Commitment to the UK Stewardship Code
Last updated 25 February 2020
Under Rule 2.2.3R of the Financial Conduct Authority’s (“FCA’s”) Conduct of Business Sourcebook, Securis Investment Partners LLP (“Securis”) is required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council’s (“FRC”’) Stewardship Code (the “Code”) and the nature of its commitment to the EU Shareholder Rights Directive (the ” SRD II Code”) or, where it does not commit to the Codes, its alternative investment strategy.
Both the Code and the SRD II Code are voluntary and set out a number of principles relating to engagement by investors with across asset classes invested in. For this purpose, “stewardship” is defined as “the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries, which leads to sustainable benefits for the economy, the environment and society.
Securis’ principal investment management activity involves investment in insurance linked securities. Securis’ funds invest exclusively in assets which do not have voting or participating rights attached to them and therefore the Code is not directly applicable to them. Nonetheless, Securis supports the objectives that underlie the Code.
Authorised and Regulated by the Financial Conduct Authority.
Registered in England – No. OC312768
Registered office 12h Floor, 110 Bishopsgate, London, EC2N 4AY.
Pillar 3 Disclosure
Securis Investment Partners LLP Pillar 3 Disclosure is stated in Securis’ audited accounts.
Modern Slavery Act 2005 (“the Act”)
This statement is issued by Securis Investment Partners LLP (“Securis”), a limited liability partnership registered in England, in compliance with section 54 of the Modern Slavery Act 2015.
Securis is an operating entity within the Northill Capital Group (”Northill”). Northill provides equity and seed capital to a small number of high-quality start-ups or early stage asset managers and provides equity capital to replace existing shareholders in larger more established asset management businesses.
Securis is authorised and regulated by the Financial Conduct Authority.
This statement is our slavery and human trafficking statement for the purposes of section 54(1) of the Modern Slavery Act 2015. It sets out our ongoing commitment as a responsible business to ensure that modern slavery and human trafficking is eradicated.
Securis has a zero tolerance approach to modern slavery and human trafficking. As such we are committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business.
We are committed to acting ethically and with integrity in all our business relationships and we will take appropriate and reasonable measures to minimise the risk of this taking place in line with the nature of services provided to the firm.
Securis considers the risk of slavery, servitude, forced or compulsory labour (together, “Modern Slavery”) and human trafficking existing within its business to be low.
Supply Chain Risk
Securis does not support or knowingly deal with any business involved in slavery or human trafficking and will not work with any party it suspects is connected with slavery in any way. Our supply chain includes regulated professional advisers, providers of financial data, IT equipment, office supplies, travel providers and other third party service providers (“Suppliers” for the purpose of this note).
Suppliers are reviewed on an ongoing basis in line with our Third Party Evaluation procedure which includes a requirement to analyse each Supplier’s or approach to combatting slavery and human trafficking.
Securis expects its Suppliers to adopt the same standards it meets itself, and in turn work only with companies that share these values and principles. Suppliers are expected to uphold their workers’ human rights and treat them respectfully, while maintaining workplaces emphasising ethical and fair behaviour.
In the event that Securis becomes aware of Modern Slavery occurring within its supply chain, we will seek to ensure that the supplier implements remedial action. Securis expects its Suppliers to react to any Modern Slavery issues constructively and responsibly, and in a manner demonstrating their willingness to remedy issues expediently.
Securis has undertaken a review of its existing Suppliers and evaluated the risk of any Supplier being unable to meet its obligations under the Act and will continue to focus on the following areas:
Key Suppliers on-boarding and due diligence – an analysis of the service provider’s approach to combatting slavery and human trafficking is to be included within our review process going forward.
Training – we have ensured awareness of the Act to enable staff generally to understand the requirements of the Modern Slavery Act and flag potential issues.
Securis’ recruitment processes are thorough and transparent. We communicate directly with candidates to discuss job opportunities and to confirm the details of any offer made. We have robust procedures in place for the vetting of new employees and ensure that we are able to confirm their identities.
Securis has policies and procedures in place to ensure compliance with human rights and UK employment laws. All staff are remunerated fairly and above the UK’s national living wage. Consequently, we are satisfied that our employees are not exploited in any way.
This annual statement covers the financial year ended 31st March 2018. It is publicly available on the Securis corporate website. The Securis LLP Board has endorsed this policy and has confirmed its commitment to improving practices to combat slavery and human trafficking.