Border to Coast Pensions Partnership Limited
Modern Slavery Statement 2023
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 are regularly reviewed, that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. These include:
- Procurement and outsourcing – how we manage suppliers and our supply chain
- Values and behaviours – sets out our values and behaviours
- Conduct – this outlines our approach to ensuring we maintain good conduct in our business
- Recruitment – outlining the process for selecting and attracting staff to ensure a fair and consistent approach is taken
- Health, safety and wellbeing – this outlines our approach to managing health, safety and wellbeing issues
- Diversity, equality and inclusion – our approach to diversity, equality & inclusion, harassment and bullying, and equal opportunities in everything we do
- Grievance Policy – setting out the grievance procedure so employees can raise problems, complaints or concerns regarding working conditions or treatment
- Responsible Investment Policy – this outlines our approach as a long term and responsible investor
- Corporate Social Responsibility Policy – 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
With 138 colleagues[2], Border to Coast is based in a modern office in the heart of Leeds city centre. We have a strong supportive culture and pride ourselves on being a learning organisation that can continue to grow and be a sustainable organisation, built to deliver for our Partner Funds for the long-term.
We are committed to the personal and professional development of our people and offer excellent career development opportunities. We empower colleagues to bring their whole selves to work, fostering diversity and inclusion in all that we do within a friendly and motivated environment. Our HR policies on recruitment, development and progression promote fairness and are in line with legal requirements.
We regularly review our policies and procedures to ensure they remain relevant and compliant. This includes aspects such as hiring and selection, remuneration and benefits, as well as our approach to health and safety.
We do not pay any colleagues below the living wage. For certain roles, we collaborate with external recruitment agencies. The costs associated with these agencies are borne by us as the employer, rather than being passed on to the employees.
We regularly seek feedback from colleagues, and this includes an annual colleague engagement survey – which is conducted anonymously. We also hold other focus groups and are committed to acting upon the feedback received and continuously assessing our progress. “This ongoing dialogue gives colleagues a strong voice in the organisation while also providing 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.
Supply chain
Most of our suppliers are based in the UK; we seek to treat our suppliers fairly and endeavour to work with suppliers who share our values.
In 2022 we enhanced our outsourcing due diligence assessment, undertaken at both on-boarding 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 there are shortcomings in existing contracts (or responses to our modern slavery enquiries which do not meet our requirements) 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.
To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme.
We have a dedicated procurement team who ensure that appropriate due diligence is carried out on potential third party suppliers in respect of their adherence to/recognition of modern slavery. This means that we ensure that all our new suppliers are assessed on their understanding and their processes and approach to modern human slavery risks. They are also required to provide certain contractual confirmations mitigate Modern Slavery risks.
As an investor
Owned by 11 Local Government Pension Scheme Partner Funds, we recognise our role as a long term and responsible investor.
When considering human rights issues, we believe that all companies should abide by the UN Global Compact Principles and the OECD Guidelines for Multinational Enterprises. Companies should have processes in place to both identify and manage human rights risks across their business and supply chain. We use third-party data to assess ESG risks across our investments, this includes UN Global Compact breaches and controversies. Additionally, ESG due diligence questionnaire is used in all of our manager selection process, taking into account established practice from Border to Coast 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 & Voting Guidelines.
As an investor, Border to Coast has signed up to a PRI led initiative for human rights and social issues. The overall objective of the initiative is to ‘advance human rights and positive outcomes for people through investor stewardship’. This initiative will run for five years and we are supporting the collaborative investor engagement.
Robeco is Border to Coast’s voting and engagement provider and has a specific engagement theme related to human rights – ‘Human Rights Due Diligence for Conflict-Affected and High-Risk Areas’, which was launched in 2022.
We are also involved in a range of initiatives relating to tackling the issue of Modern Slavery:
- ‘Votes against Slavery’, a collaborative engagement led by Rathbones engaging with FTSE 350 companies not compliant with section 54 of the Modern Slavery Act
- ‘Find it, Fix it, Prevent it’, an investor-led collaborative engagement developed by CCLA which is engaging with companies in the UK in high risk sectors.
Chris Hitchen
Chair, Border to Coast Pensions Partnership Ltd
This statement is reviewed annually by the Border to Coast Board.
[2] As of 31 March 2023.