This statement is made on behalf of Premier Miton Group plc and its subsidiaries pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes our anti-slavery and human trafficking statement. Premier Miton Group plc (registered number 06306664) is the parent company of Premier Portfolio Managers Limited (registered number 01235867) and Premier Fund Managers Limited (registered number 02274227), collectively referred to as Premier Miton in this statement.
Premier Miton’s structure, business and supply chains
Premier Miton’s business is UK asset management with a focus on delivering good investment outcomes for investors through relevant products and active management across its range of investment strategies, which include multi-asset, equity, fixed income and absolute return funds. As at the date of this statement, Premier Miton employs approximately 150 people in the UK. Premier Miton’s supply chain includes administrative support and services from large global institutional banks and commercial entities. As a firm with relatively simple supply chains Premier Miton believes that there is limited risk of slavery or human trafficking taking place. Notwithstanding this, Premier Miton is committed to developing initiatives to prevent slavery or human trafficking in its supply chains.
Policies in relation to slavery and human trafficking
Premier Miton has robust policies in place to ensure it complies with the Financial Conduct Authority rules on a variety of issues relating to financial crime, corruption, bribery, money laundering and whistleblowing. In addition, Premier Miton’s responsible investing policy guides the consideration of ESG factors (including compliance by UK companies with the Act) in its investment processes
Due diligence process in relation to slavery and human trafficking
Material suppliers are subject to an appropriate level of due diligence on their appointment and on an ongoing basis, and are required to certify that they are in compliance with the Act
Assessment and management of slavery and human trafficking risks
Premier Miton is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or business. As part of an on-going programme of assessing the effectiveness of its policies, training and due diligence, a review of any key risks is undertaken under Premier Miton’s procurement arrangements, which are reported to the relevant boards, as appropriate.
Monitoring and effectiveness
During the financial period to 30 September 2021 Premier Miton has continued to take steps within its organisation to ensure that organisational policies and relevant processes are followed by all employees and partners of Premier Miton. Premier Miton is not aware of any of its suppliers which do not comply with the Act and no breaches have been reported by Premier Miton staff or partners during the period. As Premier Miton does not have intricate or complex supply chains, no additional measures with regards to slavery and human trafficking have been deemed necessary at this time.
During the financial period to 30 September 2021, in particular in light of the COVID-19 related impact upon normal working practices within and outside Premier Miton, it has carefully considered the additional risks of exploitation, and has monitored workers’ health and safety and suppliers to be alert and responsive to any new and emerging risks.
Premier Miton provides comprehensive training to staff on a variety of issues relating to financial crime, corruption, bribery, money laundering and whistle blowing. All employees have the necessary documentation to legally work in the UK and no-one under the legal minimum age for admission to work is or will be employed
Key performance indicators
Key performance indicators (KPIs) are used to measure the effectiveness of Premier Miton’s efforts to reduce modern slavery risks. Premier Miton is committed to ensuring meaningful progress against these KPIs.
Rationale for inclusion
Raise awareness of modern slavery risks amongst employees
Equipping employees with an understanding of the risks ensures effective procurement processes
Integrating modern slavery considerations into investment process
Investments are the biggest potential area of impact for Premier Miton
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Premier Miton’s anti-slavery and human trafficking statement for the financial year 30 September 2021 as approved by each relevant Board of Directors.
Chief Executive Officer
For and on behalf of Premier Miton Group plc, Premier Portfolio Managers Limited and Premier Fund Managers Limited
Date: 7 March 2022
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