ACA Compliance Group (“ACA”) provides governance, risk, and compliance advisory services and technology solutions primarily to financial services firms. ACA’s products and services include regulatory compliance consulting services, Global Investment Performance Standards (GIPS®) compliance verifications and related investment performance consulting services, technology products, and cybersecurity and technology risk assessments. We partner with our clients to help them mitigate the regulatory, operational, and reputational risks associated with their business functions. Our clients include leading investment advisers, private fund managers, commodity trader advisors, investment companies, broker-dealers, and large domestic and international diversified financial institutions. ACA is committed to ensuring that there is no slavery or human trafficking within our business or supply chains. This statement sets out our current risk analysis and the steps that we have taken and those we plan to take to deliver on this commitment.
ACA is a global organization headquartered in New York, New York with offices in the United States and Europe. Among other locations, we maintain offices in San Francisco, Chicago, Boston, and London.
ACA Compliance Group currently is comprised of SIH ACA Topco, L.P. and a number of holding companies and operating subsidiaries, including the following UK-based entities: ACA Compliance (Europe) Limited; ACA Performance (Europe) Limited; Columbo TopCo Limited; Columbo MidCo Limited; Columbo BidCo Limited; Cordium Hold Co Limited; Cordium Inv Co Limited; Cordium Consulting Group Limited; Cordium Consulting Limited; Mirabella Financial Services LLP; and Mirabella Advisors LLP.
ACA considers itself to be at very low risk of encountering instances of modern slavery or human trafficking within our business and supply chains. According to the United Nations Office on Drugs and Crime, the sectors most at risk to involve human trafficking are agriculture, construction, apparel manufacturing, food service, domestic work, entertainment, and sex industries. The governance, risk and compliance sector in which we operate is generally not vulnerable to human rights violations. We are in the business of assisting companies with meeting their obligations to comply with applicable law, regulations, and industry standards. Most of the services we offer clients are professional services provided through ACA employees. We also offer software products and other technology solutions. We do not have offices or do business in any of the top ten countries identified in the 2018 Global Slavery Index as having the highest prevalence of modern slavery, nor in any of the 2018 Global Slavery Index top 10 countries with the highest vulnerability to modern slavery. Our global supply chain of human labor does not extend to countries where protection and regulation of modern slavery and human trafficking is severely limited. Further, our vendors and suppliers generally are limited to providing ACA infrastructure support, professional recruiting services, insurance and benefits.
Steps Taken Regarding Slavery and Human Trafficking
ACA first fell under the purview of the UK Modern Slavery Act in August of 2018 as a result of our acquisition of Cordium, a UK-based provider of governance, risk and compliance products and services. We sought legal advice regarding the requirements of the UK Modern Slavery Act to ensure compliance and received guidance on best practices to ensure slavery and human trafficking are not taking place within our business and supply chain. We published our first statement on slavery and human trafficking in January of 2019.
Currently, ACA has policies in place that set the tone and help create a culture of high ethical standards and compliance. We have a Global Employee Handbook that describes ACA’s commitment to a fair workplace, including policies on non-discrimination, non-harassment, anti-bulling, and non-retaliation, and to providing a safe, healthy, and productive work environment for its employees. The Global Employee Handbook also sets forth ACA’s values, which include dedication to maintaining an honest and ethical practice that is built upon integrity and an unwavering commitment to do the right thing. Importantly, as ACA personnel are our biggest asset, ACA conducts background checks on prospective and current employees and contractors. ACA also maintains an Enterprise Risk Management Policy, most recently updated in March of 2020, designed to detail the methods and processes used by ACA to identify, prioritize, mitigate, and manage risks relating to the achievement of ACA’s business objectives. The Enterprise Risk Management Policy requires ACA to have a Risk Committee, consisting of management-level employees who oversee and manage risk, and perform a risk assessment on at least a biennial basis.
We also launched a vendor management program in 2019 that, among other things, requires due diligence of vendors prior to their engagement to provide goods and/or services to ACA as well as ongoing due diligence of certain vendors. This program is currently undergoing a review and update that we anticipate will add further requirements with respect to engaging new vendors.
Further Steps We Intend to Take
ACA is committed to ensuring slavery and human trafficking are not taking place in our business or supply chains. In the coming months, ACA intends to take further steps across the organization toward ensuring that we meet this commitment, including:
- assessing ACA’s vendor management program, including how it can be leveraged to best to identify risks in our supply chain;
- continuing to incorporate contractual obligations into new vendor agreements to ensure that, going forward, our vendors are obligated to comply with anti-slavery requirements applicable to such vendors;
- producing an anti-slavery policy; and
- identifying opportunities to include anti-slavery matters in employee training programs.
This ACA Compliance Group Slavery and Human Trafficking Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year from January 1, 2019 to December 31, 2019. This statement was approved by the Board of Directors of SIH ACA Topco, L.P.
Shvetank Shah, Chief Executive Officer