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Modern Slavery Act - Annual Transparency Statement for the year ended December 31, 2019

I. Introduction

The Executive Office (GBR) LLP (“The Executive Office”) is committed to preventing acts of modern slavery and human trafficking from occurring within both its business and supply chains. This statement is made on behalf of pursuant to section 54 of the Modern Slavery Act 2015 of the United Kingdom (“Modern Slavery Act”).

At The Executive Office, we have a long-standing culture of “Doing What’s Right,” Employee Code of Conduct. These specific initiatives, coupled with our belief that transparency and accountability promote healthy, stable financial markets, are intended to help us achieve the highest of standards and continue to progress and evolve our social and ethical responsibilities.


II. Organizational Structure

The Executive Office is investment banking and investment management firm. We provide services to Professional Clients all over the world. We are headquartered in London, United Kingdom. We employ less than 250 people and procure goods and services from a few vendors, mainly in the United Kingdom. To find out more about the nature of our business, please visit our website www.TheExecutiveOffice.com


III. Governance and Policy

We are committed to acting ethically, with integrity and promoting work environments that engender conditions of freedom, equality, security and dignity. The Executive Office expects its employees, contractors, and suppliers to prevent acts of modern slavery and human trafficking from occurring within both its business and supply chains and has policies (including its Human Rights Statement) and codes of conduct (including the Employee Code of Conduct and the Supplier Code of Conduct) in place to establish standards expected across our business activities. Our governance framework and related corporate policies empower our employees and contractors to report and escalate any concerns of unethical conduct, whether relating to modern slavery, human trafficking or other matters.

As part of our continued commitment to responsible supply chain management and sustainable procurement, and in response to the Modern Slavery Act, we enhanced our Supplier Code of Conduct by clarifying our requirements in this area. The Supplier Code of Conduct, which is available on our website, applies to all vendors in our supply chain globally. It describes the expectations we have of our vendors to conduct business responsibly, including with respect to compliance with the requirements of applicable slavery, forced labour, child labour and human trafficking laws. The Supplier Code of Conduct describes The Executive Office’s commitments regarding social responsibility, health and safety, labour and human rights, ethics and other responsible business practices.

All vendors engaged in providing products and services to The Executive Office are expected to act in accordance with the Supplier Code of Conduct, including by aligning their guidelines, policies and practices with the Supplier Code of Conduct and by communicating and enforcing its provisions throughout their organizations and supply chains. A violation of the requirements of the Supplier Code of Conduct may lead to review or termination of our relationship.

Our Employee Code of Conduct and our policies on Whistleblowing, Escalation and Speaking Up, Reporting of Illegal or Unethical Conduct and Non-Retaliation, and Suspicious Activity Reporting empower our employees and contractors to report concerns in confidence without fear of retaliation.


IV. Risk Assessment

We have evaluated the nature and extent of our exposure to the risk of modern slavery and human trafficking in industries and geographies that we perceive to be of higher risk, including real estate, construction, and facilities management. Based on this risk evaluation, we introduced mandatory training to our key procurement staff, specifically addressing the identification of risks of slavery and human trafficking within our supply chain. We will continue to assess the risks associated with our business and supply chain and expand the scope of our focus, as necessary.


V. Training

We acknowledge that educating our staff is fundamental to ensuring potential human rights and modern slavery risks are identified and managed. The Executive Office’s current on-boarding and refresher training for staff include The Executive Office’s Code of Conduct, with a specific focus on conducting business in full compliance with all applicable laws and regulations, and in accordance with the highest ethical standards; and willing to take a stand to correct or prevent any improper activity.


VI. Continuing Efforts and Commitment

We will continue to assess our practices and engage with our people and vendors to raise awareness and manage the risk of modern slavery and human trafficking occurring in our organization and supply chain.

This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 of the United Kingdom and constitutes The Executive Office’s modern slavery and human trafficking transparency statement for the year ended December 31, 2018.


Managing Partner

Nabil Maaloul

January 8, 2020.