Modern Slavery Act 2015

      Voluntary Slavery and Human Trafficking Statement

      Voluntary Slavery and Human Trafficking Statement (the “Statement”)

      Waystone (as defined in the Appendix to this Statement) is making a voluntary Modern Slavery and Human Trafficking Statement relating to section 54 of the Modern Slavery Act 2015.

      Waystone opposes slavery and human trafficking in all its forms and make this Statement to convey Waystone’s values and commitment to ethical trading and its stance against slavery and human trafficking.

      About us

      Waystone is one of the world’s leading providers of Governance, Risk and Compliance services to the asset management industry.

      As Waystone is comprised primarily of regulated entities and given the nature of the services procured from suppliers, Waystone believes the risk of Modern Slavery arising within the business to be limited.

      Although we are not required to make a modern slavery statement under section 54 of the Modern Slavery Act.2015, we are making this voluntary statement to show our commitment to ethical trading principles and to set out the steps we propose to take to tackle modern slavery and human trafficking in our business and in our supply chains.

      Our supply chains are mainly made up of the following:

      • Third party investment service providers that perform services for the funds under management;
      • Third party outsourcing and professional services companies that provide a range of professional services to Waystone, including IT services, legal advice, audit and payroll services;
      • Third parties that provide cleaning, office equipment and supplies and services required to support staff in the Waystone office; and
      • Third party providers of private healthcare, employee benefits and other associated services required to support Waystone staff.

      Our commitment to ethical trading

      Our Code of Ethics reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to prevent unethical business practices and criminal activity.

      Waystone has corporate policies in place under which employees are encouraged to report concerns of non-compliance with regulatory rules or statutory obligations

      We are committed to ethical trading principles and to acquiring goods and services without harm to others.

      Due diligence and risk assessment

      Waystone is in the process of taking steps to help identify and monitor the risk of slavery and human trafficking in our supply chain.

      Waystone will look to vet suppliers and sub-contractors to try and ensure that they are committed to ethical practices. Waystone will not support any business knowingly involved in modern slavery and/or human trafficking.

      Effectiveness in combating slavery and human trafficking

      Waystone will consider using key performance indicators (KPIs) to measure how effective we have been at ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains.


      The Legal and Compliance Departments will provide advice and support to Waystone staff, as required.
      Waystone staff are required to review the Code of Ethics and to agree to abide by same.

      In addition, Waystone will consider providing relevant staff with responsibility for procurement from third party suppliers to receive specialist training on their obligations under the Act and how best to meet those obligations.

      Approval procedure

      This statement was approved by Waystone and will be reviewed on an annual basis or as may be required.

      Appendix 1

      Waystone shall be understood to mean the following entities:

      • Waystone Management (UK) Limited;
      • Waystone Capital Solutions (UK) Limited;
      • DMS Capital Solutions (UK) Limited;
      • WS Centralised Services (UK) Ltd;
      • Waystone Governance (UK) Limited.
      • Waystone Fund Services (UK) Limited (WFSL)