Modern Slavery Statement
This statement is made pursuant to Section 54, part 6 of the Modern Slavery Act 2015 (the Act), and constitutes our slavery and human trafficking statement for the year 2017/18. Our initial statement setting out measures to ensure that slavery and human trafficking are not taking place in our supply chains or any parts of our business was published in 2017. This statement reaffirms these measures and sets out what we have done to ensure our business and supply chain remain free of slavery and human trafficking since we published our initial statement
Our organisation's structure and business
Barings Europe, comprising Barings (U.K.) Limited and Barings Europe Limited through its operating subsidiaries is an investment manager and part of a global asset management firm which is headquartered in Charlotte, North Carolina. Barings Europe is, indirectly, wholly owned by Massachusetts Mutual Life Insurance Company (MassMutual). Barings Europe has over 400 employees and operates in the United Kingdom and a number of other locations in Europe.
Supply chain risk
The industry in which Barings Europe operates in not an industry with a high risk of modern day slavery, and we have therefore adopted a risk based approach to review those supply chains that fall within industries that carry a higher risk of modern day slavery. As part of the due diligence process when engaging new suppliers Barings Europe will seek appropriate compliance statements from higher risk suppliers with regard to their business practices. Additionally we will make sure new contracts contain wording to ensure that suppliers wording regarding comply with the Act in order to address the requirements of the Act at the point of engagement.
The Organisational Risk function is responsible for ongoing monitoring of the supply chain and has in place risk rating processes to mitigate the risk of suppliers breaching the Act’s requirements. Whether a vendor will be deemed high risk will be dependent on a number of factors including whether they are deemed critical vendors, those suppliers based or using a country that has a high prevalence of modern slavery or human rights violations and assessing whether the goods or services supplied (in the UK) are provided by a company that could employ low skilled or migrant workers.
Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. The Barings Europe anti-modern slavery policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in out supply chains. We have in place systems to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers.
We will take steps to educate and raise awareness of relevant staff in relation to the Act, particularly those involved in the procurement process, and also those on the following governing bodies:
- European Management Team
- Board of directors of relevant entities; and
- Other committees as deemed appropriate.
Our approach and due diligence
Over the last year, we have identified higher risk vendors, considering geographical location and industry, and obtained attestations from those identified higher risk vendors in respect of their approach to eradicating modern anti-slavery. For new vendors, we have been carrying out due diligence and continue ongoing monitoring of vendors via third party information sources which provide analysis and notifications. Over the last year no issues or concerns have arisen which have needed to be escalated to the Board and/or senior management,
As part of the due diligence process when engaging new suppliers, in accordance with our policies Barings Europe will seek appropriate compliance statements from higher risk suppliers/vendors with regard to their business practices. Additionally we will make sure our relevant contracts contain provisions to ensure counterparties are subject to appropriate obligations regarding the Act.
This statement has been approved by the Boards of Directors of Barings Europe Limited and Barings (U.K.) Limited and will be reviewed annually in accordance with our Modern Anti-slavery Policy and updated as necessary.
Chief Executive Officer, Barings Europe
2 August 2018