Modern Slavery Statement

We recognize that modern slavery issues such as forced labour and human trafficking are a significant global issue.

Bentham Asset Management supports action to help ensure that there is no modern slavery or human trafficking in our supply chain or across our business. Bentham supports the UN universal declaration human of human rights.
Bentham’s ESG process includes specific section on Labour management and Supply chain labour standards. The process assists analysts in evaluating these issues for individual credits.

 Bentham Analyst Questions regarding Labour management (see ESG Matrix):

Labor management:

The extent to which the security is exposed to workflow disruptions due to labor unrest or reduced productivity due to poor job satisfaction. Factors to consider include exposure to regions facing labor unrest, labor-related controversies, and corporate restructuring / layoffs; workforce policies, benefits, training, and employee engagement.
• Is there evidence of poor workforce relations in business entities linked to the security? (eg. frequent industrial disputation / strike actions, high profile union disputes, boycotts related to workforce practices, chronic workforce safety issues, etc)
• Are there potential business disruption risks emerging related to developing industrial disruption issues? (eg. poor relation with unions, threatened strike actions, boycott risks)
• Are there labour market factors (e.g. access to labour / skills shortages) which may affect capacity to achieve material business objectives?
• Are cost structures likely to be affected by changing labour market conditions in relevant time frames?
• Are execution of key strategies affected by human capital shortages or competition for talent?

Supply chain labour standards:

The extent to which the security is exposed to reputational risks or production disruptions due to sub-standard treatment of workers in the company’s supply chain. Factors to consider include brand visibility and reliance on outsourced production, labor controversies in the supply chain; labor policies, compliance monitoring, and engagement with suppliers.
• Are there materially significant business activities in emerging markets linked to the security? (resource projects, manufacturing, services).
• Is the business /brand vulnerable to public scrutiny / targeting from activist campaigns? (eg high profile consumer products)
• Have business entities linked to the security been subject to negative attention from controversial workforce practices related to product sourcing in emerging markets? (eg labour rights, human rights, workplace conditions, safety, etc)
• Are there emerging supply chain labour concerns? (eg increasing media attention on dubious workforce standards in the supply chain, etc)
• Is there evidence of workforce exploitation in supply chains related to unequal power relationships?
• Is there evidence of exploitation in third party labour hire firms linked to supply chains?
• Are there significant business disruption events in the past related to labour practices in the supply chain?