Our annual statement under The Modern Slavery Act 2015.
About us
The Financial Ombudsman Service was set up under the Financial Services and Markets Act 2000 to resolve individual disputes between regulated firms and eligible complainants quickly and with minimum formality.
The Financial Ombudsman Service is a company limited by guarantee. We have no share capital and no shareholders.
As a values-led organisation guided by a strong sense of fairness, we are fully committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain in line with the provisions of the Modern Slavery Act 2015 (‘the Act’).
Areas of risk
Due to the nature of our business, we consider the inherent risk of modern slavery and human trafficking occurring in our business to be low. Nonetheless, we take our responsibility to identify and effectively respond to any incidents of modern slavery and human trafficking very seriously.
We therefore have an effective safeguarding reporting mechanism, which allows our people to report concerns confidentially to HR about colleagues or customers so that appropriate action can be taken, such as informing the appropriate authorities or signposting vulnerable people to organisations who can offer advice, assistance and support.
Our people and suppliers
The Financial Ombudsman is classed as a "contracting authority" for the purposes of the Public Contracts Regulations 2015 and the Procurement Act 2023. We are bound to follow this legislation and, where appropriate, we use public sector frameworks, such as those set up by the Crown Commercial Service and other reputable purchasing bodies.
Approximately 80% of our expenditure relates to staff costs – including those relating to our property – with most of the remaining spend utilised via an appropriate competitive procurement process.
Where appropriate, we use our own standard contract templates, which include a Modern Slavery Act clause.
In addition to the scrutiny and support provided through these routes to market, our procurement policy sets out how we keep suppliers who fall within the remit of the Act, under review to ensure their Modern Slavery Act statements are up to date and published on their websites.
Our policies
We have several internal staff policies which are designed to reduce the risk of modern slavery and facilitate reporting of any potential slavery instances. For example:
- Our pay policy ensures all our staff, including any apprentices, are paid at least the Real Living Wage rates. We have robust controls in place to ensure that colleagues do not fall below the National Living Wage as a result of any salary sacrifice benefits, and we also have policies and processes to mitigate against the risk of excessive overtime.
- We also make sure that staff used through suppliers are paid at least the Real Living Wage rate.
- We have a speak-up policy which encourages people to report any aspect of dishonesty or unfairness. And we use an external whistleblowing provider, Safecall, to facilitate confidential and independent reporting.
- We are committed to diversity and inclusion, a workplace where everyone feels safe and supported regardless of protected characteristics, and where bullying or harassment is not tolerated.
- We have an unreasonable behaviour policy in case customers discriminate against staff or treat them without appropriate respect and courtesy (taking account of the nature of our work in handling contentious disputes).
- Our social responsibility and sustainability policy brings together a broad range of relevant commitments and practices – including in relation to our people, procurement, the environment, our carbon footprint, and the community.
Supply chain management
Our supply chains include suppliers of goods and services necessary for our daily operations. We are committed to working with suppliers who share our values and adhere to our high standards of ethical conduct. Our supplier management process includes:
- Utilising reputable public sector frameworks where available that align with the National Procurement Policy Statement, such as those set up by the Crown Commercial Service and other reputable purchasing bodies
- Screening potential suppliers for their commitment to combatting modern slavery and human trafficking
- Regular reviews of existing suppliers to ensure ongoing compliance
- Clear communication of our expectations, regarding modern slavery, to all suppliers
- Collaborating with suppliers to address any identified risks or issues.
Training and awareness
On an ongoing basis, we will continue to brief and train our procurement and resourcing teams on the importance of modern slavery and how to identify and respond to suspected incidents of modern slavery and human trafficking.
Across the organisation more generally, we will continue to make sure that staff are aware of our commitment to preventing acts of modern slavery and human trafficking, and the how they can raise any issues of concern. We will do this through all appropriate channels, including staff induction and training.
Approval
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes FOS’s modern slavery and human trafficking statement for the financial year ending 31 March 2026.
It was approved by the FOS Board on 23 March 2025, who review and update it annually.