Statement on slavery and human trafficking
Universities Superannuation Scheme Limited and USS Investment Management Limited
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (‘the Act’) and constitutes
our slavery and human trafficking statement for the financial year 1 April 2022 to 31 March 2023.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as
slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the
deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Universities Superannuation Scheme Limited (‘USSL’) and its subsidiary USS Investment Management
Limited (‘USSIM’) (together (‘USS Group’)) have zero tolerance for any activity which constitutes modern
slavery or human trafficking under the Act and we are committed to combatting all such practices. We are
committed to acting ethically and with integrity in all our business dealings and relationships and to
implementing and enforcing effective systems and controls to ensure modern slavery is not taking place
anywhere in our own business or (within the limitations of our controls over third parties) in any of our
supply chains. We are fully committed to complying with all aspects of the Act.
USSL is the corporate trustee of the Universities Superannuation Scheme (‘scheme’), an occupational
pension scheme for the higher education sector and USSIM is its wholly owned internal investment
manager. We invest the scheme’s assets as trustee in the UK and on a global basis in a variety of different
types of investments. Full details of our corporate structure appear on our how we're governed page.
Our supply chains
Due to the nature of our business, we consider that the group operates in a low risk sector. We operate in
the financial services industry. Our supply chains relate mainly to the following areas: investment
management service providers, advisory services (legal and management), accountancy services and a
range of other ancillary services necessary for the effective operation of the scheme and businessincluding
building services, IT, consultancy, recruitment and training.
Our investment approach
We are committed to responsible investment and we view our commitments and obligations to tackle
modern slavery and human trafficking as fundamentally important. We seek to include environmental,
ethical, social and corporate governance (‘ESG’) considerations within our investment decision making
processes and are an active owner using ourinfluence as amajorinstitutional investorto promote good ESG
practices. Our investment approach, including our Statement of Investment Principles, Investment Beliefs
and Stewardship Code statement can be found on our principles and approach page.
Our policies on slavery and human trafficking
We are committed to taking all reasonable steps to try and ensure that there is no modern slavery or human
trafficking in our supply chains and this is reflected in the USS Code of Conduct. The USS Code of Conduct
articulates our commitment to acting ethically and with integrity, and to implementing and enforcing
effective systems and controls to try and reasonably ensure that slavery and human trafficking is not taking
place anywhere in our operations or, asfar as we can reasonably control, in our supply chains.
Due to the importance of continuing to prevent modern slavery and human trafficking, we have developed
a Modern Slavery policy to deal with these issues. The policy includes an overview of key legislation and
details on how to report suspected breaches.
Our Recruitment Policy includes provisions to ensure that the recruitment process is fair, consistent and
robust. The policy includes a requirement that only approved recruitment agencies may be used and all
candidates must evidence their eligibility to work in the UK. This helps to safeguard against the risk of
modern slavery in the recruitment process.
Our Supplier Code of Conduct (‘Supplier Code’) holds our supply chain accountable and prohibits the use of
forced, compulsory, bonded (including debt bondage) or indentured labour, involuntary prison labour,
slavery, servitude or trafficking of persons and unlawful child labour. All relevant suppliers receive a copy
of, and are asked to comply with, the Supplier Code before onboarding.
Due diligence processes for slavery and human trafficking
Our current practice and processes as well as our supplier list are under regular review in order that we
continue to have systems in place to:
- identify and assess potential risk areas in our supply chains and operations;
- mitigate the risk ofslavery and human trafficking occurring in our supply chains; and
- monitor potential risk areasin our supply chains and relationships.
As part of our controls to identify and mitigate risk in our supply chain, we use reasonable efforts to ensure
that contracts that we enter into with suppliers contain provisions which relate to adherence to the Act
Our Whistleblowing Policy is designed to encourage employees to promptly report any suspected
wrongdoing or dangers at work. Employees can make such reports in the knowledge that their concerns
will be taken seriously and investigated appropriately and confidentially.
USS Group plan to make training on modern slavery available to all our employees. This is designed to raise
awareness of what modern slavery is, who is affected, how to spot the signs of modern slavery, and what
to do if you spot the signs of modern slavery. This training will be compulsory for those employees, who
are most likely to come across potential risk areas.
All employees are required annually to complete training on whistleblowing, to ensure they are aware of
the appropriate reporting mechanisms if they do have any suspicions of any wrongdoing, including modern
All employees are regularly required to complete training on anti-money-laundering (noting that the
proceeds of crime could include the proceeds of modern slavery) and counter terrorist financing, to ensure
all employees can identify the signs of suspicious activity and understand our due diligence and suspicious
activity reporting processes.
Signed on behalf of Universities Superannuation Scheme Limited:
Group Chief Executive Officer
Universities Superannuation Scheme Limited
Date: 4th September 2023