This Statement is published pursuant to Section 54(1) of the UK Modern Slavery Act 2015, and any subsequent related UK legislation by Orchard Global Asset Management LLP (“Orchard UK” or “the Firm”) which is an alternative investment manager specializing in credit investment and is regulated in the United Kingdom by the Financial Conduct Authority. Whilst this Statement is made by Orchard UK pursuant to UK law, in respect of similar applicable law in other jurisdictions in which Orchard UK and its affiliates (collectively “Orchard Global”) operate, Orchard Global acknowledges it adheres to the principles set out in this Statement.
Orchard UK is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking. Orchard UK respects human rights and operating with integrity in regards to all aspects of its business. This Statement sets out the steps Orchard UK has taken to understand the potential risks posed by modern slavery and/or human trafficking and ensure such activity does not occur as a result of its business ventures. This Statement refers to actions and activities undertaken during the current calendar year 2023.
As part of the investment management sector, Orchard UK recognises that we have a responsibility to take a robust approach to slavery and human trafficking. Orchard UK is fully committed to preventing such crimes in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Organisational Structure and Supply Chain
Orchard UK operates through affiliated companies globally, with highly skilled staff located in the United Kingdom, United States, Singapore and Canada. It has created a range of alternative investment vehicles located in a wide range of jurisdictions. Both Orchard UK and these investment vehicles utilize service providers located in these jurisdictions. Orchard UK invests across a wide range of credit related investments for the investment vehicles using a range of reputable counterparties. We make a wide range of investments, including in private companies and we take steps in our due diligence to ensure as part of our investment process that there are appropriate arrangements in place to mitigate risk of modern slavery and human trafficking. We do not view any of our group locations, investment vehicle jurisdictions, service providers, counterparties or investments as being at a high risk of modern slavery or human trafficking.
As a supplier of investment management services, Orchard UK does not have an extensive supply chain and the Firm, its suppliers, and its service providers can be considered at low risk of engaging in modern slavery. Whereas we consider the risk of modern slavery to be more prevalent in the manufacturing and distribution of goods, we have also carried out a risk assessment of our activities and ensure that we have engaged reputable suppliers in each of our locations for ancillary but important aspects of our operations including use of temporary staff, office cleaning, and building security.
Orchard UK does not and would not enter into business with any organisation, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.
Steps taken by Orchard UK as well as Orchard Global to ensure modern slavery is not taking place in our organisation or supply chains include, but not limited to the following:
We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Code of Conduct: Orchard Global has an employee code of conduct which governs our employees, officers and directors to behave ethically and operate with integrity at all times. Orchard Global strictly prohibits all of its employees and service providers from engaging in the use of forced or trafficked labour.
- Diverse Recruitment and Selection: Orchard Global has in place robust recruitment and onboarding process with multiple checks built in to ensure all individuals employed by Orchard Global have the right to work in the respective locations wherein Orchard Global operates, are paid a fair salary in compliance with all relevant rules and regulations, and are not subjected to human trafficking or forced labour.
- Whistleblowing policy: An effective whistleblowing policy is in place to ensure that, should an employee or employees uncover evidence of the use of forced labour, they will be able to report their concerns and be protected from victimisation.
- Equal Opportunity and Commitment to Diversity policy: Orchard Global is an equal opportunities employer, and we’re committed to creating and ensuring a diverse, inclusive, non-discriminatory and respectful working environment for our staff free from violence, threats or coercion.
- Disciplinary and Grievance policy: We want all staff to feel confident that they can expose wrongdoing and concerns without any risk to themselves. Where wrongdoing or breached are found, employees will be disciplined accordingly.
- Working with Respect Training: Orchard supports good relationships between employers and employees which underpin business success. The mandatory training covers good corporate behaviours, anti-harassment and bullying. Existing staff are required to undertake training every 3 years and new hires within 2 weeks of start date.
- Robust Anti-Money Laundering and Counter-Terrorism Financing manual: This covers our approach to anti-bribery and corruption, anti-money laundering, antitax evasion facilitation and sanctions. It sets out the minimum control requirements designed to ensure that all Orchard Global’s businesses and legal entities comply with the requirements and obligations set out in relevant legislation, regulations, rules and industry guidance for the financial services sector. This includes the requirement to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This Statement is relevant because modern slavery offences are often linked to money laundering and other financial crimes.
Staff awareness and training
All members of staff have been made aware of Orchard UK’s Statement on the UK Modern Slavery Act 2015 and its content. To raise awareness, Orchard Global have distributed our Modern Slavery and Human Trafficking policy and made this available on our Intranet for easy access. Orchard Global also requires all staff to complete training on modern slavery. The training module covers:
- How to identify signs of slavery and human trafficking;
- What initial steps should be taken if slavery or human trafficking is suspected;
- How to escalate potential slavery and human trafficking issues to the relevant parties within our organisation.
Orchard Global intends to maintain constant contact with its key suppliers to reinforce the message that it requires third parties to comply with applicable laws and that it will not tolerate modern slavery or human trafficking in its supply chain or sphere of influence or control.
Orchard Global will review its arrangements periodically to ensure these remain effective.
This Statement has been approved by the Firm’s Executive Committee, who will review and update it on an annual basis.
Partner, Orchard Global Asset Management LLP