Modern Slavery Act Transparency Statement 2022
Angelo, Gordon Europe LLP (“AG Europe”) is authorised and regulated by the Financial Conduct Authority (“FCA”). AG Europe provides investment advice and services to Angelo, Gordon & Co. L.P. and its affiliates (together AG Europe and Angelo, Gordon & Co. L.P. are referred to as “Angelo Gordon”). Angelo Gordon is a global alternative investment management firm.
This statement is made pursuant to section 54(1) of the UK’s Modern Slavery Act 2015 (“MSA“) in respect of the financial year ended 31 December 2021 for Angelo Gordon.
Introduction
Angelo Gordon acknowledges the importance of compliance with the MSA. Modern slavery, as referred to in the MSA, includes slavery, servitude and forced or compulsory labour, and human trafficking. Angelo Gordon’s approach to corporate governance, including modern slavery, is set out in the firm’s policies, including its firmwide policy on Environmental, Social, and Corporate Governance (“ESG Policy”). Angelo Gordon is committed to conducting its business with integrity and without modern slavery in either its business or its supply chain and to being transparent in its approach, consistent with Angelo Gordon’s obligations under the MSA.
Due Diligence and Supply Chains
The direct supply chain to Angelo Gordon is typical of companies in the financial sector and includes other regulated financial service providers, professional advisers, consultants and contracted staff. Angelo Gordon considers that the risk of modern slavery and trafficking within its supply chain continues to be low due to the fact that the majority of Angelo Gordon’s suppliers are professional and business services firms.
Angelo Gordon keeps these relationships under review, conducts regular KYC/regulatory authorisation checks (where relevant) and evaluates risks relating to modern slavery to the extent such risks may arise in the course of due diligence activities.
Angelo Gordon is committed to acting ethically and with integrity in all of Angelo Gordon’s business relationships and to implementing and enforcing effective systems and controls, as well as training, as needed, designed to ensure modern slavery is not taking place anywhere in Angelo Gordon’s business or supply chains.
Policies and Procedures
Angelo Gordon also operates a Whistleblowing Policy designed to protect any member of staff that raises concerns about any risk, including relating to modern slavery. If issues are identified in relation to modern slavery, these will be escalated to Angelo Gordon’s ESG Committee.
Where it occurs in the world, modern slavery can also involve financial crime offences. Angelo Gordon has several policies and procedures in place designed to prevent financial crime generally and specifically for the purpose of preventing and detecting money laundering, terrorist financing, breach of sanctions, fraud, bribery and corruption.
Key Risks and Effectiveness
Angelo Gordon considers that its overall modern slavery risk is relatively low. The business model of Angelo Gordon means that it generally only deals with persons that are: (i) regulated (either within the financial sector or other sectors); (ii) reputable and well-established; (iii) based in jurisdictions which have low risk of modern slavery; and/or (iv) are usually themselves either subject to anti-slavery legislation or are conducting business whose brand could be very adversely affected by the use of modern slavery and therefore could reasonably be expected to be alert to avoiding modern slavery.
In addition, Angelo Gordon has recruitment procedures designed to help combat modern slavery through the use of reputable employment agencies to source staff and by undertaking background checks for the vetting of new staff. Angelo Gordon believes its employment policies and procedures are fair, transparent and implement positive working practices for all staff. Angelo Gordon aims to embed the principles of trust, honesty, objectivity, fairness and respect for others in all its staff. All staff of Angelo Gordon must read, understand and comply with the policies and procedures that are applicable to them. These are kept under review and enhancements are made where appropriate.
The effectiveness of the steps taken to ensure there is no modern slavery in the business or supply chain is kept under periodic review by Angelo Gordon’s ESG Committee.
Training
Training is provided to all staff around Angelo Gordon’s culture, values and conduct expectations. Angelo Gordon will seek to continue to raise awareness and educate staff about modern slavery and the importance of its eradication generally.
Monitoring and Reporting
Any significant issues identified in relation to modern slavery should be immediately reported to our Legal and Compliance team.
Angelo Gordon’s Legal and Compliance team will report any material changes to the risk of modern slavery in its business or supply chain to the ESG Committee. Any instances of modern slavery identified will be reported to the ESG Committee, alongside any suspicions or concerns relating to modern slavery raised in the respective period.
All instances, suspicions or concerns raised will be treated confidentially, as of very high importance and addressed as quickly as possible.
To date no such breaches or concerns have been identified.
Angelo Gordon will periodically review and, as appropriate, update this statement.
This statement is made pursuant to section 54(1) of the MSA in respect of the financial year ended 31 December 2021 for Angelo Gordon.
Approvals
This statement was approved by the managing member of Angelo, Gordon Europe LLP and Angelo, Gordon & Co, L.P.’s ESG Committee.
UK Stewardship Code and Shareholder Rights Directive Disclosure
Angelo, Gordon Europe LLP (“AG Europe”) is authorised and regulated by the UK Financial Conduct Authority as an investment firm. AG Europe manages investments solely on behalf of Angelo, Gordon & Co, L.P. and its affiliates (collectively, “Angelo Gordon”).
Angelo Gordan is a global alternative investment management firm. As AG Europe manages investments solely on behalf of Angelo Gordon, it applies shareholder engagement policies which are determined by Angelo Gordon on a firmwide basis. Angelo Gordon’s approach to corporate governance (including shareholder engagement) and stewardship is set out in the firm’s policies, including its firmwide policy on Environmental, Social, and Corporate Governance (“ESG Policy”).
UK Stewardship Code
FCA COBS 2.2.3R requires FCA authorised firms to disclose whether they conform to the requirements of the UK Financial Reporting Council’s Stewardship Code (the “Code”). While AG Europe and Angelo Gordon generally supports the principles and objectives of the Code, AG Europe does not consider it appropriate to conform to the Code at this time.
When managing investments, AG Europe adopts our firmwide ESG Policy which is applicable across all investment strategies. The ESG Policy forms an integral part of the engagement by Angelo Gordon with investors, investee companies and other stakeholders. A copy of the ESG Policy is available on request.
SRD II
COBS 2.2B.5R, which implements the requirements under Article 3g of the revised Shareholder Rights Directive (“SRD II”) in the UK, requires FCA authorised firms to develop and publicly disclose an engagement policy and publicly disclose on an annual basis how its engagement policy has been implemented; or to explain why it has chosen not to comply with the requirements.
As AG Europe manages investments solely for Angelo Gordon, it is not practicable for it to have an engagement policy separate from our firmwide policy. On that basis, although AG Europe generally supports the objectives of SRD II, AG Europe has decided not to adopt a separate engagement policy under SRD II, as it does not consider it appropriate, or practicable, to adopt an approach solely relating to a specific region or jurisdiction.
MifiD 2 Best Execution Reports (RTS 28)
2017
- Best Execution – April 2018 Equity Derivatives Disclosure
- Best Execution – April 2018 Securitized Derivatives Disclosure
- Best Execution – April 2018 Credit Derivatives Disclosure
- Best Execution – April 2018 Debt Instruments Disclosure
- Best Execution – April 2018 Equities Disclosure
2018 and later
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