Modern Slavery and Human Trafficking Statement 2022

Alfa Financial Software Limited (“the Company”), a wholly owned subsidiary of Alfa Financial Software Holdings PLC (“Alfa”), is committed to continually improving its practices to combat slavery and human trafficking. Alfa and the Company has zero tolerance of modern slavery, in all its different forms, both in its business and in its supply chains. 

This is the Company’s seventh Modern Slavery Statement in response to the Modern Slavery Act 2015 (‘the Act’). This statement sets out the steps taken during the financial year ended 31 December 2022 by the Company to prevent modern slavery and human trafficking in its business and supply chains. 

Alfa is not aware of any slavery or human trafficking in any part of our business or supply chain, and no issues were raised during the year ended 31 December 2022. Therefore, and taking into account the nature of Alfa’s business, we consider the overall risk level among our supply chains to be low. 


The term modern slavery is a broad one and considers someone to be in modern slavery if he or she is in forced labour, servitude, slavery, human trafficking, debt bondage, forced or servile marriage, descent-based slavery or child exploitation. It is a global and growing issue. No sector or industry is exempt from the potential for modern slavery. The Company has zero tolerance of modern slavery in all its forms and has a responsibility to understand the risks in its business and supply chain and manage those risks accordingly. 

The Company’s modern slavery statement is made pursuant to section 54(6) of the Act and constitutes the Company’s anti-slavery and human trafficking statement for the financial year ending on 31 December 2022. The Company aims to be transparent about its approach to modern slavery and this statement outlines its approach to prevent modern slavery and Human trafficking in its supply chain or in any part of the business. 

Our commitment to the principles of the Modern Slavery Act 2015

The Company remains committed to managing and mitigating the risk of modern slavery or human trafficking taking place anywhere in the business, or in any of its supply chains. In 2023, we will continue to build on what we have learnt, increase our awareness of areas of high risk and deepen understanding of modern slavery across the business. 

As a software company, the Company does not use an extensive range of local or international suppliers where modern slavery or human trafficking would generally be a material risk. The Company is committed to acting ethically and with integrity in all of its business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking does not take place anywhere in the business or supply chains. Due to the nature of the Company, we have identified that the overall risk to the facilitation of modern slavery was low, due to its limited supply chain.

Our commitments are reflected in Alfa’s Group-wide policies, which set the standard of expected business behaviour for all employees. Relevant policies include:

  • Ethics and Code of Conduct Policy, which details the policies in relation to ethics, anti-corruption and bribery.
  • Our staff handbook, which aims to foster a workplace environment that is fair, open and respectful, and one that promotes and protects the rights and dignity of all employees;
  • Whistleblowing Policy, encourages employees to speak up and report any potential signs of wrongdoing or concerns about illegal activity.
  • Harassment Policy to ensure our employees have a safe place of work, free from any form of bullying or harassment.
  • Diversity and Inclusion Policy, ensures that we foster a fair and inclusive workplace, where our people are valued, their differences are respected, and discrimination is eliminated.
  • Recruitment Policy, provides equality and fairness for all those who apply to us for employment and all those in our employment and not to discriminate in any circumstance.

The Company reviews its procurement processes and associated policies to ensure that there is an appropriate approach taken to managing modern slavery in its supply chain and to set out its expectations of its supply chain partners.

Due diligence processes for slavery and human trafficking

To ensure a high level of understanding of the risks of modern slavery and human trafficking in the supply chains and to the business, the Company ensures staff who are directly involved in procurement activity are aware of and follow modern slavery procurement guidance on GOV.UK

Effectiveness in combating slavery and human trafficking 

The Company understands that it has a responsibility to continue to assess and mitigate the risk of modern slavery in its supply chain in the long term. While the Company continues to make progress in this area, future developments will be to update understanding and reassess the nature of that risk, assessing whether policies and controls are appropriate and also to ensuring that controls to manage any risk are operating effectively if that risk arises. It is expected that the nature of the risk may change over time and ongoing vigilance will be required.

Alfa remains committed to running its business responsibly and, in order to maintain visibility across its supply chains, Alfa will introduce a Supplier Code of Conduct in 2023 to address, among other things, issues of child labour, compulsory labour and human trafficking. Where not already addressed, adherence to the Code is included in commercial agreements, either when Alfa enters into contracts with new suppliers and/or when contracts with existing suppliers are renewed.

In addition, Alfa will require suppliers to complete a Supplier on-Boarding questionnaire as part of its due diligence procedures in relation to existing and potential suppliers. The results of each questionnaire are reviewed and stored securely upon their return.

Alfa is committed to only working with suppliers who take their obligations towards modern slavery as seriously as we do and who will adhere to the tenets of our Supplier Code of Conduct.

To assess effectiveness of controls to ensure modern slavery does not exist within any of the business activities, the Company aims to, in 2023:

  • Launch our new Supplier Code of Conduct, and Supplier On-Boarding process, which requires suppliers to confirm they have in place or adhere to Modern Slavery legislation;
  • Continue to raise awareness of the signs of modern slavery and human trafficking and the reporting mechanisms if a case of slavery or human trafficking is suspected; and
  • Monitor government and other perspectives and approaches to modern slavery and actively consider their applicability to the Company.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement for the financial year ending 31 December 2022.

Signed by Andrew Denton on behalf of Alfa Financial Software Limited.

Date: 26 April 2023

See the 2021 statement.