Modern Slavery and Human Trafficking Statement 2019
York Capital Management Europe (UK) Advisors, LLP is a BIPRU firm regulated by the Financial Conduct Authority. The following statement has been published on behalf of York Capital Management Europe (UK) Advisors, LLP and York Capital Management UK Advisors Limited (together, “YCM UK” or “the Firm”) pursuant to section 54 of the UK Modern Slavery Act 2015.
YCM UK is committed to respecting human rights and operating with integrity in regards to all aspects of its business. This Statement sets out the steps the Firm has taken to understand the risks posed by modern slavery and ensure such activity does not occur as a result of its business ventures.
Organisational Structure and supply chain
The Governing Body of YCM UK is responsible for ensuring the Firm operates within an established framework of effective systems of internal control, risk management and compliance with applicable laws, rules, and regulation. The Governing Body is ultimately responsible for the risk framework of the Firm.
Given the size and scope of the Firm and the limited scope of its business activities, the Governing Body has not created separate decision-making committees.
The Firm’s Governing Body is comprised of individuals with extensive experience building and running an investment management business on a global scale and which have been with the Firm for a long time, and as a result the Firm has a strong culture of accountability for compliance with applicable laws, rules and regulation.
YCM UK provides certain advisory, consulting and other services to its US parent. YCM UK has particular expertise in analyzing worldwide financial markets, trends and prospects, and in identifying and developing opportunities to derive value therefrom, all of which its US parent considers may be valuable to the York business of managing assets, including investing the assets of hedge funds, private equity funds, and other traditional and alternative asset investment vehicles and managed accounts.
Due to the nature of the Firm’s business it 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.
The Firm does not have a dedicated anti–slavery policy although the employee code of conduct makes it abundantly clear that employees are expected to behave ethically and operate with integrity at all times. The Firm prohibits all of its employees, clients and service providers from engaging in the use of forced or trafficked labour. An effective whistleblowing policy is in place to ensure that, should an employee or employees uncover evidence of the use of forced labor, they will be able to report their concerns and be protected from victimisation.
The Firm preforms extensive due diligence on its suppliers and service providers.
These procedures are reviewed annually to ensure they continue to effectively mitigate the risk of forced labour occurring in relation to any of the Firm’s business activities.
The Firm continually takes steps to enhance its anti-slavery measures and what has already been achieved.
Staff awareness and training
All members of staff have been made aware of the UK Modern Slavery Act 2015 and its content.
Approval by the Governing Body
The Firm’s Governing Body approved this Statement in March 2019, and will review and update it on an annual basis.