Modern Slavery Statement 2017

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Introduction from Craig Newman, CEO

We are an asset management business, specialising in the long term investment of our client’s money. We are authorised and regulated by the Financial Conduct Authority.

This page sets out our ongoing commitment as a responsible business to ensure that modern slavery and human trafficking is eradicated. This is our slavery and human trafficking statement for the purposes of section 54(1) of the Modern Slavery Act 2015 (MSA). This statement explains the steps we are taking and the processes we have already implemented to combat slavery and human trafficking.

The annual statement covers the period ending 31 March 2017 and was approved by the management board.

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
  • Fraud
  • 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

Woodford Investment Management Ltd is authorised and regulated by the Financial Conduct Authority (firm reference number 745433). Incorporated in England and Wales, company number 10118169. Registered address: 27 Old Gloucester Street, London, WC1N 3AX.

© 2020 Woodford Investment Management Ltd.
All rights reserved.

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