Modern Slavery and Human Trafficking Statement

Creation is a UK-based subsidiary of BNP Paribas, a leader in global banking and financial services registered in France. As a global responsible investment bank, BNP Paribas is committed to driving out acts of modern day slavery and human trafficking within its business and supply chain, and expects the same from suppliers and partners. This commitment is in part based on the International Labour Organisation’s fundamental principles of rights to work which we uphold, including:

  • Elimination of forced and compulsory labour;
  • Abolition of child labour; and
  • Elimination of discrimination in respect of employment and occupation.

Creation is a member company of the BNP Paribas group and acknowledges responsibility to comply with the UK Modern Slavery Act 2015. This statement outlines the policies and procedures Creation has in place to mitigate and manage the potential risk of modern slavery and human trafficking in its operations and supply chains.

Policies

Creation has reviewed its policies to ensure that modern slavery and human trafficking receives increased focus. We have developed a specific Modern Slavery policy which describes how Creation tackles any risks and deals with any issues related to modern slavery and human trafficking across its business and supply chains. It states that Creation has a zero-tolerance approach to modern slavery and human trafficking. It further states that we are committed to act ethically and with integrity in dealing with our partners, suppliers and customers, and to implement systems and controls that effectively ensure modern slavery and human trafficking is not taking place anywhere in our business or that of our supply chain.

Other Group and Creation policies are in place which also contribute to tackling modern slavery and human trafficking as part of our business operations. These include:

  • Modern Slavery policy;
  • Whistleblowing Policy;
  • Code of conduct;
  • Supplier Code of Conduct; and
  • Statement of BNP Paribas on human rights

Identifying and managing risks

Creation has carried out a detailed review with external advisors of its supply chains and procurement processes to identify where there may be risks of modern slavery or human trafficking. This showed that overall there is a low risk as the company’s activities do not directly involve operations where modern slavery or human trafficking are known to occur.

However, some categories of products and services provided by third party suppliers may present risks in their supply chains. We have identified those categories and are carrying out additional due diligence, including extending our supplier questionnaires to cover the risks of slavery and human trafficking and requesting information about the supplier’s own policies and mitigation processes.

Suppliers must also sign up to our code of conduct which prohibits forced or child labour and we continue to embed clauses within our supplier contracts to ensure that the supplier signs up to and agrees with our policies in all legal contracts.

Employees and suppliers are encouraged to raise any concerns about any issues or suspicion of modern slavery within the Creation business operations or any tier of our supply chain as soon as they become aware of it. Our whistleblowing policy ensures that anyone raising such concerns will not suffer dismissal, disciplinary action, threats or other unfavourable treatment as a result.

BNP Paribas and Creation have extensive and rigorous risk management and compliance processes in place in the company. Modern slavery and human trafficking risk is included in these risk management and compliance processes, and will be managed and monitored on an ongoing basis by the company’s risk function in conjunction with other relevant business functions.

Awareness and Training

As part of Group-wide compliance processes, a human rights training course is available to Creation employees to raise awareness of how human rights issues, including modern slavery and human trafficking, may impact BNP Paribas’ business operations and what role employees play in mitigating the risk. Staff involved in procuring products and services in those categories where there is a potential supply chain risk are also being provided with additional guidance and training.

This statement is owned by the Chief Executive Officer and approved by the Board of Directors. It is reviewed annually and published on the Creation website.

Date: 30/06/2017

Stephen A R Hunt

Chief Executive Officer