Slavery and Human Trafficking Statement

For the financial year ending 31 December 2025

Seven Investment Management LLP (“7IM”) is committed to conducting business with integrity and to taking effective steps to prevent modern slavery and human trafficking in our business and supply chains. We recognise that modern slavery is a serious abuse of human rights and that organisations have a responsibility not only to comply with the law, but also to identify, assess and address risks in a meaningful and proportionate way.

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 (the “Act”) and reflects the reporting areas set out in the Government’s Transparency in Supply Chains guidance published in March 2025. It constitutes 7IM’s Slavery and Human Trafficking Statement for the financial year ended 31 December 2025.

Our Business

At 7IM, we provide investment management, financial planning and platform services to individuals, families, advisers, businesses, charities and trustees. Our business model is service-led and relationship-based, supported by regulated operations, technology and specialist third-party providers.

For financial advisers and planners, this means helping them focus on their client relationships by providing an open-architecture platform, multi-asset investment solutions and discretionary investment management support. For private wealth clients, our approach starts with understanding each client’s circumstances, family context and objectives, and then developing a tailored financial plan designed to support long-term financial wellbeing.

As at March 2025, we operated from offices across the UK, employed approximately 400 people and managed approximately £25.7 billion on behalf of a broad client base. Our services are predominantly knowledge-based and regulated, which influences the nature of our operational and supply chain risk profile.

Our Supply Chains

Our supply chains are primarily made up of providers of regulated financial services and suppliers supporting our technology, data, operations, office environment and other professional and business support services. Many of these relationships are long-standing and a significant proportion of our supplier base operates in the UK, although some suppliers also operate internationally or rely on overseas delivery models and subcontracting arrangements.

Given the nature of our business, we consider the inherent risk of modern slavery in our direct operations to be lower than in sectors with extensive manufacturing, raw material sourcing or large-scale low-paid labour. However, we do not regard a lower-risk profile as a reason for complacency. We recognise that modern slavery risks can arise indirectly through outsourced services, recruitment practices, facilities-related services, complex subcontracting chains and cross-border delivery arrangements. Our approach is therefore to identify where exposure may exist, apply proportionate controls and continue improving our visibility over higher-risk areas of our supply chain.

Our Policies & Procedures

We maintain a framework of policies and procedures that supports ethical conduct, legal compliance and effective escalation of concerns. These include policies and controls relating to anti-money laundering, anti-bribery and corruption, whistleblowing and other financial crime matters, alongside broader governance and risk management processes. Colleagues in Operational, Compliance and Infrastructure roles contribute to the development, implementation and periodic review of these arrangements.

These policies help set expectations for our people, support the identification and escalation of concerns and provide a basis for ongoing assurance. During the year, policy attestations were completed by 100% of employees. We also note that no whistleblowing reports relating to modern slavery were raised during the reporting period. We review our policies and procedures on an ongoing basis so that they remain current, practical and aligned to our risk profile.

Our Approach To Suppliers

During 2025, we completed the implementation of enhanced lifecycle management processes for third-party suppliers. Under this framework, all suppliers were risk-rated and subject to due diligence calibrated to that rating. During the reporting period, 35 new suppliers were onboarded, including 2 Outsourced Service Providers (Tier 1). This enables us to apply greater scrutiny to suppliers and arrangements that present heightened operational, geographic or outsourcing-related risk.

Our due diligence may include assessing a supplier’s control environment, corporate governance, use of subcontractors, geographic footprint and, where relevant, compliance with statement publication requirements under the Act. When entering into new supplier arrangements, we seek appropriate contractual commitments to compliance with applicable laws and regulations, which includes legislation relevant to modern slavery.

We continue to review and refine our third-party risk management processes so that we can strengthen our response over time. This includes ongoing monitoring of all Tier 1 and Tier 2 suppliers and targeted in-person due diligence, on a periodic basis, where we are aware of overseas outsourcing or other supply chain features that may increase vulnerability. During the reporting period, three in-person reviews were completed. Where issues or gaps are identified, these are escalated through our governance processes so that appropriate follow-up action can be considered.

Responsible Investing

Within our investment process, 7IM remains a signatory to the Principles for Responsible Investment (“PRI”) and the UK Stewardship Code. These commitments support our wider approach to Environmental, Social and Governance considerations, including human rights-related issues. We continue to undertake due diligence on firms in which we invest and may request further information on how they approach corporate responsibility matters, including how they consider risks associated with modern slavery.

We have also invested in third-party due diligence resources to support the depth and consistency of our review processes. ESG metrics are monitored through our Risk Management Framework, including quarterly review through the Investment Risk Committee. Among the factors considered are third-party assessments of a company’s exposure to, and management of, key ESG issues, including controversies and global norms relating to human rights.

Training

We recognise that training is an important part of identifying and responding to modern slavery risks. We provide training relevant to anti-modern slavery, anti-money laundering and financial crime, both as part of onboarding for new joiners and through our regular training programme for existing employees. This is intended to help colleagues understand the indicators of potential exploitation, the importance of speaking up and the routes available for escalation.

During the reporting period, all staff completed the relevant training programme, achieving a 100% completion rate. We also achieved a 100% completion rate for onboarding training for new joiners. We keep our training programme under review and assess providers and content periodically so that training remains relevant to our business, responsibilities and risk profile.

Our Effectiveness In Combatting Modern Slavery In Our Business & Supply Chains

We assess the effectiveness of our approach through ongoing review by relevant stakeholders of the steps taken across our business and supply chains. During the reporting period, all suppliers were risk-rated; 35 new suppliers were onboarded, including 2 Outsourced Service Providers (Tier 1); all Tier 1 and Tier 2 suppliers have ongoing monitoring; 100% of employees completed policy attestations; all staff completed relevant training, achieving a 100% completion rate; 100% of new joiners completed onboarding training; and two in-person supplier reviews were completed. No whistleblowing reports relating to modern slavery were raised during the reporting period. Our focus remains on continuous improvement: strengthening controls where appropriate, improving visibility over areas of potential exposure and embedding modern slavery considerations within our wider risk and governance framework.

Our Commitment To Anti-Modern Slavery

In addition to the steps described above, we intend to continue publishing this statement on the Government’s Modern Slavery Statement Registry as part of our commitment to transparency.

7IM is a limited liability partnership and this statement has been approved by 7IM’s Board in accordance with its governance procedures.

Signed:

Duncan Walker
Designated member
For and on behalf of 7IM