Border to Coast Pensions Partnership Limited
Modern Slavery Statement 2026
Modern slavery is an umbrella term encompassing slavery, servitude, forced or compulsory labour, and human trafficking. As both a business and an investor, we recognise the importance of human rights issues globally and proactively seek to manage capital in a way that supports sustainable and inclusive economies.
We seek to mitigate the risk of human slavery both in our business operations and through our role as a global investor. We address our operational risk through our employment, procurement and outsourcing processes, and our investment risk through careful assessment and due diligence processes. We also use our voice as a global investor to support initiatives addressing modern slavery.
Policies relating to the management of modern slavery
Policies and procedures 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 identify, onboard and manage suppliers and our supply chain
- Conduct risk – how we identify, manage and oversee conduct risk to support good outcomes for customers, markets and stakeholders
- Responsible investment – our approach as a long-term responsible investor
- Corporate social responsibility – we operate over and above legal and regulatory requirements, recognising that doing so promotes stakeholder confidence and our long-term sustainability.
Supply chain
We seek to treat our suppliers and contractors fairly and endeavour to work with those who share our values. We have a supply chain compliance programme to facilitate this.
Our dedicated procurement team ensures that appropriate due diligence is carried out on potential suppliers in respect of modern slavery, including their understanding, processes and approach to associated risks. Suppliers are also required to provide certain contractual commitments to mitigate modern slavery risks.
As part of our annual due diligence, we seek assurance from suppliers on their compliance with the Modern Slavery Act 2015. Should concerns arise, we undertake further enquiries, including reviewing their modern slavery policy or seeking alternative evidence of compliance and risk management practices.
The nature of our business is such that our procurement is primarily focused in lower risk sectors including technology, software, professional services and consultancy.
As an investor
We are owned by 18 Local Government Pension Scheme (LGPS) pension funds, our Partner Funds. We recognise our role as a long-term and responsible investor.
We are clear that all companies should abide by the UN Global Compact Principles and the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises on Responsible Business Conduct. Modern slavery can be found in any industry, and we expect all companies to have robust processes that identify and mitigate human rights risks across their operations and supply chain.
Our investment process is designed to identify and assess material environment, social and governance risks, including those related to human rights and modern slavery. We use third party data to support our assessment of material sustainability risks and we have an established risk response to flagged breaches of the UN Global Compact Principles.
Our due diligence process in external manager selection processes ensures their approaches meet our standards.
Our approach feeds into our engagement and voting on human rights. We assess related risks, such as modern slavery and labour rights, on a case-by-case basis and will vote against the most accountable board member or the report and accounts if a company fails to manage these. In 2025, we voted against management at five companies due to inadequate risk management.
We have endorsed Advance, a PRI-led initiative to protect and enhance risk-adjusted returns by advancing progress on human rights through investor stewardship.
Robeco, our voting and engagement provider, has a dedicated programme on ‘Modern Slavery in Supply Chains’. During 2025, Robeco engaged six of our holdings to enhance their effectiveness in identifying and addressing modern slavery risks. The engagement focused on effective remediation measures and prevention of further recurrences by working closely with suppliers and establishing the right accountability structures.
Our people
We are 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 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, remuneration and progression promote fairness and are in line with legal and regulatory requirements. We are an accredited Living Wage Employer.
We are committed to the personal and professional development of our colleagues and offer career development opportunities that support fair progression.
We encourage and listen to colleague feedback. This dialogue gives colleagues a strong voice and provides an opportunity to reinforce our values and expected conduct.
All colleagues undertake training on modern slavery to support awareness and enable any concerns to be escalated through the appropriate channels.
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 2026. It was approved by the Board on 15 September 2026.
This statement is reviewed annually by the Border to Coast Board.