Introduction
This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 (the “Act”) and constitutes the slavery and human trafficking statement (“Statement”) for the financial year ending 28 February 2021 for CSP Investment Management LLC (“CSP”). This Statement sets out the CSP’s policy and approach in relation to the Act.
CSP's Policies on Modern Slavery
CSP’s anti-slavery policy reflects its commitment to acting ethically and with integrity in all of its business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking practices are not taking place anywhere in its business or supply chains. CSP will take appropriate and reasonable measures to minimise such risks, taking into account the nature of services with which it is being provided.
This Statement will be reviewed annually and updated where necessary to reflect changes in circumstances and actual practice.
CSP’s Approach to Slavery and Human Trafficking
CSP administers a suitable risk-based approach to minimise the risk of slave labour.
As a provider of investment management and advisory services, CSP does not have a particularly long or complex supply chain – the key suppliers are providers of investment research, middle and/or back office support services (such as IT support), equipment and office management. CSP is nevertheless committed to preventing acts of modern slavery and human trafficking from occurring within both CSP’s business and that of its supply chain.
Based on the above, the relative risk exposure to slavery, human trafficking and forced labour is low given the nature of the business undertaken, and the skillset required in CSP’s supply chain; i.e. mainly skilled labour. Nevertheless, as a general principal, CSP endeavours to deal only with suppliers who conduct their business in a lawful and ethical manner, including adopting business practices that prevent or eliminate modern slavery and human trafficking from taking place.
As part of CSP’s initiative to identify and mitigate risk in connection with its business and/or supply chains (as applicable) CSP endeavours to:
- identify and assess potential risk areas;
- mitigate the risk of slavery and human trafficking occurring in our business; and
- monitor potential risk areas.
Training and Monitoring
Relevant training is provided, as deemed appropriate, to CSP’s staff, to ensure an appropriate level of understanding of the risks of modern slavery and human trafficking.
CSP is committed to reviewing its processes on an ongoing basis to ensure that there is no modern slavery in any aspect of its business.
This statement is made pursuant to section 54(1) of the Act and constitutes CSP’s slavery and human trafficking statement for the financial year ending 28 February 2021.
For and on behalf of the
CSP Investment Management LLC