Slavery and Human Trafficking Statement
For the financial year ending 31 December 2022
Seven Investment Management LLP (“7IM”) is committed to taking our responsibilities as a corporate citizen seriously. We acknowledge our responsibility to take steps against the risks of slavery and human trafficking taking place in our business and supply chains.
This statement is made in accordance with section 54(1) of the UK Modern Slavery Act 2015 (the “Act”) and constitutes 7IM’s Modern Slavery and Human Trafficking Statement for the financial year ending 31 December 2022.
The ‘7’ in 7IM refers to the seven original founders of the business. Back in 2002, they were unable to find a firm they trusted to manage their families’ money properly, so they started the kind of investment management organisation they would like to invest with themselves. Their aim was to deliver steady returns over the long term, while keeping an eye on risk, using the best technology. They wanted everyone to have access to the kind of service and expertise that institutional investors would expect.
Today, 7IM offers more than just investment management, although that remains at the heart of our business. We make investing easy via the 7IM Platform service, which delivers a unique, personal, and digital client experience. We help individuals with pensions and retirement income, partner with advisers who want to focus on their client relationships rather than administration and provide an enhanced overall experience via the use of technology to make things simple and clear.
Our supply chains
Our supply chains consist mainly of key outsourced providers of regulated financial services and suppliers in respect of data, IT, operations, office and support services, and professional advisers. Our supply chains are more straightforward in comparison to providers of physical goods or other types of services. We, therefore, believe that the risk of slavery and human trafficking practices by our suppliers is relatively low. Nonetheless, we are aware of modern slavery threats in the financial services industry and recognise the importance of combatting modern slavery and our responsibility to take steps to tackle the issue.
Our policies and procedures
We have several policies and procedures in place which reflect our commitment to acting with integrity in our business relationships and which help us to detect and prevent any potential modern slavery within our business and supply chains. These include an anti-money laundering policy, anti-bribery, and other financial crime-related policies and procedures. We also encourage our staff to report any concerns they may have under our whistleblowing policy.
Our approach to suppliers
We are committed to carrying out reviews on our suppliers’ adherence to the statement publication requirement under the Act as part of our efforts to ensure the requirements under the Act are addressed in our supply chains. During the year, we have reviewed our relationships with all of our key suppliers and their adherence to their own obligations under the Act formed part of such a review. We have continued to require that suppliers who provide services in relation to promotional events complete a specific modern slavery compliance questionnaire as this is a particular area of our supply chain where we believe modern slavery is a higher risk. Where relevant, when entering into new agreements with suppliers, we required confirmation of compliance with all applicable laws, including the Act.
We regularly look at reviewing and updating our policies and procedures to continue to pursue the highest standards and a transparent and accountable culture. However, we recognise we can do more to combat the risk of modern slavery in our supply chains and so during the year we began a review into our lifecycle management of all of our third-party suppliers. We have continued this review in the current financial year and hope to roll out new policies and procedures by the end of 2023, including those to monitor such third parties’ adherence to their obligations under the Act.
Turning to our investment process, 7IM is a signatory to the Principles for Responsible Investment and the UK Stewardship Code. As signatories to these organisations, we have committed to incorporating Environmental, Social and Governance (“ESG”) factors into our investment process. As part of this and in reference to the Modern Slavery Act, we explicitly ask firms we invest with how they are considering the risks relating to modern slavery and we are in the process of updating our ESG due diligence procedures to make them even more robust.
We recognise the importance of training our staff in order to raise awareness of modern slavery threats in our business and supply chains. We review and update our company-wide training programme on an annual basis to ensure that our staff receive relevant training, including training related to anti-modern slavery, anti-money laundering and financial crime, and our policies and procedures for the management and escalation of associated risks. We require that all staff electronically attest that they have read and understood all such policies.
Our effectiveness in combatting modern slavery in our business and supply chains
An internal working group meets to consider and assess the steps we have taken. It also looks to identify any further measures we can take, to help detect and prevent modern slavery in our business and supply chains and review the effectiveness of our approach. We will continue to review our policies, procedures, and processes, and engage with our suppliers to develop our approach to combatting modern slavery.
Our commitment to anti-modern slavery
In addition to working pro-actively to combat anti-modern slavery in our business and supply chain, during the year, the internal working group resolved to voluntarily publish the statement for the previous financial year to the government’s newly introduced Modern Slavery Statement Registry.
7IM is a limited liability partnership and this statement has been approved by 7IM’s members in accordance with its governance procedures.
For and on behalf of 7IM