Introduction
The Modern Slavery Act 2015 (the "Act") seeks to address the role of businesses in preventing modern slavery from occurring in their supply chains and organisations. This statement constitutes the slavery and human trafficking statement required by Section 54 of the Act, for the financial year ending 31 December 2022 for Eisler Capital (UK) Ltd and its Group companies (together “Eisler”).
Eisler is committed to addressing the requirements placed on it by the UK Modern Slavery Act 2015 (the “Act”). While this is a UK Act, Eisler applies policies and processes on a group-wide basis irrespective of where our companies, people, clients and supply chain providers are located.
Organisational structure
Eisler Capital (UK) Ltd is a limited liability company incorporated in England and Wales and regulated in the United Kingdom by the Financial Conduct Authority ("FCA"). Eisler’s sole business is investment management.
Supply chains and due diligence procedures
Eisler is committed to ensuring that its supply chain is free of any slavery and/or human trafficking. Eisler will not knowingly support and/or do business with any suppliers who are involved in slavery.
Eisler’s direct supply chain is limited and includes, for example, financial data providers and outsourced administration and IT service providers. Eisler also uses a number of third-party suppliers as part of its indirect supply chain, relating to non-core functions such as cleaning, catering, office services and brand marketing.
Approach to Modern Slavery Act
To fulfil its obligations under the Act, Eisler may:
- Undertakes due diligence of service providers to assess the nature and extent of its exposure to the risk of slavery.
- Request information regarding third party suppliers’ working practices and require the relevant key supplier to confirm that it is aware of, and complies with, its obligations under the Act.
- Communicate to potential key suppliers that we have a zero-tolerance policy with regards to slavery.
- As a minimum, we expect all our suppliers and their supply chain to comply with all applicable laws and regulations in the conduct of their business, but in addition believe that our suppliers should meet appropriate standards with respect to labour practices and treatment.
Training and policies
Eisler maintains existing policies which we consider relevant to the detection and protection of Modern Slavery including Vendor/Supplier Onboarding Procedures, a Staff Handbook, Whistleblowing Policy, Financial Crime and Complaints policy.
Eisler staff receive training on a variety of areas including, but not limited to, money laundering, bribery, corruption, whistleblowing and complaints. They are reminded and encouraged to identify potential violations and report behaviour that does not comply with internal policies and external regulations and laws.
Monitoring and adherence
Responsibility for ensuring and monitoring adherence to this policy within Eisler rests with all its employees. Employees who interact with third party suppliers are charged with monitoring adherence to this statement by those third parties, to the extent they are able. Employees who are aware of, or suspect, any violation of the Act are required to report such conduct to the Chief Compliance Officer, or to follow Eisler’s whistleblowing policy.
Approval Procedure and Publication
This statement has been approved by Eisler’s senior management. We will continue to engage with our staff and suppliers to raise awareness and take such further steps as we consider necessary to ensure Modern Slavery is not taking place in our business or our supply chain.