Modern Slavery Policy

Modern Slavery Policy

 MODERN SLAVERY AND HUMAN TRAFFICKING POLICY STATEMENT 2024

This statement is made by Validus Risk Management Limited and its subsidiaries (together referred to as “Validus”) pursuant to section 54 of the Modern Slavery Act 2015 (the “Statement”). Validus is committed to conducting business in an ethical and honest manner, and to implementing and enforcing systems that ensure slavery and /or human trafficking is prevented. The Statement was approved by the Board of Directors of Validus for the financial year ending December 2023 and will continue to apply until amended. The Board of Directors of Validus will review it at least once a year.

Introduction from the Founding Partners

Validus operates in the financial services sector as a provider of independent market risk advisory firm specialising in the management of currency, interest rate and commodity price risk. It is authorised by the Financial Conduct Authority (the “FCA”) as a MIFIDPRU investment services firm (FRN: 555972).

Validus considers its legal and corporate responsibilities of great importance in relation to its investors, its partners, its employees, and its wider community. Validus acknowledges that modern slavery and human trafficking are punishable by up to life imprisonment.

Validus faces a very low risk of involvement in slavery or human trafficking in the territories that the firm is active in. However, Validus is focused on maintaining its zero-tolerance approach to these issues.

Policies

Validus operates a number of internal policies and procedures which are relevant for mitigating the risk of modern slavery and human trafficking occurring in its business or any of its supply chains. In particular, the following policies contribute towards mitigating the risk of modern slavery and human trafficking:

(I) Recruitment Policy. Validus follows a robust recruitment policy, including conducting eligibility to work checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. Only specified, reputable recruitment agencies are used to source labour and any new agency is verified before they are used.

(II) Whistleblowing Policy. This ensures all employees are aware that they can raise concerns about how colleagues are being treated, or practises within the organisation without fear of reprisals. Our employees are encouraged to report any breaches of policies or any other concerns that have come to their attention.

Risk Assessment for Slavery and Human Trafficking

Validus applies risk assessment policies and procedures that are proportionate to their size, structure and location. Validus is of the opinion that it faces a low risk of slavery and human trafficking in its business and supply chains.

This assessment is based on the following reasons:

i) the nature of its business;
ii) the territories in which it is active;
iii) a clean track record; and
iv) the limited range of goods and services forming its supply chains.

Due Diligence Processes and Training

The following due diligence procedures to review our supply chains and prospective clients apply:

(i) Supply Chains.

As part of the financial services sector, Validus recognises that it has a responsibility to take a robust approach to modern slavery and human trafficking. Validus is committed to improving its practices to combat modern slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from modern slavery and human trafficking.

Given the nature of its suppliers, who are either financially regulated themselves or supply financially regulated firms, the majority of suppliers and business is done from locations which are considered to be a very low risk of engaging in modern slavery, forced labour or human trafficking. Our supply chains are generally short and direct, in that our service cannot be resold and must be consumed by our clients directly.

(ii) Client due diligence.

All clients undergo a simplified or enhanced due diligence process whereby they are screened for evidence of criminal activity, adverse media and sanction lists. Under the aforementioned information, Validus assesses if the client presents any risk from a modern slavery and human trafficking perspective.

(iii) Training

Validus provides a mandatory online training course on modern slavery and human trafficking to all staff members across the firm alongside wider training on financial crime, bribery, corruption, data protection and other related topics. Each financial year, employees receive e-learning modules followed by examination on the module material provided. Validus intends to periodically update this training in the future.

Board Approval
Validus takes full responsibility and accountability for upholding this Statement and it was approved by the Board of Directors of Validus on 26 June 2024.