This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 in respect of the financial year ended 31 December 2019. Pharo Management (UK) LLP (“PMUK”) acknowledges the importance of compliance with the Modern Slavery Act 2015 (the “MSA”). Modern slavery as referred to in the MSA includes slavery, servitude and forced or compulsory labour, and human trafficking.
PMUK is regulated by the FCA and its sole business is hedge fund management. PMUK has non-UK affiliates in Jersey, New York and Hong Kong, none of which conduct business in the UK. However, Pharo Advisors UK Limited (a member of PMUK) is included in the ambit of this Statement (together “Pharo” or “the firm”) as it provides services directly to PMUK.
Policy on slavery
It is Pharo’s policy to ensure that its business and supply chains are free from modern slavery and human trafficking. As such, Pharo 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.
Approach to MSA
Pharo seeks to implement an appropriate risk-based approach to minimise the risk of modern slavery. This includes consideration of supply chains. Whilst it is acknowledged that risk factors are present in all global supply chains and across all sectors, it is believed that Pharo’s relative risk exposure to slavery, human trafficking and forced labour is low given the nature of its business as a fund manager operating in capital markets and the skillset required in its supply chains.
However, Pharo will endeavour to include appropriate risk assessment, due diligence and management requirements designed to minimise the risk of modern slavery within its employment and supply chain.
Risk of modern slavery through employment or contracting: Pharo staff are protected by relevant laws and regulations, which are fully reflected in the firm’s policies and procedures. Contractors and consultants utilised by Pharo carry out highly skilled activities and are therefore deemed low risk. To the best of its knowledge, Pharo is not in breach of any employment legislation.
Risk of modern slavery through the supply chain: Given that Pharo’s supply chain primarily consists of professional advisers, financial services firms and leading services businesses that require skilled labour to provide services to Pharo, Pharo takes the view that there is a low risk of modern slavery.
Enhanced risk of modern slavery during COVID-19 pandemic: Pharo has completed enhanced assessments of Modern Slavery during this period and consider the overall risk as low.
Furthermore, Pharo encourages employees to report any potential instances of modern slavery to management or externally through its Whistleblowing Policy.
Pharo continues to look for ways to improve its approach to eradicate modern slavery and ensure that its policies and procedures are robust and effective in doing so.
This statement has been reviewed by senior management, the UK Governance Committee and approved by the members of Pharo Management (UK) LLP.