enjoy their job and to perform in a pleasurable working environment.
- Security: The prevention of and protection against (the consequences of) assault, damage, fire, fraud, invasion of privacy, theft, unlawful entry, war threat and other such occurrences caused by deliberate
This information security technology asset disposal policy is concerned with managing the secure disposal of equipment owned by the organisation but no longer required.
IT equipment such as computers, tablet computers, mobile phones and digital storage devices are vital and valuable assets to any modern organisation. The disposal of such equipment, due to its need for replacement or upgrade, or merely because it has become obsolete, surplus or redundant, is an issue because:
- IT equipment may contain data or information that must be protected
- the equipment represents an asset value
- the equipment may be reused or recycled
- the equipment must be disposed of safely according to the law and in an environmentally sustainable way.
The organisation aims to ensure that all of its IT equipment is managed effectively, including its disposal. The organisation understands that responsible IT asset management and disposal is essential for compliance with the Data Protection Act 2018.
In this organisation:
- this policy relates to technological equipment that can record or hold data, including:
- mobile phones
- multi-functional devices — printers/scanners
- fax machines
- USB memory sticks and external hard drives
- managers should identify all such devices and ensure that these are recorded in an asset register
- All staff and managers must follow the approved disposal/destruction methods for equipment to ensure that the risk of any loss of sensitive information or data breach is minimised all IT equipment that is identified for disposal should be accompanied by an Equipment Disposal Verification Form and an entry included in the asset register
- any IT equipment that has the potential to store sensitive data and which is no longer needed or has reached its “end of life” must have its data securely deleted/wiped and sensitive data deemed unreadable and unrecoverable before:
- redistribution or reuse within the organisation
- decommissioning and disposal
- all such equipment should be processed by a registered and approved contractor to securely remove any personal data
- when agreeing a contract with a professional equipment disposal service, the management of the home should obtain clear evidence of sufficient data security arrangements, including a written statement regarding confidentiality, destruction methods, and indemnity should the contractor fail to adequately destroy information; companies should comply with the ISO 27001:2013 IT Asset Disposal Standard
- IT and data equipment should not leave the organisation’s premises unless a chain of custody is established relating to the data contained within the device; this means establishing who is responsible for deleting the personal data contained on them
- deleting visible files, emptying files from the “Recycle Bin” of a computer or reformatting a drive are not considered a sufficiently secure method of wiping equipment, as data recovery software could be used by a new owner to “undelete” files or “unformat” a drive
- in the event that IT assets containing sensitive information are no longer needed by the care service and cannot be securely wiped, the equipment may need to be physically destroyed
- in all cases, the Equipment Disposal Verification Form should be completed and signed and kept with the asset register redundant IT equipment should not be donated to charities/schools, etc
- managers should ensure that any equipment that is leased has a data destruction clause written into the contract. Under such an arrangement, the supplier will ensure that data is wiped when it is returned.
Computer monitors, printers, scanners and fax machines are defined as hazardous waste due to the metals and chemicals used in their construction, and arrangements for their disposal must be handled in compliance with the organisation’s waste policies.
This organisation must comply with its requirements under the Waste Electronic and Electrical Equipment Directive (WEEE). Small amounts of obsolete or broken IT equipment that has been effectively wiped of any data or does not contain any data storage potential can be disposed of through the electrical waste stream at a Council site, or disposed of via the manufacturer or an electrical supplier.
IT equipment must never be disposed of through general waste routes. It is illegal to mix computer waste with general waste or to send untreated computer waste to landfill.
Staff and managers in the organisation are responsible for compliance with this policy. They are responsible for all IT equipment being appropriately data cleansed before disposal, and then for the appropriate destruction or disposal of equipment in compliance with waste regulations.
All managers and staff have responsibilities under the Data Protection Act 2018 to have appropriate security in place to prevent personal data held from being accidentally or deliberately compromised. This is relevant in the IT asset destruction and recycling processes.
This policy will be reviewed on an annual basis.
Last reviewed 5 January 2022
This summary statement describes our approach to safeguarding confidential data and information provided by our clients.
Our certification procedures aim to maintain the trust of our clients that commercially sensitive and other types of confidential information received, from them or from other sources, will not be revealed to unauthorised parties. Any staff, officers or contractors who are found in deliberate breach of our confidentiality rules will be removed from participation in the firm’s activities. Edale reserves the right to initiate legal action against any party in breach of a confidentiality agreement.
All Edale personnel must sign a confidentiality agreement with Edale where they agree to maintain complete confidentiality in terms of all client documentation, interviews, conversations, and any information related to the certification audit process pertaining to the organisation/source being evaluated. Auditors shall not distribute copies of any documents or reports, or discuss the content of these reports with other parties unless specifically authorised by Edale’s Director. All documents, data and other evidence provided to, or collected by, the auditor in conducting an audit must be returned to Edale or the client, or be destroyed. When in doubt about the confidential nature of information, auditors should refer questions or public requests for information directly to their supervisor.
The confidentiality principles do not apply to information which is already public and/or which is required to be publicly available regulation, law or contractual arrangements. Edale public information includes, but is not limited to:
- information found in the corporate registrar
- information provided by the client
- information about the client organisation, received from sources other than the client, which is not of a sensitive nature
- information that is available in the public domain.
When we are required by law or contractual arrangements to release confidential information, the client or person concerned will, unless prohibited by law, be notified of the information provided.
Edale aims to follow the best practices in relation to IT security and applies reasonable security measures to safeguard all electronic client information and communication.
This statement confirms Edale’s commitment to prevent money-laundering and the financing of terrorism in its business practices and transactions. Money laundering is the process of disguising the financial proceeds of crime to conceal their illegal origin. The financing of terrorism is any kind of financial support to those who attempt to encourage, plan or engage in terrorism.
Edale has established Know Your Counterparty (KYC) procedures to combat money laundering and the financing of terrorism. These procedures allow us to identify every organisation that we deal with, to understand the legitimacy of our business relationships and to identify and react to unusual or suspicious activity.
A director is responsible for the development and implementation of this policy and relevant procedures, and Edale commits to review our KYC policy and procedure every year.
To support our KYC policy and procedures, Edale has developed a KYC process which we use to perform checks on all our counterparties (this is our business partners: suppliers and customers) to collect relevant business information to identify risks of money-laundering.
By collecting and reviewing information, Edale commits to
• establishing the identity of our counterparties
• checking that our counterparties are not considered high-risk (this means checking whether counterparties are based in FATF high-risk jurisdictions, named on government-sponsored watchlists or international (UN) sanctions lists, or if they source from conflict-affected and high-risk areas (CAHRAs))
• maintaining an understanding of the nature and legitimacy of all our counterparties’ businesses
• maintaining KYC records for at least five years
• maintaining records of all single or linked cash (or cash-like) transactions above 10,000EUR
• monitoring transactions for unusual or suspicious activity – this type of activity will cause the counterparty to be considered high-risk.
If counterparties are considered high-risk for any reason (for example named on a sanctions list or engaging in unusual activity) we may:
• Cease trading with the counterparty
• Identify the beneficial owners of the counterparty and check whether the beneficial owners are on any watchlists or sanctions list
• Make an on-site visit to the high-risk counterparty.