Pure Research Limited – Anti-Slavery and Human Trafficking Statement

Introduction from the General Counsel

We, Pure Research Limited, are committed to improving our practices to combat slavery and human trafficking in our business and supply chain.  We are committed to ensuring that we take all steps within our control to address the risks of modern slavery.  We take great care in regard to the people we hire either on an employment basis or as third-party contractors.  Furthermore, we undertake due diligence on any parties that are to become suppliers or customers of the company.

Organisation's structure

We are a provider of services in the fund management sector. We are a standalone company with head office in the United Kingdom.  

While our annual turnover is below £36m, the board of directors has taken the decision to publish this modern slavery and human trafficking statement, as well as adopt an appropriate company policy.

Our supply chains

Our supply chains only include data providers who themselves have published their own modern slavery statements and policies, which we have reviewed to ensure they meet our own requirements.

Our policies on slavery and human trafficking

We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies.

Our Anti-slavery Policy 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 chains.

Due diligence processes for slavery and human trafficking

We understand that, in relation to our own business, the following areas give rise to the highest modern slavery risks:

• the hiring of personnel
• engaging third-party contractors
• the sourcing of data products

As part of our initiative to identify and mitigate risk we undertake background checks on all personnel, whether they are employed or engaged as contractors, to ensure they have a right to work and bear little to no risk of being subject to modern slavery or trafficking.

We also have in place systems to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a  supply chain compliance programme. This consists of research into the practices and policies of our suppliers, as well as any information that we are able to find from conducting due diligence from available resources.

We have a compliance team, which consists of involvement from the following departments:

• Legal.
• Procurement.
• Sales.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.

Further steps

Following a review of the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:

• Regular screening of our suppliers on their alignment or adherence to the UK Modern Slavery Act 2015, Australia’s Modern Slavery Act 2018;
• Obtaining employee confirmation of their understanding of our Company policies; and
• Senior management reviewing the Company policies on a regular basis and signing off on any material amendments to such policies.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending December 2023. It was approved by the board on 22nd February 2024.

Gavin Nathanson, director

Pure Research Limited

Date: 23rd February 2024