Modern Slavery Act 2015 ("the Act")
Slavery and human trafficking statement for the Financial Year 2020 GAM (U.K.) Limited and its subsidiaries identified in Schedule 1
This statement is issued by GAM (U.K.) Limited (the “Company”), a company incorporated under the
laws of England and Wales and a member of the GAM Holding AG group (“GAM”), on behalf of itself
and its UK subsidiary entities who are required to make a statement (as identified in Schedule 1)
(together the “Relevant Entities”), in compliance with section 54 of the Modern Slavery Act 2015 (the
“Act”). This statement constitutes the Relevant Entities’ Modern Slavery and human trafficking
transparency statement for the financial year ended 31 December 2020 and sets out the Relevant
Entities’ approach to the prevention of slavery, servitude, forced or compulsory labour (together,
“Modern Slavery”) within the relevant organisation and its supply chains.
The GAM group is one of the world’s leading independent asset management groups focused on
active investing. GAM group entities manage investments for a wide range of clients, including
institutions, wholesale intermediaries and financial advisers. GAM is headquartered in Switzerland
and is listed on the SIX Swiss Exchange.
As the Company’s trading subsidiary entities are regulated investment management entities, primarily
operating in major financial centres, and given the nature of the services procured from suppliers, the
Relevant Entities believe the risk of Modern Slavery arising within their businesses, or within the
businesses of their suppliers, to be limited.
The Relevant Entities’ supply chains include:
- Third party distribution companies and platforms that enter into arrangements to distribute or
promote GAM’s proprietary investment funds and investment strategies;
- Third party outsourcing and professional services companies that provide a range of
professional services to the Relevant Entities, including IT services, legal advice, audit and
- Third party commercial real estate, cleaning, office equipment and supplies and services
required to support staff in the Relevant Entities’ offices; and
- Third party providers of private healthcare, employee benefits and other associated services
required to support the Relevant Entities’ staff.
Policy on Slavery and Human Trafficking
The Relevant Entities are committed to ensuring that their supply chains are free of any slavery
and/or human trafficking and will not knowingly support or do business with any supplier who is
involved in such activities. The Relevant Entities expect their employees, contractors and suppliers to
prevent acts of modern slavery and human trafficking from occurring within both their businesses and
supply chains. The Relevant Entities have corporate policies in place under which employees are
encouraged to report concerns of non-compliance with FCA rules or statutory obligations, including
those under the Act, to the relevant Compliance or HR department. Any concerns raised in respect of
the Act will be escalated to senior management for review and investigation.
Due diligence processes
In any procurement process appropriate due diligence is conducted to assess the extent of the
Relevant Entities’ exposure to the risk of slavery. This includes measures such as:
- incorporation of questions in procurement documents covering the service provider’s or
supplier’s working practices; and
- placing a contractual obligation on the service provider or supplier to comply with all
applicable laws which, where relevant, would include compliance with the Act.
The above measures are applied proportionately in accordance with the Relevant Entities’
assessment of the level of risk associated with the particular supplier. Consideration is given to the
nature of products or services and the locations from which those products are made, or services
All staff at Relevant Entities with responsibility for procurement from third party suppliers receive
appropriate training on their obligations under the Act and how best to meet those obligations. In
addition, the Legal and Compliance Departments provide on-going advice and support to such staff,
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and was approved by the Relevant Entities’ Boards of Directors on 15 April 2021 and is effective as of 11 April 2021.
Schedule 1: Subsidiary entities required to make a statement
GAM International Management Limited