The Modern Slavery Act 2015 (the “Act”) seeks to address the role of UK businesses in preventing modern slavery from occurring in their supply chains and organisations. Pursuant to section 54 of the Act, this constitutes the modern slavery statement of Horizon Asset LLP (“HALLP”) and Horizon Asset (UK) Limited (“HAL”), HALLP’s sole corporate member (together the “Horizon UK Group” or “we”) for the financial year ended 31 December 2016.
Organisational Structure and Business
HALLP is authorised and regulated by the Financial Conduct Authority ("FCA") and its sole business is investment management. HALLP has two non-UK affiliates which directly employ staff, in Hong Kong and Tokyo; neither of these affiliates conduct business in the UK. Horizon Asset (UK) Limited is does not provide any services in the UK.
Approach to Modern Slavery
It is our policy to ensure that its business and supply chains are free from modern slavery. We adopt appropriate and reasonable measures to minimise, as far as possible, the risk of modern slavery occurring anywhere within its business or supply chains, and we will not knowingly deal with any organisation that is connected with modern slavery in any way.
We acknowledge that the risk of modern slavery is relevant to all supply chains across all sectors. However, our business and that of our affiliates is focused solely on investment management, which we believe to be relatively lower risk industry deploying as it does a highly skilled labour force with extensive reliance on specialised information technology and a very limited level of manufactured goods.
Our Supply Chain
Review and Due Diligence
We take a proportionate, risk-based approach when entering in to or renewing supplier arrangements.
We conducted a review to assess the nature and extent of the risk of modern slavery in our supply chains and business. As part of its proportionate, risk-based approach we focussed on countries and parts of the supply chain considered (relatively) higher risk. The main criteria used to evaluate suppliers included the origin of manufacture, the nature of the services provided and the location from which these services are provided.
As a result of this review, we identified some parts of our supply chain where the risk of modern slavery is proportionately higher. These parts include our third party suppliers who provide products and services for office buildings such as cleaning staff, security staff and courier services (“Relevant Suppliers”).
We have undertaken background checks of Relevant Suppliers in order to confirm that they are not and have not been named on any national or international watch lists and/or that their businesses are not and have not been subject to or associated with any relevant negative press.
We have also contacted any Relevant Suppliers to notify them of our commitment to eradicating modern slavery, to explain our expectations of their compliance with the requirements and spirit of the Act and to seek confirmation that they comply with the same.
Prior to entering into a new supplier arrangement with a Relevant Supplier, we will review the supplier’s business and may request information and/or written assurances regarding their commitment to the protection of human rights and eradicating modern slavery, their day-to-day working practices and any other area(s), we consider necessary in accordance with our proportionate, risk-based approach.
All key stakeholders in our business are aware of the requirements of the Act. These stakeholders include the senior managers of HALLP and those in control of procurement for the business.
This statement has been reviewed by senior management and approved on behalf of the members of HALLP and the board of directors of Horizon Asset (UK) Limited.