This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement (“Statement”) for the financial year ending 31 March 2015 for BlueBay Asset Management LLP (“BlueBay LLP”) and 31 October 2015 for BlueBay Asset Management (Services) Ltd (“BlueBay Services”) (together, “BlueBay entities”).
This Statement outlines BlueBay LLP and BlueBay Services policy, approach and status in relation to the Modern Slavery Act 2015.
Policy on slavery for the BlueBay entities
It is the policy of the BlueBay entities not to tolerate slavery and human trafficking practices within their business and supply chains. The BlueBay entities will take appropriate and reasonable measures to minimise the risk of this taking place in line with the nature of services provided to either firm.
This Statement, including the policy, approach and status will be reviewed annually and updated where necessary to reflect changes in circumstances and actual practice. The Statement will be approved by the members of BlueBay LLP and the board of directors of BlueBay Services and be made publicly available on the BlueBay entities’ corporate website.
BlueBay’s Modern Slavery Act approach
The BlueBay entities seek to implement an appropriate risk-based approach to minimise the risk of slave labour. This includes consideration of supply chains and, for BlueBay LLP, investment portfolios. Whilst it is acknowledged that risk factors are present in all global supply chains and across all sectors, it is believed that the BlueBay entities’ relative risk exposure to slavery, human trafficking and forced labour is low given the nature of business undertaken - financial services - and the skillset required in their supply chains; i.e. mainly skilled labour. This is as compared with other sectors1 or characteristics of supply chains2 which are considered ‘high-risk’.
However, the BlueBay entities will endeavour to include appropriate risk assessment, due diligence and management requirements designed to minimise the risk of slave labour within their employment, supply chain and investment management practices, as relevant to either firm.
The below details the scope of potential risk areas that the BlueBay entities will seek to manage:
Directly: The risk of employing a trafficked or exploited person within the business or through a subcontractor or recruitment agency. BlueBay staff are protected by relevant laws and regulations, which are fully reflected in the firm’s policies and procedures. Contractors and consultants employed by BlueBay LLP carry out highly skilled activities and are therefore deemed low risk. BlueBay Services has no staff or contractors, only a Board of directors and company secretary.
Indirectly: Through the supply chain (through illegal subcontracting or through use of products and materials which have been produced by people under conditions of forced labour), and/or via BlueBay LLP’s investment activities.
- Supply chain: The BlueBay entities have third party suppliers who either provide products and services for office buildings, as required (e.g. cleaning and security staff, utility suppliers etc.) or which enable the BlueBay entities to conduct their business (e.g. providers of financial data, office I.T. equipment & supplies etc.), or which the BlueBay entities use in the course of their business (e.g. travel and hospitality providers etc.).
- Investments: this risk exposure would potentially be through the investment portfolios managed by BlueBay LLP, as they may include debt exposure to issuers in sectors and markets (given the firm manages debt strategies spanning all sectors and all regions globally), where this can be a high-risk issue.
The BlueBay entities’ view on their slavery risk performance
Employment risk: To the best of its knowledge, BlueBay LLP is not in breach of employment legislation for any of the jurisdictions in which it operates.
Supply chain risk: The BlueBay entities do not believe that any of their suppliers engage in slave labour practices.
Investment risk: Given the absolute number of debt issuers BlueBay LLP manages exposure to, BlueBay LLP cannot rule out that at any point in time, one or more of the investment portfolios which it manages may have exposure to companies engaged in slave labour practices. Whilst BlueBay LLP has developed an ESG investment risk management framework to source intelligence on investment ESG risks, and monitor investment exposure, the process does not necessarily monitor for slave labour practices in a formal way.
General Counsel, and Designated Member
BlueBay Asset Management LLP
Chief Financial Officer, Director
BlueBay Asset Management (Services) Ltd
1 Such as agriculture, construction, domestic work, manufacturing, mining and utilities cited by the International Labour Office, 2012. ILO Global Estimate of Forced Labour
2 For instance when sourcing or other processes occur in countries with inadequate regulation and weak enforcement; industries which rely upon a low-skilled and temporary workforce with fluctuating seasonal work and/or those dependent on migrant workers; industries which are based on competitive pricing and where forced labour is used to minimise costs; where supply chains are complex, multi-tiered, global and span multiple countries. As cited by Finance Against Trafficking, November 2015. Forced Labour, Human Trafficking & the FTSE 100 – a Review of Company Disclosure and Recommendations for Investor Engagement.
Environmental, Social and Governance
To find out more about our approach to Environmental, Social and Governance (“ESG”) with regards to the investment process please refer to the ESG section of the site.
For information about BlueBay’s approach to its day-to-day activities with regards to staff, the marketplace, community and the environment, please refer to our Corporate Responsibility section.
This document is issued in the United Kingdom (UK) by BlueBay Asset Management LLP (BlueBay), which is authorised and regulated by the UK Financial Conduct Authority (FCA), registered with the US Securities and Exchange Commission, the US Commodity Futures Trading Commission (CFTC) and is a member of the National Futures Association (NFA). Past performance is not indicative of future results. All data has been sourced by BlueBay. To the best of BlueBay’s knowledge and belief this document is true and accurate at the date hereof. BlueBay makes no express or implied warranties or representations with respect to the information contained in this document and hereby expressly disclaim all warranties of accuracy, completeness or fitness for a particular purpose. This document is intended for “professional clients” and “eligible counterparties” (as defined by the FCA) only and should not be relied upon by any other category of customer. Except where agreed explicitly in writing, BlueBay does not provide investment or other advice and nothing in this document constitutes any advice, nor should be interpreted as such. No BlueBay Fund will be offered, except pursuant and subject to the offering memorandum and subscription materials (the "Offering Materials"). If there is an inconsistency between this document and the Offering Materials for the BlueBay Fund, the provisions in the Offering Materials shall prevail. You should read the Offering Materials carefully before investing in any BlueBay fund. This document does not constitute an offer to sell or the solicitation of an offer to purchase any security or investment product in any jurisdiction and is for information purposes only. No part of this document may be reproduced in any manner without the prior written permission of BlueBay Asset Management LLP. Copyright 2016 © BlueBay, the investment manager, advisor and global distributor of the BlueBay Funds, is a wholly-owned subsidiary of Royal Bank of Canada and the BlueBay Funds may be considered to be related and/or connected issuers to Royal Bank of Canada and its other affiliates. ® Registered trademark of Royal Bank of Canada. RBC Global Asset Management is a trademark of Royal Bank of Canada. BlueBay Asset Management LLP, registered office 77 Grosvenor Street, London W1K 3JR, partnership registered in England and Wales number OC370085.
Published September 2016