This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (“MODSA”). Aegon Asset Management (Aegon AM) has agreed to make a statement to set out the steps taken to ensure that modern slavery and human trafficking is not taking place in any part of Aegon AM business or supply chains. Aegon AM reviews annually the steps it has taken and its compliance with relevant policies.


Organisation’s Structure

We are a specialist investment management business which manages £37.3 billion1 on behalf of UK and international clients. Based in Edinburgh, we are a UK subsidiary of Aegon Asset Management Holding B.V which is part of the Aegon N.V. group. Kames Capital plc is authorised and regulated by the Financial Conduct Authority and is a subsidiary of Kames Capital Holdings Limited.

Our Business and Supply chains

We have proven investment management capabilities across fixed income, equities, multi-asset, property, absolute return and ethical investing. We offer agile and responsible investment management expertise to our customers and we distribute our capabilities in the UK and many other countries. In order to provide these services to our customers we procure a range of services from third party suppliers who, in turn, may enter into sub-contracts with their suppliers. We also outsource certain administrative and operational functions. We procure services both from within the UK and overseas.

The UK Financial Services sector is not considered high risk for Modern Slavery, however, we are not complacent and whilst the majority of our spend relates to fully managed outsourced services, IT and professional services our offices do employ cleaners, security and catering staff. We expect transparency from our suppliers and business partners and we will not knowingly support or deal with any business involved in modern slavery. In the event that we did become aware of any modern slavery issues within any of our supply chains, this would be treated as of significant concern at the most senior levels in our organisation and appropriate action taken.

Our Policies on Modern Slavery and Human Trafficking 

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We have a number of policies which collectively demonstrate our approach to modern slavery issues.

  • Our Anti-Slavery and Human Trafficking Policy reflects our commitment to ensuring effective systems and controls such that slavery and human trafficking is not taking place anywhere in our supply chains.
    Our Global Sustainable Procurement Policy reflects our commitment by requiring suppliers to meet social
    sustainable procurement standards such as eliminating forced or compulsory labour, effectively abolishing child labour, providing fair wages, following applicable law on working hours, respecting human rights, refraining from discrimination, providing a safe and healthy working environment with adequate training and appropriate grievance mechanisms.
  • Our Responsible Investment Policy incorporates environmental, social and governance considerations into our evaluations and engagement with investee companies. Our investment approach is a key additional way through which we believe we can drive change.
  • Our Whistleblowing Policy allows our staff to escalate any concerns. This is a confidential and independent speak up service available to our employees and all reports received are investigated and appropriate action taken.
  • Our Global Code of Conduct describes the principles and standards that we hold ourselves to and ask all our employees to abide by during their business dealings and work for the company. Our Code states that “Aegon is committed to upholding internationally-recognised human rights. Under Aegon’s human rights policy, all the company’s activities are guided by the articles of the United Nations Universal Declaration of Human Rights, the core standards of the International Labor Organisation and the principles on human rights and labor standards contained in the UN Global Compact”.

We pay all employees the National Living Wage and ensure our employees are supported by the Employee Assistance Programme and a range of flexible benefits.