Anti Modern Slavery Statement

 

1. Modern Slavery Statement
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 have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships. We are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
This policy makes reference to the modern Slavery act of 2015 and although RiverRock does not meet the threshold for a mandatory statement we believe it demonstrates our commitment to transparency in our own business and in our approach to tackling modern slavery throughout our supply chains ensuring that modern slavery does not exist at RiverRock or, to the best of our knowledge, in our supply chain or investment companies.

2. About this Policy
This policy applies to all persons working for us or on our behalf in any capacity, including (but not exclusively): employees, partners, interns, agents, contractors, external consultants, third-party representatives and business partners, wherever they may be located.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are provided with adequate and regular communications and training on the issue of modern slavery.
This policy will be subject to annual reviews overseen by the Human Resources and Risk departments. The Executive Committee of RiverRock has ultimate responsibility for ensuring this policy complies with our legal and ethical obligations.

3. Compliance with the policy
All employees, volunteers, interns, contractors, external consultants, third-party representatives and business partners must ensure that they read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for RiverRock or under our control. Staff are required to avoid any activity that might lead to a breach of this policy and must notify the Head of Human Resources as soon as possible if they believe or suspect that a conflict with this policy is occurring, has occurred, or may occur in the future.

4. Commitment
RiverRock commits to:
4.1 Undertaking a risk assessment of our business to evaluate the nature and extent of our exposure to the risk of modern slavery and human trafficking within our firm and our supply chain
4.2 Requiring existing and potential suppliers to provide information relating to their anti-modern slavery and human trafficking policies as part of the due diligence and onboarding process
4.3 Terminating existing agreements or discussions with potential suppliers in the event that they are unable to supply such policies and termination of contract in the event of a violation
4.4 Training all staff about their rights and responsibilities under the modern slavery policy on an annual basis as part of the firm’s conduct training
4.5 Clear whistleblowing procedure to empower staff to report any concerns in confidence without fear of retaliation.
4.6 Reviewing this policy on an annual basis, or more regularly if necessary, to ensure compliance with legal, regulatory and industry expectations