What is Modern Slavery?

Modern slavery is an international crime, affecting an estimated 29.8 million slaves around the world. It is a growing global issue that transcends age, gender and ethnicities. It includes victims who have been brought from overseas and vulnerable people in the UK, who are forced to illegally work against their will across many different sectors. The Modern Slavery Act (MSA) is UK legislation which received Royal Assent in 2015. The serious criminal offences of slavery, servitude, forced or compulsory labour and human trafficking are brought together under one piece of legislation. The intention of the Act is to protect victims, bring perpetrators to justice and provide more effective tools for law enforcement.

In addition, the MSA places disclosure obligations on large companies with a turnover of over £36m and operations in the UK. Such companies must publish an annual statement setting out the steps they have taken to eradicate and prevent all forms of modern slavery in their business and supply chains. The reason behind this obligation is that large companies have significant resources and purchasing power, which gives them strong influence over the global supply chain, and therefore they can play a role in ending these appalling crimes. We welcome the Modern Slavery Act and its aim to eradicate forced labour and human trafficking.

Our policy

Marlborough Fund Managers Ltd, the immediate parent company Marlborough Group Holdings Limited and the ultimate parent company UFC Fund Management PLC (collectively “Marlborough”) as an organisation will seek to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. As part of a regulated sector, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking. Marlborough will not tolerate any form of modern slavery in its supply chains or operations.

Our structure

Marlborough is a UK-based financial services business which provides a range of financial products and services to personal, corporate and institutional customers. Marlborough Group employs approx. 130 employees across its operations. The organisation currently operates only in the UK.

Our supply chain relationships

Whilst recognising our statutory obligation to set out the steps we must take to ensure that modern slavery and human trafficking is not taking place in our supply chains, we must acknowledge that we do not control the conduct of individuals and organisations in our supply chains.

Principle risks

Marlborough operates no activities which are considered to be at high risk of slavery or human trafficking.

Our policies and processes

We have a number of policies and procedures in place that contribute to ensuring modern slavery does not occur in our business or supply chains.

–  Policies: HR is responsible for putting in place and reviewing policies which will be developed using appropriate resources.
• A Modern Slavery Policy
• Whistleblowing Policy
• Employee code of conduct
• Supplier/Contractor Code of conduct
• Temporary Agency workers policy

–  Risk assessments: the business considers our involvement as low risk as we have no overseas operations and our work is in the arena of financial services, but will carry out risk assessments were there is a perceived risk.

–  Investigations/due diligence/supplier audits: HR and other teams involved from time to time in procurement will be jointly responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.

–  Training: HR will ensure that any training or correspondence relating to modern slavery will be rolled out to staff, suppliers and contractors, so they can better understand and respond to the identified slavery and human trafficking risks.

Employment

Robust recruitment processes in line with UK employment laws, including: ‘right to work’ document checks; contracts of employment and checks to ensure everyone employed is 16 and above.

Marlborough offers market-related pay and reward, and prides itself on paying above the living wage to all members of staff, along with an enhanced benefits package, which is reviewed annually and linked to professional services firms’ benchmarks.

Employee training

We want to help our teams to understand more about this growing issue and how to report any suspicions they may have, whether in a business or personal context.

The organisation will ensure that any modern slavery training covers key areas on purchasing practices, assessing the risk of human slavery, identifying and reporting suspicions.

Key performance indicators

Going forward, we aim to:

–  continually develop employee training which outlines what modern slavery is, how to identify it and what individuals should do if they suspect there are any cases of slavery occurring.
–  continually monitor how our suppliers comply with our supplier Code of Conduct.

Marlborough takes responsibility for this statement and its objectives which will be reviewed and updated as appropriate.