We believe that all forms of modern slavery, from human trafficking and forced labour, to bonded labour and child slavery, have no place in our society. As an investment company we want to do all that we can to help tackle these issues. We are committed to operating ethically, raising awareness of modern slavery issues, and encouraging good practices among our suppliers and the companies we invest in.
We work with a limited number of suppliers who provide us with various goods and services. The majority of our spending is with suppliers of fully managed outsourced services, operating systems, information technology and professional services which support our investment management process.
We ensure the management and oversight of all material service providers through our vendor due diligence process. These due diligence requirements involve cross-business representatives focusing on procurement, legal, sustainability, risk and compliance to ensure we continuously review and improve our approach.
The Canadian and United States financial services industry is not considered a high-risk sector for modern slavery. However, we are not complacent and recognise the possibility that modern slavery issues may exist somewhere in our supply chain. We expect transparency from our suppliers and will work with our business partners to support them in driving positive change. In the event that we did become aware of any modern slavery issues within any of our supply chains, this would be escalated to our Board of Directors through our risk management framework and appropriate action would be taken. Depending on the circumstances, this may range from supporting a supplier to make a positive change to terminating the relationship with a supplier. We also recognise that the biggest impact we can make is through our investment approach, engaging directly with high-risk companies and encouraging better practices as part of our commitment to environmental, social and governance (“ESG”).
A key way we can drive change is through how we invest. We incorporate ESG considerations into our investment approach across all mandates. We take our responsibilities as an investor seriously and seek to encourage the adoption of best-practice ESG standards. We expect that the companies in which we invest meet internationally recognised modern slavery standards and industry best practices. We also expect companies to report to shareholders regarding policies, practices and the performance of all the steps taken to address modern slavery issues. Where we believe a company is exposed to modern slavery risk and not taking action to mitigate this, we will incorporate this into our investment view and engage with the company to drive positive change.


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