Border to Coast Pensions Partnership Limited
Modern Slavery Statement 2025
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, including modern slavery, and proactively seek 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 our 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 company policies include:
- Procurement and outsourcing – how we manage suppliers and our supply chain
- Conduct risk – our approach to ensuring we maintain good conduct in our business
- Responsible investment – our policy outlines 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 the confidence of stakeholder and the long-term sustainability of the business
Our people policies further cover:
- Values and behaviours – how we expect our people to operate
- Recruitment –our process for attracting and selecting employees to ensure a fair and consistent approach
- Health, safety and wellbeing – providing 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 promote a positive culture, guard against harassment and bullying and enable colleagues to raise grievances relating to unfair treatment at work
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 are an accredited Living Wage Employer and have policies and procedures in place in relation to remuneration and benefits.
We regularly seek feedback from colleagues and are committed to acting upon the feedback received and continuously assessing our progress. This dialogue gives colleagues a strong voice and provides an opportunity to reinforce our values and expected conduct.
Our grievance policy offers individuals the opportunity to raise concerns in a structured manner, underscoring our dedication to maintaining a transparent and accountable workplace. We also operate a whistleblowing policy with Board ownership.
All colleagues undertake training on modern human slavery to promote understanding and ensure we can identify issues and take action.
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 in
place to facilitate this.
We have a dedicated procurement team which 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. They are also required to provide certain contractual commitments to mitigate modern slavery risks.
We undertake enhanced outsourcing due diligence assessments during onboarding and ongoing contract management in proportion to risk and materiality. We have established a tiered review process for ongoing contracts and expect suppliers to address any shortcomings within an agreed timescale.
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.
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 (ESG) risks, including those related to human rights and modern slavery. We use third-party data to support our assessment of ESG risks and we have an established risk response to flagged breaches of the UN Global Compact Principles.
We also use an ESG due diligence questionnaire in our external manager selection processes to ensure their approaches meet our standards.
Our approach results in analysis that feeds into our engagement and voting approach on human rights. Further detail on our voting approach is included in our Corporate Governance and Voting Guidelines.
Border to Coast has endorsed Advance, a PRI-led initiative to protect and enhance risk-adjusted returns by advancing progress on human rights through investor stewardship. During 2024, we supported ‘Votes against Slavery’, a collaboration led by Rathbones to engage with FTSE 350 companies which are not compliant with the Modern Slavery Act 2015.
Robeco, our voting and engagement provider, has a dedicated programme on ‘Modern Slavery in Supply Chains’, which looks at companies’ effectiveness in identifying and addressing modern slavery risks across their supply chains and promotes remediation and prevention measures.
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 2025. It was approved by the Board on 16 September 2025.
Chris Hitchen
Chair, Border to Coast Pensions Partnership Ltd
This statement is reviewed annually by the Border to Coast Board.