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Modern slavery and human trafficking

Introduction and purpose
This statement is made with respect to the obligation of Ruffer LLP and its subsidiaries’ (the ‘Ruffer Group’ or ‘Ruffer’), whether incorporated in the UK or outside it, under section 54(1) of the Modern Slavery Act 2015 (the ‘Act’).

This statement is made for the financial year ending 31 March 2020 and will be reviewed for each subsequent financial year.

The Ruffer Group

Structure and operational activities

Ruffer is a discretionary investment manager for private clients, charities, pension funds and other institutional clients founded in 1994.

Ruffer LLP is a UK limited liability partnership owned and managed by its partners, and authorised and regulated by the FCA, with offices in London, Edinburgh, Paris and Hong Kong. It is the parent company of four wholly owned subsidiaries: Ruffer AIFM Limited, Ruffer SA, Ruffer (Asia) Limited and Ruffer (Channel Islands) Limited. This statement applies to all entities in the Ruffer Group.

Ruffer's supply chain

Ruffer does not tolerate modern slavery and human trafficking, in any form, in its supply chain or its business activities. Ruffer’s supply chain is limited. Ruffer does not produce, manufacture or retail any physical goods and as such has no supply chain related to such activities. It does, however, use routine services for the support of its offices in London, Edinburgh, Paris and Hong Kong including cleaning, catering and IT technical support. Ruffer regularly reviews its suppliers and their recruitment policies and has thus far found no cause for any concern with engagement from suppliers remaining high.

Working for Ruffer

Ruffer regards itself as a supportive and caring employer, providing a wide range of benefits to its employees. Ruffer ensures the working conditions of its staff meet all the required standards. Additionally, Ruffer promotes the health and wellbeing of its staff, and actively encourages a work-life balance. The firm is accredited as a living wage employer.

Existing policies

Ruffer has a number of policies which it believes to be relevant in the prevention of slavery and human trafficking. These include –

  1. an anti-bribery code of conduct
  2. an anti-money laundering policy and
  3. a whistleblowing policy

The above policies ensure that Ruffer checks the sources of the funds it manages and the clients it takes on to ensure that Ruffer is not used to launder the proceeds of criminal activity, which includes that obtained through human trafficking and the exploitation of slave labour. Additionally, Ruffer encourages its staff to report any malpractice at the earliest possible stage.

Responsible investment

At Ruffer we interpret responsible investment as the incorporation of environmental, social and corporate governance (ESG) considerations throughout our research and investment processes, while behaving as active stewards of our clients’ assets. Our specialist responsible investment team partners closely with the analysts in our research team to identify and evaluate the material risks and impacts to the environment and society that could arise as a result of a company’s operations. The risks associated with weak corporate governance practices are also considered. We recognise that ESG considerations are important drivers of investment performance, representing both sources of value and investment risks. Therefore, incorporating these considerations into our investment approach forms an essential part of our responsibility to our clients. We believe that investing responsibly will lead to better long-term outcomes for our clients. 

Ruffer is a signatory to the Principles for Responsible Investment. To act as responsible stewards of our clients’ assets, we use our professional judgement to determine when to engage and how to vote at shareholder meetings to best protect the economic interest of our clients while being cognisant of the impact on all stakeholders. Ruffer offers clients the possibility of incorporating their values and beliefs into our investment approach. We use a third party ethical screening and research provider who offers a wide range of exclusion criteria to ensure our clients’ preference are met.

The future

This is Ruffer’s fifth statement pursuant to the Act. Ruffer will continue to review and, where appropriate, update it annually. 


This statement was approved by the Partners of Ruffer LLP.

Myles Marmion, Chief Financial Officer
For and on behalf of Ruffer LLP
Designated Partner

80 Victoria Street
London SW1E 5JL
31 Charlotte Square
Edinburgh EH2 4ET
103 boulevard Haussmann
75008 Paris, France