Modern Slavery Policy - Iguana Investments

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Iguana Investments Ltd - Modern Slavery Policy

Iguana Investments Ltd (“Iguana”) is authorised and regulated by the Financial Conduct Authority ("FCA") in the United Kingdom. The content of this website is for information only and is not intended to be independent investment research. It is not an invitation to buy or sell an investment and is not advice on investments, taxation or on any other matter. The investment services of Iguana Investments Ltd are only available to professional clients and eligible counterparties for the purposes of the FCA’s rules. They are not available to retail clients. This information is not intended to be used by or distributed to any person or entity in a jurisdiction or country where this would be contrary to local law or regulation. We believe the information in this document is based on reliable sources, but its accuracy cannot be guaranteed. The opinions expressed represent our views at the time of publication and are subject to change. Iguana Investments Ltd will not be liable for any losses relating to the accuracy, completeness or use of information in this document, including any consequential loss. Past performance does not predict future results and the capital value of investments and the income generated can fluctuate. Where investments are exposed to currencies other than the base currency, they may be subject to foreign exchange rate fluctuations. The registered office of Iguana is Kemp House, 160 City Road, London, EC1V 2NX. Copyright©2020, Iguana Investments Ltd. All rights reserved.
Introduction from the CEO:
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We are committed to improving our practices to combat slavery and human trafficking. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Iguana Investments Ltd’s slavery and human trafficking statement for 2020.

About us
We are an asset management business and in this regard, we provide services that specialise in the long-term management of client’s money. We are regulated by the FCA (Financial Conduct Authority).

Our supply chains
We believe that the risk of slavery or human trafficking is relatively low within our supply chain. Our suppliers are primarily located in the UK, US North America and Western Europe and our supply chain includes:
  • Regulated professional advisors (accountants, lawyers)
  • Regulated financial service providers (brokers, banks)
  • Professional IT service providers that support the asset management industry
We have several policies in place to prevent financial crimes in general including:
  • Anti-bribery policy
  • Anti-money laundering and terrorist financing policy
  • Compliance
  • Fraud
Our policies on slavery and human trafficking
We have a zero-tolerance policy on modern slavery and human trafficking. And as such, we are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We have systems in place to monitor potential risk areas within our supply chain and to protect whistle blowers. We have in place systems to:
  • Identify and assess potential risk areas in our supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains.
  • Monitor potential risk areas in our supply chains.

We have in place systems to:       
  • Protect whistle blowers
  • Employees & Training
Our recruitment is transparent, and we communicate clearly with candidates to discuss job opportunities and confirm details of employment where applicable. We have policies and procedures in place to ensure compliance with all human rights laws and UK employment laws and all staff are remunerated fairly and above the UK’s national living wage. We are satisfied that our employees are not exploited in any way.
Our employees are required to act with integrity and in compliance with the Code of Ethics set out in the employee handbook. Further, to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. Our employees are required to ensure that all relationships in the workplace are respectful, free of harassment, bias, bullying and violence. We have no tolerance for such harassment or discrimination in the workplace or among our employees.

Planned Actions: Given that the risk of modern slavery and human trafficking remains low in the industry we operate, the steps we plan to take regard mitigating modern slavery are focused on key service providers:
  • Due diligence: ensuring that all suppliers (new and existing) are compliant with laws (including MSA) and are continually updating their approach and monitoring operations
  • Training: maintain or appropriately update staff training to educate employees on slavery and human trafficking
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