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Statement on slavery

Statement on modern slavery and human trafficking

Introduction and purpose of this statement

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 2017 and will be reviewed for each subsequent financial year.

Ruffer does not tolerate modern slavery and human trafficking, in any form, in its supply chain and its business activities.

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 members, 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 International Limited, Ruffer (Asia) Limited and Ruffer (Channel Islands) Limited. This statement applies to all entities in the Ruffer Group.

Ruffer’s supply chain

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 and Hong Kong including cleaning, catering and IT technical support.

Prior to the publication of this statement, Ruffer undertook a review of the recruitment and employment practices of its most frequently used suppliers with contracts of a value over £50,000 per annum. Additionally, for Ruffer’s catering supplies, our supplier’s sources were reviewed. In all cases, recruitment screening was robust with due regard to the prevention of slavery and supplies are sourced predominantly from UK providers. Ruffer is continuing a programme of rolling due diligence on its service providers and suppliers which has included reviews, where possible, of any modern slavery statements made by them. Engagement from suppliers remains high.

Working for Ruffer

Ruffer prides itself on being 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. Since Ruffer’s statement, the firm has been 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 –

  • an anti–bribery code of conduct
  • an anti–money laundering policy and
  • 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.

Environmental, social and governance

Ruffer actively seeks to integrate environmental, social and corporate governance (ESG) issues into its investment process and in doing so employs a dedicated manager for responsible investment and ESG issues. The firm is also a subscriber to the UN Principles for Responsible Investment. Ruffer believes that ESG factors are often a signal of management quality, particularly over the long–term, and good practice in this regard is likely to be consistent with good corporate performance. As such, ESG factors are considered alongside other factors when an investment decision is made. Additionally, Ruffer engages with the management of investee companies directly via one–on–one meetings at Ruffer’s offices and will vote on AGM or EGM resolutions where either Ruffer’s clients have a material interest in the company or the value of the holding is material to Ruffer clients.

Ruffer also considers, and agrees where appropriate, to requests from clients to impose restrictions on certain types of investment and screens companies to ensure their activities are consistent with clients’ specific investment restrictions.

The future

This is Ruffer’s second statement pursuant to the Act. Ruffer will continue to review and, where appropriate, update this statement annually and build upon the progress we have made already.

Approval

This statement was approved by the Members of Ruffer LLP.

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

Jonathan Ruffer

Chairman

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