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Modern Slavery Act 2015 ("MSA")

Modern Slavery Act 2015 ("MSA") Tenet Group Ltd and Subsidiaries (''Tenet") Slavery and Human Trafficking Statement for the Financial Year ending 30 September 2017

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Tenet has taken, and is continuing to take, to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern Slavery encompasses slavery, servitude, human trafficking and forced labour. Tenet has a zero tolerance approach to any form of modern slavery. We are 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.

Our Business

Tenet is a UK based company which operates a Financial Services Network through its subsidiary companies, TenetConnect Limited, TenetConnect Services Limited and Tenetlime Limited, all of which are authorised and regulated by the Financial Conduct Authority.

Tenet authorises individuals and corporate bodies to act as its Appointed Representatives in accordance with the Financial Services and Markets Act 2000.

Tenet is a service business within the financial services sector, providing amongst other things compliance and back office support to its Appointed Representatives who are authorised by us to provide financial advice and recommend financial products to retail customers within the United Kingdom.

Our Supply Chains

Our supply chains include suppliers of IT, telephone and office equipment, hotel conference facilities, insurance brokerage, professional services from our lawyers, accountants and other advisers.

Our suppliers are predominantly from the United Kingdom, Europe and the United States of America. Following a review of our suppliers, we determined that we are in a low risk industry as are the vast majority of our suppliers; therefore we do not consider the risk of modern slavery within our supply chain to be a significant risk.

We shall be contacting all relevant suppliers to ensure that they comply with the Modern Slavery Act 2015.

Due Diligence Processes for Modern Slavery and Human Trafficking

We have taken appropriate steps to help ensure that slavery or human trafficking is not taking place in our supply chains by reviewing existing business and supply chains and reviewing and revising our procurement processes to ensure that Modern Slavery does not exist.

Our procurement process includes steps to ensure that assurance is sought from relevant suppliers that they have anti-slavery and human trafficking policies in place and whether they are taking steps to prevent slavery and human trafficking in their respective business and supply chains. We will not support or engage suppliers where they/we are aware of slavery or human trafficking in such suppliers' business or supply chains or where a supplier has failed to give us the requisite assurances.

Our Working Practices

We allow all individuals who work or provide services to us the right to freely choose employment and the right to associate freely with other individuals. We offer an environment which is free from harassment and unlawful discrimination.

We ensure that our working practices are in accordance with the Equality Act 2010 and all employment legislation. We do not engage in forced or involuntary labour and have a zero tolerance approach to the same, meaning we do not tolerate any of our suppliers engaging in such conduct.

This statement is made under section 54(1) of the Modern Slavery Act 2015 and constitutes Tenet's slavery and human trafficking statement for the financial year ending 30th September 2017.

This statement has been approved by Tenet's Board of Directors and will be reviewed annually.

Signed by
MG Signature

Martin Greenwood
Chief Executive Officer

Date: 19th March 2018

Tenet Group Ltd - Gender Pay Gap Report

Tenet Group Ltd (the Tenet Group) is required by law to publish an annual gender pay gap report. This is its report for the snapshot date of 5th April 2017.

  • The mean gender pay gap for TGL is 28%.
  • The median gender pay gap for TGL is 32%.
  • The mean gender bonus gap for TGL is 11%.
  • The median gender bonus gap for TGL is 26%.
  • The proportion of male employees in TGL receiving a bonus is 87% and the proportion of female employees receiving a bonus is 85%.

Pay quartiles by gender

A 28% 72% Includes all employees whose standard hourly rate places them at or below the lower quartile
B 34% 66% Includes all employees whose standard hourly rate places them above the lower quartile but at or below the median
C 51% 49% Includes all employees whose standard hourly rate places them above the median but at or below the upper quartile
D 68% 32% Includes all employees whose standard hourly rate places them above the upper quartile

The figures set out above have been calculated using the standard methodologies used in the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017.

What are the underlying causes of the Tenet Group’s gender pay gap?

Under the law, men and women must receive equal pay for:

  • the same or broadly similar work;
  • work rated as equivalent under a job evaluation scheme; or
  • work of equal value.

The Tenet Group is committed to the principle of equal opportunities and equal treatment for all employees, regardless of sex, race, religion or belief, age, marriage or civil partnership, pregnancy/maternity, sexual orientation, gender reassignment or disability. It has a clear policy of paying employees equally for the same or equivalent work, regardless of their sex (or any other characteristic set out above).

Tenet Group is therefore confident that its gender pay gap does not stem from paying men and women differently for the same or equivalent work. Rather its gender pay gap is the result of the roles in which men and women work within the Company and the salaries that these roles attract.

Across the UK economy as a whole, men are more likely than women to be in senior roles, while women are more likely than men to be in front-line roles at the lower end of the organisation. In addition, men are more likely to be in technical and IT-related roles, which attract higher rates of pay than other roles at similar levels of seniority. Women are also more likely than men to have had breaks from work that have affected their career progression, for example to raise children. They are also more likely to work part time.

At Tenet Group we have four group Board Directors, three of whom are women. We are therefore bucking the trend in this regard compared to most organisations. We are therefore committed to reducing the gender pay gap over time, and are undertaking several initiatives currently to assist in this regard:

  • A Company-wide Talent Development Programme and a Management Development Programme with at least a 50:50 split of men and women to ensure the talented men and women at Tenet have equal opportunities to progress into the technical and leadership roles of the future.
  • An annual salary benchmarking exercise conducted by HR and the Board of Directors, to ensure salaries for roles are aligned across the individual departments.
  • A proactive approach to internal recruitment, with all vacancies being advertised internally, and a culture which encourages staff, both male and female, to seek out and apply for progression opportunities. 70% of our internal applicants are women.
  • A dedicated training budget available to all staff who wish to progress their learning and development, whether this be through the achievement of regulatory qualifications, or other professional qualifications such as AAT, CIMA and CIPD.
  • A revamped Appraisal Form and process which has a focus on career development and personal development, to ensure that every member of staff has the opportunity to discuss their career aspirations and opportunities to develop with their line manager each year.
  • A more flexible approach to work – if a role can be done from home, or on non-standard working hours, or a combination of home and office working, we will look to demonstrate flexibility in this regard wherever possible.

None of these initiatives will, of itself, remove the gender pay gap - and it may be several years before some have any impact at all. In the meantime, the Tenet Group is committed to reporting on an annual basis on what it is doing to reduce the gender pay gap and the progress that it is making.

I, Emily Blain, Head of HR & Central Services, confirm that the information in this statement is accurate.


MG Signature

Date: 5th April 2017