This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Cheyne Capital Management (UK) LLP (‘Cheyne Capital’) and our affiliated UK entities have taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Cheyne Capital is a diversified Alternative Investment Manager, managing a number of investment funds and vehicles. We do not deal in any hard goods or manufactured items, and have no offices in, nor purchase any good from, any developing countries. Cheyne Capital does not have a traditional manufacturing supply chain. We do not purchase goods produced in developing countries for on-sale or integration into our products. Cheyne Capital oversees the provision of financial services to support the investment funds and vehicles it manages. Predominately this includes the supply of fund administration services, trading and execution services and asset custody services. We also work with suppliers who support our office facilities.
We have assessed the risk of modern slavery to our business and we do not believe we have any high risk areas in relation to slavery, servitude, human trafficking or forced labour.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Cheyne Capital has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain. To ensure compliance with this policy we conduct regular checks on our supply chain and provide training to our staff, and operate a number of internal supporting policies. We may terminate any contract at any time should any instances of modern slavery and or human trafficking come to light.
We operate a number of internal policies and procedures to ensure that we are conducting business in an ethical and transparent manner. These include:
- Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery.
- Recruitment process. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
- Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
- Code of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
- No reports are received from employees, suppliers, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
This statement for the financial year ending 31 March 2020 was approved by the Executive Committee on 17 September 2020.