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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
Directions | Map +44 (0)20 7963 8100
Paris
Ruffer S.A.
103 boulevard Haussmann
75008 Paris, France
Directions | Map +33 (0)1 88 45 02 54
New York
Ruffer LLC
300 Park Avenue
New York NY 10022
Directions | Map +1 917 947 3003
Edinburgh
Ruffer LLP
31 Charlotte Square
Edinburgh EH2 4ET
Directions | Map +44 (0)131 202 1602
  • Home
  • Statement on slavery

Modern slavery and human trafficking

Introduction and purpose of this statement

This statement is made by Ruffer LLP and the subsidiaries within the Ruffer Group pursuant to section 54(1) of the Modern Slavery Act 2015. It covers the financial year ended 31 March 2026 and will be reviewed annually.

The Ruffer Group

The Ruffer Group structure and operational activities

Ruffer is a discretionary asset 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. It is authorised and regulated by the UK Financial Conduct Authority (FCA) and has 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, and is also the ultimate parent of Ruffer LLC (together the ‘Ruffer Group’). This statement is intended to apply to all entities across the Ruffer Group and describes the steps taken during the financial year to prevent modern slavery and human trafficking in the Group’s business and supply chains.

Ruffer’s supply chain

Ruffer does not tolerate modern slavery or human trafficking in its business or supply chains. Given the nature of its business as an asset manager, Ruffer considers the inherent risk of modern slavery within its direct operations to be low. Its supply chain principally comprises professional and corporate support services for its offices in London, Edinburgh, Paris (Ruffer S.A.), Guernsey (Ruffer (Channel Islands) Limited) and New York (Ruffer LLC). Ruffer recognises, however, that modern slavery risks can arise in a wide range of sectors and geographies and that a lower-risk profile does not remove the need for ongoing vigilance and proportionate due diligence.

Modern slavery risk is considered as part of supplier selection and onboarding. During the year, Ruffer’s critical suppliers were based in the UK, USA, Ireland, Luxembourg and Guernsey. Where concerns arise during onboarding or ongoing due diligence, Ruffer may request further information, seek contractual assurances, require remediation steps, or decide not to appoint, or to terminate, the supplier relationship.

Assessing and managing risk

Ruffer’s assessment of modern slavery risk takes into account the nature of the services being procured and the geographic location of suppliers, and any other indicators identified through onboarding or ongoing supplier review. Ruffer continues to keep its approach under review and to refine its supplier questionnaires and procurement processes so that modern slavery risk is considered on a proportionate and risk-based basis.

Due diligence

As part of its commitment to preventing modern slavery and human trafficking, the Group undertakes initial and ongoing due diligence for applicable third party service providers. During the due diligence process, third parties are asked for information about their approach to modern slavery, including a copy of their modern slavery statement where they are required to publish one.

Where a third party is not subject to a statutory obligation to publish a modern slavery statement, Ruffer may request information on the steps it takes to prevent slavery and human trafficking within its own business and supply chains. This information is considered alongside other relevant risk factors as part of supplier due diligence.

The Ruffer Group keeps its approach under review and enhances its third party assessment processes where appropriate in light of its evolving understanding of modern slavery risk.

Working for Ruffer

Ruffer seeks to ensure that the working conditions of its staff meet applicable legal and regulatory standards. The firm is accredited as a Living Wage Employer.

Our Staff Handbook sets out Ruffer’s zero tolerance approach to slavery and human trafficking and requires all staff to report any concerns, whether arising internally or externally. HR highlights this to new joiners as part of their induction.

Training

Modern slavery training is provided to new joiners as part of their governance induction to help staff identify indicators of modern slavery in relation to suppliers and other third parties. Staff are also reminded periodically of Ruffer’s zero tolerance approach to slavery and human trafficking and where to find further information. Ruffer will continue to review whether its training approach remains appropriate and proportionate to its risk profile.

Existing policies

Ruffer has policies and procedures that support the prevention of slavery and human trafficking, including –

  • an anti-money laundering policy
  • a whistleblowing policy
  • a third party risk management policy and guidance

Together, these policies and procedures help Ruffer to

  • check the source of the funds it manages and the clients it takes on, to help reduce the risk that it is used to launder the proceeds of crime, including proceeds linked to human trafficking and the exploitation of forced labour
  • encourage staff to report concerns or malpractice at the earliest possible stage
  • undertake due diligence on applicable third party suppliers and other relevant third party service providers.

Ruffer encourages members of staff to raise any concerns, including relating to modern slavery and human trafficking, at the earliest opportunity and Ruffer’s whistleblowing policy and guidance provide a framework for doing so. No concerns were raised through whistleblowing channels during the year.

Monitoring and effectiveness

Ruffer recognises the importance of monitoring the effectiveness of the steps it takes to address modern slavery risk. During the year, no instances of modern slavery were identified within Ruffer’s business or supply chains. Ruffer will continue to review the effectiveness of its controls, including through its supplier due diligence processes, staff reporting channels and periodic review of its policies, procedures and training.

APPROVAL

This statement was approved by the Partners of Ruffer LLP on 18 June 2026 and is signed on its behalf by a Designated Partner.

cb

Chris Bacon
Chief Executive

For and on behalf of Ruffer LLP
Designated Partner

London
Ruffer LLP
80 Victoria Street
London SW1E 5JL
Directions | Map +44 (0)20 7963 8100
Paris
Ruffer S.A.
103 boulevard Haussmann
75008 Paris, France
Directions | Map +33 (0)1 88 45 02 54
New York
Ruffer LLC
300 Park Avenue
New York NY 10022
Directions | Map +1 917 947 3003
Edinburgh
Ruffer LLP
31 Charlotte Square
Edinburgh EH2 4ET
Directions | Map +44 (0)131 202 1602