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Ruffer provides investment management services for institutions, pension funds, charities, financial planners and individual investors.
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London
Ruffer LLP
80 Victoria Street
London SW1E 5JL
Paris
Ruffer S.A.
103 boulevard Haussmann
75008 Paris, France
New York
Ruffer LLC
300 Park Avenue
New York NY 10022
Edinburgh
Ruffer LLP
31 Charlotte Square
Edinburgh EH2 4ET
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  • Statement on slavery

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 2024 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 and Edinburgh. It is the parent company of four wholly owned subsidiaries: Ruffer AIFM Limited, Ruffer S.A., Ruffer (Channel Islands) Limited and Ruffer IH Limited. In addition, Ruffer LLP is the ultimate parent of Ruffer LLC. 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, and the nature of our business is such that we have assessed that the risk of slavery or human trafficking within our supply chain is low. 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, Guernsey and New York and our supply chain is predominantly based in those locations. However, we also have a number of service providers globally.

Due diligence

During the tender process we ask suppliers for evidence of their modern slavery policy or statement if they are required to produce one. In addition, we have recently reviewed and updated our supplier due diligence questionnaire to request that suppliers who are not required to produce a statement explain how they are taking steps to prevent slavery and human trafficking within their own business and their supply chains.

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.

Training

In 2024 Ruffer is rolling out training sessions on slavery and human trafficking for all staff with procurement responsibilities. Modern slavery training will also be provided to all new joiners as part of their Governance induction to encourage all staff to be aware of and able to identify the signs of modern slavery in relation to clients, suppliers and other third parties. In addition, Ruffer has made available to all staff a voluntary online modern slavery training module which they will be encouraged to complete annually, and will count towards their continuing professional development requirement.

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
  3. a whistleblowing policy and
  4. a DE&I (diversity, equity and inclusion) strategy

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. Ruffer encourages its staff to report any malpractice at the earliest possible stage. In addition, Ruffer believes that an inclusive and diverse environment supports good judgement and decision making and has a DE&I strategy in place to help support equality in the workplace and assist Ruffer in putting its diversity and inclusion commitments into practice.

Responsible investment

At Ruffer, we incorporate ESG considerations into our investment approach, analysing both risks and opportunities. We are committed to being good stewards of our clients’ assets. We believe active stewardship can lead to lasting and meaningful change; therefore, we engage with companies on a range of ESG topics including Modern Slavery, and vote on the total shareholding of the companies held within our core funds.

Our Responsible Investment Policy is based on the twin pillars of integration and stewardship. Integration refers to the incorporation of potentially material ESG factors into our fundamental analysis of individual securities. Stewardship has two components: engagement with companies to improve our understanding of material ESG risks faced and to encourage or challenge how relevant ESG issues are considered; and proxy voting to represent the interests of our clients, further the aims of our engagements and, where appropriate, show support for management.

We are signatory of the UK Stewardship Code and the Principles for Responsible Investment. We are a member of the Institutional Investors Group on Climate Change. We joined the Net Zero Asset Managers initiative (NZAM) in March 2022 and set our targets in March 2023. When setting our NZAM targets, we have focused on ensuring they are consistent with our investment strategy and fiduciary duty and, support real world emissions reduction. We publish an annual Stewardship Report and a Taskforce for Climate-related Financial Disclosures report.

We source ESG research and data from MSCI ESG Research and, ISS Governance provides specific proxy voting research and recommendations. We offer clients ethically screened products. We also utilise data, frameworks and research from such organisations as the Science-Based Targets initiative, CDP and the IFRS Foundation.

The future

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

Approval

This statement was approved by the Partners of Ruffer LLP.

cb

Chris Bacon
Chief Executive

For and on behalf of Ruffer LLP
Designated Partner

London
Ruffer LLP
80 Victoria Street
London SW1E 5JL
Paris
Ruffer S.A.
103 boulevard Haussmann
75008 Paris, France
New York
Ruffer LLC
300 Park Avenue
New York NY 10022
Edinburgh
Ruffer LLP
31 Charlotte Square
Edinburgh EH2 4ET