Ex-offenders Policy
Last Updated: August 2026 A transparent and fair framework regarding the recruitment and ongoing employment of individuals with criminal records.
1. Commitment to Equal Opportunities
Sustainable Impact Capital Limited is deeply committed to the principles of equal opportunity, diversity, and inclusion. We firmly believe that everyone deserves a fair chance to build a meaningful career. We do not discriminate unfairly against any subject of a criminal record check on the basis of a conviction or other information revealed. We actively promote equality of opportunity for all individuals with the right mix of talent, skills, and potential, and we welcome applications from a wide range of candidates, including those with criminal records.
2. Objective and Fair Assessment
Having a criminal record will not necessarily bar an individual from working with us. The decision to employ an individual with a criminal record will be made based on an objective, fair, and rigorous assessment. This assessment will carefully consider the nature of the position being applied for, alongside the circumstances, background, and relevance of the specific offenses. We evaluate the time that has elapsed since the offense, the age of the individual at the time of the offense, and any evidence of rehabilitation or positive changes in behavior.
3. FCA Regulatory Requirements
As a firm authorized and regulated by the Financial Conduct Authority (FCA), many roles within Sustainable Impact Capital Limited require individuals to be assessed as 'fit and proper' under the Senior Managers and Certification Regime (SM&CR). For these specific roles, which involve a high level of trust, direct handling of client funds, or access to highly sensitive financial data, we are legally required to conduct comprehensive background checks, which may include standard or enhanced Disclosure and Barring Service (DBS) checks. Where a role is subject to these requirements, it will be clearly stated in the job advertisement and at the earliest stage of the recruitment process.
4. The Recruitment Process and Disclosure
We request that all applicants applying for positions that are exempt from the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 disclose all convictions, cautions, reprimands, or final warnings that are not 'protected' as defined by the Act. For non-exempt roles, we only require the disclosure of 'unspent' convictions. We encourage open and honest discussions about any relevant criminal history during the interview stage, providing candidates with the opportunity to contextualize their past experiences.
5. Handling of Disclosure Information
Any disclosure information provided by a candidate or obtained through a DBS check is handled in the strictest confidence. It is only seen by those specific individuals within the HR department and senior management who directly need to see it as part of the recruitment and risk assessment process. We guarantee that this information will not be shared with the wider team or external parties unless strictly required by law or regulatory obligation.
6. Data Security and Record Retention
We strictly adhere to the guidelines set out by the DBS regarding the secure storage, handling, use, retention, and disposal of certificate information. Once a recruitment decision has been made, we do not keep certificate information for any longer than is absolutely necessary, which is generally for a period of up to six months. This allows for the consideration and resolution of any disputes or complaints. After this period, the information is securely destroyed.
Questions regarding this policy?
For detailed inquiries or to request further information regarding our institutional policies, please contact our compliance team at compliance@sic-limited.com.