Modern Slavery Transparency Statement

Modern Slavery

BlueCove Limited (“BlueCove”) was incorporated on 22 March 2018. BlueCove’s business objective is to research, develop and advance scientific investment processes applicable to fixed income investment management. BlueCove will offer investors scientifically-driven alternatives to traditional fixed income discretionary strategies. BlueCove is targeting the first half of 2019 for FCA for authorisation and will then launch its initial suite of scientific investment products during the third quarter of 2019, following phase one of an R&D programme currently in progress.

BlueCove takes compliance seriously. This includes a strong commitment to the opposition of modern slavery and forced labour, where forced labour means any conduct which is an offence under Part 1 of the Modern Slavery Act 2015, including slavery, servitude, any type of forced or compulsory labour and trafficking for the purposes of exploitation.

It is BlueCove’s policy not to tolerate any form of forced labour either within its business or within its supply chain. BlueCove will take such reasonable measures as may be appropriate to minimise the risk of this taking place in line with the nature of services provided to BlueCove.

BlueCove’s employees are highly skilled and are all paid well above the London Living Wage. BlueCove employees are entitled to a variety of employment benefits (including medical insurance and pension) and 30 days’ holiday (in addition to bank holidays) each year.

Given the nature of BlueCove’s business, areas of risk are more likely to be indirect through supply chains, although overall still likely to be relatively low risk compared to many businesses in other sectors. BlueCove undertakes appropriate due diligence and agrees mechanisms designed to minimise the risk of slave labour. In particular, BlueCove performs a risk based review of its service providers to identify high risk providers based on the type of services provided to BlueCove. BlueCove requires its service providers to comply with their obligations regarding Modern Slavery.

At present, as a new company, there are limited agreements in place. However, BlueCove works with a number of highly skilled contractors and has agreements in place to ensure that fees and working conditions are appropriate. BlueCove also engages a cleaning company to undertake office cleaning. Under the terms of the service agreement with the cleaning company, BlueCove pays a higher fee to ensure that cleaners providing that service to BlueCove are paid the London Living Wage rather than the lower National Minimum Wage.

To the best of BlueCove’s knowledge, BlueCove does not believe that any business within its supply chain makes use of forced labour in any form. This policy will be reviewed annually.

November 2018