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 2018 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 or 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 partners, and authorised and regulated by the FCA, with offices in London, Edinburgh and Hong Kong. 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. 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.
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 director 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 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.
This is Ruffer’s third 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