EOS Investment Management Ltd part of the EOS IM Group

This Modern Slavery and Human Trafficking Statement (the “Statement”) has been produced by EOS Investment Management Ltd (“EOS IM” or the “Firm”), a UK fund management company that is authorised and regulated by the Financial Conduct Authority (“FCA”) in the UK and forms part of the EOS IM group of companies (“EOS IM Group” or “we”). The Firm’s registered office is at 67 Grosvenor Street, Mayfair, London W1K 3JN, United Kingdom.

The UK Modern Slavery Act 2015 (the “UK Act”) came into force for UK entities on 29 October 2015. The concept of “modern slavery” encapsulates behaviours such as forced, compulsory or coerced labour, deprivation of personal freedom or human trafficking and facilitating the movement of people for exploitation. The UK Act creates additional criminal offences for people that commit such acts and seeks to establish transparency in supply chains of commercial organisations.

Although the Firm is not required under the UK Act to issue a Statement, it believes such a declaration is appropriate and of sound practice, demonstrating our commitment to human rights. This Statement is made in alignment with Section 54 of the UK Act and sets out the steps that the Firm has taken and continues to take to ensure that modern slavery or human trafficking are not taking place within the Firm’s business or supply chain.

The Firm is a signatory of the United Nations Principles for Responsible Investment (UN PRI) and it is committed to provide its services according to the highest ethical and professional standards taking its responsibilities to its clients, underlying investors in funds, people, suppliers, and the communities in which it does business seriously. The Firm and the EOS IM Group align to the wider rights objectives as set out in the EU Taxonomy Article 18, including the OECD Guiding Principle for multinational enterprises. The Firm constantly take a responsible approach in its business activities, considering environmental, social, and economic factors along the entire value chain, including taking steps to address and mitigate the risks of any modern slavery or human trafficking encouraging counterparties to do so as well. We strong believe that collaboration and sharing of best practices are essential to raise awareness and prevent modern slavery and human trafficking in businesses and supply chains.    

This Statement, form integral part of the Modern Slavery Policy which in turn is an integral part of the Firm’s overall social, environmental and governance approach and culture, created to deliver on its commitments, and it is explicitly included in the ESG Policy (“ESG Policy”). This includes acting responsibly, maintaining appropriate standards as well as the condemnation of forced and compulsory labour, encompassing child labour. As an integral part of this, the responsible supply chain management represents one of the Firm material topics.  
The Firm has a zero-tolerance approach to the participation in, facilitation of or interacting with parties that are in or are connected to any form of modern slavery or human trafficking.  As such, in the event of modern slavery being identified, the Firm will take the appropriate and affirmative action.
The supply chain pertaining to the EOS IM Group’s fund management business encompasses service providers that one would typically expect for a financial services business. The Firm aims to deal with reputable and well-established suppliers of goods and services and carries out risk based due diligence on suppliers. The key categories of supplier within our firm’s supply chain include, without being limited to, professional services (i.e. accountants, lawyers, advisors, etc.), IT consultancy and software services, IT hardware, software, and telecom services, data services, banking services, property and facilities services, hotel and catering services, and travel services (i.e. airlines, public transport, etc.).

As part of the initiative to identify and mitigate the risk of modern slavery and human trafficking in the supply chain, we periodically review the list of suppliers. This assessment due diligence may include consideration of (i) nature of services, (ii) reputation in the market, and (iii) supplier’s internal policies and procedures in relation to modern slavery and human trafficking.

The Firm and the entities across the EOS IM Group, have incorporated human rights into their policies, in a manner that is consistent with international human rights principles and applicable laws in the countries with which they operate. The majority of individuals at EOS IM are employed directly and on a permanent basis primarily office style-based roles. All employees who join the Firm are subject to checks to ensure they are genuine applicants and have the right to work in the relevant jurisdiction. These include verification which may encompass checks covering identity, references, evidence of qualifications, and criminal and financial checks. This approach is designed to proactively prevent involvement in and/or facilitation of human rights abuses, as well as create a positive working environment, optimising the skill sets to the benefit of the funds. Management is committed to ensuring that all directly employed and contracted employees receive fair treatment and appropriate remuneration for the job they perform. Staff are encouraged to report unprofessional behaviours, potential illegal activities and/or other suspicious matters, through the Speak-up / Whistleblowing policies. This includes concerns relating breaches of human and rights, which would include modern slavery, human trafficking and child labour.

This approach has the purpose to ensure that staff are aware of the importance of ESG and the approach taken to prevent human rights abuses. This includes the responsibilities and standards expected of staff and other individuals representing the EOS IM the entities in the EOS IM Group. Indeed, the Firm and wider EOS IM Group provide training programmes which are designed to encompass ESG issues and policies, as well as human rights. This is intended to ensure full understanding of the requirements placed upon the Firm and its staff, including the potential risk for modern slavery to occur.

This Statement complies with the governance framework applied by EOS IM and the EOS IM Group, along with its legal, regulatory and ethical obligations.

This Statement was approved by the Board of Directors.