Border to Coast Pensions Partnership Limited
Modern Slavery Statement 2024
Modern slavery is an umbrella term encompassing slavery, servitude, forced or compulsory labour and human trafficking. Victims of modern slavery are unable to leave their situation of exploitation – controlled by threats, punishment, violence, coercion and deception. They are commodified for the purpose of exploitation and financial gain. Slavery violates human rights, denying people of their right to life, freedom and security.
As both a business and as an investor, we recognise the importance of human rights issues globally, including modern slavery, and increased stakeholder scrutiny on the global financial system to manage capital in a way that supports sustainable and inclusive economies.
Due to the nature of our business, we consider ourselves at low risk of being directly involved in facilitating modern human slavery. However, we recognise that we play a role in helping to eliminate modern human slavery, wherever possible through our operations and our investments.
Policies relating to the management of modern human slavery
We have a range of policies and procedures which underpin our commitment to ensure there is no modern slavery or human trafficking in our supply chains or in any other part of our business. These are regularly reviewed to ensure relevance, compliance and adherence with good practice. The policies include:
- Procurement and outsourcing – how we manage suppliers and our supply chain
- Values and behaviours – sets out how we expect our people to operate
- Conduct – our approach to ensuring we maintain good conduct in our business
- Recruitment –the process for attracting and selecting employees to ensure a fair and consistent approach is taken
- Health, safety and wellbeing – our approach provides rounded support for colleague wellbeing with attention to individual needs
- Diversity, equality and inclusion – our approach to ensuring diversity, equality and inclusion are considered in everything we do
- Fair treatment at work – we pay attention to day-to-day work, guard against harassment, bullying and allow for colleagues to raise grievances relating to unfair treatment at work
- Responsible investment – our policy outlines our approach as a long term responsible investor
- Corporate social responsibility – guiding how we operate over and above legal and regulatory requirements, recognising that doing so promotes the confidence of stakeholders and the long-term sustainability of the business.
Our people
Border to Coast is based in a modern office in Leeds city centre. We have a strong, supportive culture and pride ourselves on being a learning, sustainable organisation which can continue to grow. We are built to deliver long-term objectives for our Partner
Funds.
We are committed to the personal and professional development of our people and offer excellent career development opportunities. We empower colleagues to be themselves at work, fostering diversity and inclusion in all that we do within a friendly and motivated environment. Our policies on recruitment, development and progression promote fairness and are in line with legal and regulatory requirements.
We have policies and procedures in place in relation to remuneration and benefits. All colleagues are paid at least the living wage. For certain roles, we collaborate with external recruitment agencies, and hold them to the same high standards we set for ourselves.
We regularly seek feedback from colleagues. This includes an annual colleague engagement survey, which is conducted anonymously. We also hold colleague focus groups. We are committed to acting upon the feedback received and continuously assessing our progress. This ongoing dialogue gives colleagues a strong voice in the organisation and provides an opportunity to reinforce our values and expected conduct.
In cases where further investigation is necessary, our grievance policy offers individuals the opportunity to raise concerns in a structured manner. This process underscores our dedication to maintaining a transparent and accountable workplace. We also operate a whistleblowing policy.
All colleagues undertake training on modern human slavery to raise understanding, ensure we meet our corporate responsibility, and to help colleagues identify issues and take action.
Supply chain
We seek to treat our suppliers fairly and endeavour to work with suppliers who share our values.
To ensure all those in our supply chain and our contractors comply with our values, we have in place a supply chain compliance programme.
We have a dedicated procurement team which ensures that appropriate due diligence is carried out on potential third-party suppliers in respect of their adherence to/recognition of modern slavery. All our new suppliers are assessed on their understanding, processes and approach regarding modern human slavery risks. They are also required to provide certain contractual commitments to mitigate modern slavery risks.
In 2022 we enhanced our outsourcing due diligence assessment, undertaken at both onboarding and ongoing contract management, as a standard practice. We take a proportionate and risk-based approach in our assessments. For ongoing contracts, we have set up a tiered review process. If we identify shortcomings in existing contracts or responses to our modern slavery enquiries, we endeavour to receive a commitment from the supplier that they take steps to meet certain modern slavery requirements within an agreed timescale, based on materiality of the contract.
As an investor
We are owned by 11 Local Government Pension Scheme (LGPS) pension funds, our Partner Funds. We recognise our role as a long-term and responsible investor.
When considering human rights matters, we believe all companies should abide by the UN Global Compact Principles and the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises. Companies should have processes in place to identify and manage human rights risks across their business and supply chain. We use third-party data to assess environment, social and governance (ESG) risks across our investments, including UN Global Compact breaches and controversies.
We use an ESG due diligence questionnaire in all our external manager selection processes, taking into account established practice from our investment policies and processes. This results in further deep dive analysis, and feeds into our engagement and
voting approach. Further detail on our voting approach is included in our Corporate Governance and Voting Guidelines.
As an investor, Border to Coast has signed up as a collaborative investor to the Principles for Responsible Investment PRI-led initiative ’advance’. The overall objective of the initiative is to “advance human rights and positive outcomes for people through investor stewardship”. The initiative launched in December 2022 and will run for five years.
We use Robeco as our voting and engagement provider. Robeco has two specific engagement themes related to human rights, ‘Human Rights Due Diligence for Conflict-Affected and High-Risk Areas’, which launched in 2022 and “Modern Slavery in Supply
Chains’, which launched in 2024.
We are also involved in a range of initiatives relating to tackling modern slavery:
- ‘Votes against Slavery’, a collaboration led by Rathbones to engage with FTSE 350 companies which are not compliant with section 54 of the Modern Slavery Act 2015
- ‘Find it, Fix it, Prevent it’, an investor-led collaborative engagement developed by CCLA, which is engaging with UK companies in high risk sectors.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2024. It was approved by the Board on 18 September 2024.
Chris Hitchen
Chair, Border to Coast Pensions Partnership Ltd
This statement is reviewed annually by the Border to Coast Board.