Our policies on slavery and human trafficking
We have a zero tolerance approach to modern slavery and human trafficking, and as such we are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We are committed to acting ethically and with integrity in all our business relationships.
Our supply chains
We consider the risk of slavery or human trafficking within our supply chain to be low. In general, our supply chain involves regulated professional advisers, financial services firms and, in respect our IT infrastructure and operational requirements, leading services businesses who specialise in servicing asset managers. They are typically based in the UK, Channel Islands, western Europe and North America.
We have several policies and procedures in place to prevent financial crime generally and specifically to prevent:
- Money laundering
- Terrorist financing
- Sanctions compliance
- Bribery and corruption
Our recruitment processes are transparent and reviewed regularly. We communicate directly with candidates to discuss job opportunities and to confirm the details of any offer made. We have robust procedures in place for the vetting of new employees and ensure that we are able to confirm their identities and that they are paid directly into an appropriate, personal bank account. We have policies and procedures in place to ensure compliance with all human rights laws and UK employment laws and all staff are remunerated fairly and above the UK’s national living wage. We are satisfied that our employees are not exploited in any way.
Actions taken or planned
The MSA is a relatively new law and this is the first year in which we are subject to the MSA. Considering slavery and human trafficking risks are low to the business and our straightforward supply chains, our planned approach is one that is proportionate and risk based and will focus on:
- Key service provider on boarding – enhance checks and seek confirmation of their compliance with MSA.
- Due diligence – focusing on existing key service providers, assess and review their approach to combatting slavery and human trafficking.
- Training – develop staff training to include education on slavery and human trafficking