Modern Human Slavery: Our position
Commercial organisations in the UK with an annual turnover of at least £36 million are required to publish a modern slavery statement as per Section 54 of the Modern Slavery Act 2015. Whilst Brunel Pension Partnership is currently exempt from this requirement, we are voluntarily publishing this statement to comply with best practice.
There are an estimated 40 million people globally classified as being victims of modern human slavery, of which 136,000 live in the UK 1.
Furthermore, in the UK alone there are £13bn of goods imported each year that are likely to have been produced through forced labour. Brunel Pension Partnership is committed to respecting human rights across our operations, our supply chain and our investments. We understand that modern human slavery can take many forms (including but not limited to human trafficking, forced labour debt bondage, descent-based slavery, slavery of children and forced and early marriage), and is likely to be in the supply chain of many, if not all, companies.
Due to the nature of our business, we consider ourselves at low risk of being directly involved in facilitating modern human slavery. However, we recognise that we play a key role in helping to eliminate modern human slavery, wherever possible through our operations and our investments.
About us
Brunel Pension Partnership is one of eight national Local Government Pension Scheme (LGPS) Pools, bringing together circa £35 billion investments of 10 likeminded pension funds. We are committed to respecting human rights in all our operations, including our recruitment practices and through our suppliers.
Our People
Brunel Pension Partnership has a workforce of 59 people based in the UK at the time of writing this policy. To ensure that we recruit and treat employees fairly, eliminating modern human slavery at all costs, our human resources policies set out procedures on how we:
- Recruit and select employees in a fair and lawful way, both for internal and contract staff
- Treat all employees fairly, and if an employee wishes to raise a grievance there are procedures in place to do so
- Manage the exit of employees in a fair and consistent manner
We have a commitment to fair labour and workforce rights including (but not limited to): terms and conditions of employment, remuneration, working hours and health and safety. We ensure we are in line with statutory requirements and best practice wherever possible.
From time to time, we use recruitment agencies and ensure their practices align with our Values. We support the ‘Employer pays’ principle where any incurred recruitment fees are paid by Brunel, as opposed to the individual. We pay all our employees, at minimum, the Real Living Wage – a voluntary rate of pay higher than that of the UK minimum wage. As of January 2021, Brunel became an official ‘Living Wage Employer’ as defined by the Living Wage Foundation.
We seek feedback from our employees through our annual survey which is open to all Brunel employees. This feedback allows our HR team to identify behaviours and practices that could lead to a failure of ethics or governance. This also allows potential exploitation to be raised confidentially and investigated.
All Brunel staff undertake training on modern human slavery.
Supply chain
In 2021 we made a decision to include modern human slavery in the due diligence of all of our suppliers as a standard practice. This means that our suppliers are assessed on their understanding and their processes and approach to modern human slavery risks on an annual basis. Brunel also sits on the ‘client forum’ for one of our large international suppliers where modern human slavery is incorporated in the overall governance of the vendor.
Most of our suppliers are based in the UK, which has a low prevalence of modern human slavery according to the Global Slavery Index. We seek to treat our suppliers fairly and endeavour to work with suppliers who share our values.
Policies relating to the management of modern human slavery
Procurement Policy – outlining our approach to procurement.
Code of Conduct – a framework that promotes and supports a respectful and professional approach to all our dealings at work, with our colleagues and our business partners.
Equal Opportunities Policy – relating to Brunel’s approach to recruitment and fair treatment of employees
Health, Safety and Wellbeing Policy – Outlining Brunel’s approach to managing health, safety and wellbeing risks
Grievance Policy – setting out the grievance procedure so employees can raise problems, complaints or concerns regarding working conditions or treatment
Recruitment Policy and Procedure – outlining the process for selecting and attracting staff to ensure a fair and consistent approach is taken
Interim Temporary Workers Policy – outlining the process for selecting and attracting staff to ensure a fair and consistent approach is taken
Investments
Whilst our direct operations are based in the UK, our investment Portfolios are exposed to companies and assets with global operations and supply chains.
As part of our investment selection process, we expect our fund managers to be aware of, and supportive of, combating violations of human rights. We expect companies to comply with all legal requirements and the duty to respect all internationally recognised human rights, including the obligations of the Modern Slavery Act in the UK and the United Nations Guiding Principles on Business Human Rights (UNGP’s).
We are supportive of companies who provide disclosure on their workforce and follow the Transparency in supply chains guide issued by the Home Office. We encourage companies to adopt and to increase use of appropriate technology to improve transparency on end-to-end supply chains. We use several data sources to monitor the underlying companies within our Portfolios for human rights and supply chain standards as well as compliance with the United Nations Global Compact Principles.
As part of our approach to stewardship we support several engagement initiatives that encourage businesses to prioritise strong governance mechanisms to eliminate modern human slavery. We detail some of these below.
Find It, Fix It, Prevent It Engagement
We are part of an investor coalition with collective assets under management of £2.4 trillion engaging on modern human slavery with leisure, tourism and hospitality companies. The engagement initiative, backed by the Principle for Responsible Investment, asks companies to proactively search for risky parts of their supply chains, to work towards effective remedy for those affected and to ensure the situation does not continue. See here for more information on this initiative.
Engaging with FTSE 350 companies on the Modern Human Slavery Act 2015
In 2021 we signed and supported engagement letters which are sent to non-compliant FTSE 350 companies who have failed to meet the reporting requirements of section 54 of the Modern Human Slavery Act 2015.
Engaging with companies in the UAE on Migrant Labour
In 2020 we signed and supported engagement letters alongside investors with over £2.2 trillion of assets to companies with operations in The Gulf. The initiative enquired about recruitment practices and the welfare of migrant workers after the COVID-19 crisis highlighted poor practices by some companies in this region.
Public Policy Engagement
In 2021 we conducted engagement directly with the UK government around the role that investors can play tackling modern human slavery.
Engagement by Federated Hermes EOS
Our engagement and voting services provider, Federated Hermes EOS, engages with Portfolio companies on labour rights and human rights, including modern human slavery.
For more information about Brunel’s approach and stewardship activities please see the Responsible Investment and Stewardship Outcomes Report publicly available on our website.
Laura Chappell, Chief Executive Officer, Brunel Pension Partnership
- Global Slavery Index ↩︎