Anti-Slavery Statement

Constantin Capital Limited is a single family office. It is part of a global family office comprising family office services that are separate legal entities.

We are a values-driven organization and we aspire to meet the highest professional, legal and ethical standards.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business.

Beyond our own organization, we take seriously our commitment to assist organizations and initiatives that promote human rights and tackle forced-labour and child-labour practices. We provide support to a range of philanthropic, civic, and cultural organizations that work on these issues at both a global and local level through donations and pro bono activities.

This statement sets out our approach to modern slavery.

Given the nature of the services we provide and the professional workforce we employ, we assess the risk of modern slavery or human trafficking in our organization to be low.

We consider our supply chain typical of a single family office. Our supply chain comprises primarily services, including professional advisory services, administrative services, travel services and IT services, as well as office supplies. We have reviewed our supply chain and believe the overall risk of modern slavery is low due to:

  • The nature of the goods and services we procure (mostly services, mostly skilled professions).
  • The locations from which we procure them (mostly in developed markets).
  • Our procuremment practices (for example, we agree to reasonable terms and ensure timely payment).

While the overall risk is low, these criteria also enable us to identify where the risk may be higher.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. Our Supplier Code of Conduct reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain.

We have embedded checks for modern slavery in our routine supplier due diligence process and have raised awareness of these issues with colleagues who manage the supplier vetting process.

Our due diligence process reflects the relative risk for potential suppliers and includes:

  • Checks against global sanctions and enforcement databases, for example OFAC and the World Bank Debarment List, and subject to adverse media review to identify risks including human rights abuses, human trafficking and labour violations.
  • Plans to embed in our risk assessment an evaluation of modern slavery based on criteria such as the country of operation and government response, as assessed by the Global Slavery Index.
  • Those potential suppliers identified as medium or high risk are subject to further vetting and evaluation based on the specific supplier’s circumstances. This includes higher risk and higher spend suppliers, who will be asked as part of a questionnaire about their policies and procedures in place regarding human rights, modern slavery, forced labour, child labour or human trafficking.
  • As part of our supplier policy, we require suppliers to fully comply with the applicable legal requirements of slavery, forced labour and human trafficking laws, including the UK Modern Slavery Act 2015, and expect suppliers to enact practices to ensure compliance with such laws.

We do not engage with suppliers whom we know or believe fail to operate to similar ethical standards and treat their staff with respect.

We support our human rights related policies with internal guidelines, regular awareness and training. Every member of the organization has the right to raise concerns about values, ethics and professional conduct, without fear of retribution.

We remain committed to continually improving our practices to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement.