Individual Investor Contact Us Careers United Kingdom Our Company Products Fund Views Insights Resources Search Home Modern Slavery Statement Share MODERN SLAVERY STATEMENT Franklin Templeton Global Investors Limited (“FTGIL”) and Franklin Templeton Investment Management Limited (“FTIML”) THE MODERN SLAVERY ACT 2015 – STATEMENT FINANCIAL YEAR ENDING 30 SEPTEMBER 2020 This statement is made on behalf of the UK companies, Franklin Templeton Global Investors Limited (“FTGIL”) and Franklin Templeton Investment Management Limited (“FTIML”) to address section 54 (1) of the Modern Slavery Act 2015. The statement describes the steps taken to mitigate the risk of slavery and human trafficking taking place in the supply chains of FTGIL and FTIML and in any part of their business. ORGANISATION STRUCTURE AND BUSINESS FTGIL is a UK private limited company which provides support and administration services to Franklin Resources, Inc. and its subsidiaries operating as Franklin Templeton Investments (“FTI”). FTI is a global investment management organisation providing investment management and related services to retail, institutional and high net worth clients. Services provided by FTGIL to its parent and associated companies include legal, compliance, human resources, accounting, fund administration and IT support. FTGIL has a number of subsidiaries including the UK Company, FTIML, a UK private limited company which provides investment management and advisory services to various FTI sponsored products and on a discretionary basis to institutional clients. SUPPLY CHAINS FTGIL and FTIML contract with a number of direct and indirect suppliers of goods and services including suppliers of IT, office equipment, cleaning services and professional services from lawyers, accountants and other advisers and consultants. Due to the nature of the good and services supplied the majority of suppliers in our supply chain are not located in countries or sectors that are considered to be at high risk of exposure to human trafficking or slavery. POLICIES IN RELATION TO SLAVERY AND HUMAN TRAFFICKING FTGIL and FTIML are committed to ensuring that no member of staff and no vendor has any involvement in human trafficking and modern slavery. This commitment reflects our core values to put clients first, build relationships, achieve quality results and work with integrity. This approach is supported by our Anti-Bribery Policy which outlines the principles that FTI follows to achieve zero-tolerance against bribery and corruption and our Code of Ethics which require staff to uphold the highest level of ethical conduct in their day to day business. DUE DILIGENCE Employees Recruitment at Franklin Templeton is conducted through an online application system either direct by the candidate or via a third-party supplier such as a Franklin Templeton contracted recruitment business. Applications for all roles (permanent, temporary and contract) are reviewed and appropriately experienced candidates are invited for interview. Reference and background checks are carried out on all prospective employees, using a third party specialist company, and proof of the right to work is mandatory before an offer will be made. Franklin Templeton base salary levels and benefit provision are set with reference to appropriate market benchmarking data (third party industry surveys), which are reviewed regularly. We also take into account any mandated minimum pay levels, fair pay and any other relevant legislation. All salary payments are made directly to each employee’s personal bank account. Vendors All direct vendors that Franklin Templeton uses are considered to be at a low risk of exposure to human trafficking or slavery. Franklin Templeton ensures that all contracts have appropriate modern slavery act terms to ensure vendor compliance. All key staff involved in recruitment and vendor sourcing are made aware of our policy. William Jackson, Director Franklin Templeton Global Investors Limited (“FTGIL”) and Franklin Templeton Investment Management Limited (“FTIML”) Board Approval Date: 17 December 2020 LEGG MASON INVESTMENTS (EUROPE) LIMITED ORGANISATION’S STRUCTURE AND BUSINESS Legg Mason became a member of the Franklin Templeton group of companies on the 31st July 2020, combining years of expertise and know-how within the asset management industry. Franklin Templeton is now one of the largest asset management firms in the world with over $1.4 trillion in assets under management and offices in 34 countries. Today, Franklin Templeton is a globally diversified group of more than 1,300 widely recognized investment professionals committed to long term performance and outstanding client service who provide clients with deep expertise across asset classes, investment styles, and geographies. Franklin Resources Inc. is headquartered in San Mateo, California in the USA and operates in the UK via a number of subsidiaries, one of which is Legg Mason Investments (Europe) Limited (the “Company”), a private company limited by shares incorporated in England and Wales. The Company falls within the scope of S54(2) of the Modern Slavery Act 2015 (the “Act”). The Company acknowledges their responsibilities to the Act and the prevention of slavery and human trafficking. In addition, the Company takes steps to seek to ensure transparency within the organisation and with suppliers of goods and services with whom it contracts in relation to the prevention of modern slavery and human trafficking. OUR SUPPLY CHAIN The Company’s supply chain includes the following suppliers: Third party distribution companies and platforms who enter into arrangements to distribute Legg Mason’s proprietary mutual funds or other investment solutions; Third party outsourcing and professional services companies who provide a range of professional services to the Company including fund administration, legal advice, audit and payroll; Third party commercial real estate, cleaning, office supplies and services required to support the staff in the Company’s various offices; and Third party payroll providers, pension fund managers and providers of private healthcare, employee benefits and other associated services required to support the Company’s POLICIES ON SLAVERY AND HUMAN TRAFFICKING The Company is committed to seeking to ensure that there is no slavery or human trafficking in its supply chains or in any part of its business. The Legg Mason Employee Handbook reflects the Company’s commitment to acting ethically and with integrity in all of its business relationships and to implement and enforce effective systems and controls to seek to ensure slavery and human trafficking is not taking place. DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING As part of the Company’s initiative to identify and reduce the risk of slavery and human trafficking occurring within its supply chain, the Company has adopted the following due diligence procedures: Where possible the Company builds long standing relationships with its third party service providers and suppliers and place obligations on these suppliers to comply with all applicable laws, which, where relevant, would include compliance with the The Company is regulated in the United Kingdom by the Financial Conduct Authority (FCA) and is therefore required to have appropriate systems and controls in place to operate a prudential and well-managed business. The adoption of and compliance with the requirements of the Act in our view, form part of the operation of a prudent and well-managed As an FCA regulated business, the Company is under an obligation to carry out initial and ongoing know your customer and anti-money laundering checks on third parties that we enter into agreements for goods and services with. We believe that this due diligence provides us with an understanding of third parties with whom we enter into arrangements with for the provision of services and The Company carries out regular checks on its service providers and suppliers and a review of anti-slavery and human trafficking procedures has been included in this due SUPPLIER ADHERENCE TO OUR VALUES AND OUR ASSESSMENT OF RISK The Company has a zero tolerance approach to slavery and human trafficking. Where relevant, those in its supply chain and contractors are required to comply with these values. Where applicable, contractual provisions are included in and put into agreements. Further, where applicable, notices of the Company’s expectations will be sent to certain providers in the Company’s existing supply chain. Many of our suppliers and contractors are financial and professional services organisations as set out above. As such we consider that, given the nature of the services that we offer, the risk of modern slavery or human trafficking in our business and its supply chain is low. EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING The Company uses the following types of key performance indicators to measure the effectiveness of any measures implemented in seeking to ensure compliance with the Act: Risk based approach to oversight of the Company’s third party service providers and suppliers to seek to ensure that resources are allocated appropriately. Risks considered include country risk, sector risk, transaction risk and business partnership risk. Ongoing analysis and review of risk of slavery and human trafficking with appropriate reporting as required on the perceived risk and any action Honest and open communication with the relevant personnel of our service providers and suppliers to set the Company’s expectations of their compliance with the Completion of regular due diligence reviews on certain third party The Company has procedures in place to encourage the reporting of concerns and the protection of whistle blowers. TRAINING To seek to ensure the risks of modern slavery and human trafficking in the Company’s supply chains and business are understood, training is available to relevant members of staff. The Board of Directors have been briefed on the requirements of the Act. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Legg Mason Investments (Europe) Limited’s slavery and human trafficking statement for the 2019/2020 financial year. The short delay in publishing this statement was due to additional time required to ensure compliance with relevant processes during Covid-19 in combination with the acquisition of Legg Mason by Franklin Resources on the 31st July 2020. This statement was approved by the Board of Legg Mason Investments (Europe) Limited in November 2020. Jaspal Sagar, Director Legg Mason Investments (Europe) Limited 2020 LEGG MASON & CO (UK) LIMITED ORGANISATION’S STRUCTURE AND BUSINESS Legg Mason became a member of the Franklin Templeton group of companies on the 31st July 2020, combining years of expertise and know-how within the asset management industry. Franklin Templeton is now one of the largest asset management firms in the world with over $1.4 trillion in assets under management and offices in 34 countries. Today, Franklin Templeton is a globally diversified group of more than 1,300 widely recognized investment professionals committed to long term performance and outstanding client service who provide clients with deep expertise across asset classes, investment styles, and geographies. Franklin Resources Inc. is headquartered in San Mateo, California in the USA and operates in the UK via a number of subsidiaries, one of which is Legg Mason & Co (UK) Limited (the “Company”), a private company limited by shares incorporated in England and Wales. The Company falls within the scope of S54(2) of the Modern Slavery Act 2015 (the “Act”). The Company acknowledges their responsibilities to the Act and the prevention of slavery and human trafficking. In addition, the Company take steps to seek to ensure transparency within the organisation and with suppliers of goods and services with whom it contracts in relation to the prevention of modern slavery and human trafficking. OUR SUPPLY CHAIN The Company’s supply chain includes the following suppliers: Third party outsourcing and professional services companies who provide a range of professional services to the Company including fund distribution, legal advice and audit; Third party commercial real estate, cleaning, office supplies and services required to support the staff in the Company’s various offices; and Third party payroll providers, pension fund managers and providers of private healthcare, employee benefits and other associated services required to support the Company’s POLICIES ON SLAVERY AND HUMAN TRAFFICKING The Company is committed to seeking to ensure that there is no slavery or human trafficking in its supply chains or in any part of its business. The Legg Mason Employee Handbook reflects the Company’s commitment to acting ethically and with integrity in all of its business relationships and to implement and enforce effective systems and controls to seek to ensure slavery and human trafficking is not taking place. DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING As part of the Company’s initiative to identify and reduce the risk of slavery and human trafficking occurring within its supply chain, the Company has adopted the following due diligence procedures: Where possible the Company builds long standing relationships with its third party service providers and suppliers and places obligations on these suppliers to comply with all applicable laws, which, where relevant, would include compliance with the Act. The Company carries out regular checks on its service providers and suppliers and a review of anti-slavery and human trafficking procedures has been included in this due SUPPLIER ADHERENCE TO OUR VALUES AND OUR ASSESSMENT OF RISK The Company has a zero tolerance approach to slavery and human trafficking. Where relevant, those in its supply chain and contractors are required to comply with these values. Where applicable, contractual provisions are included in and put into agreements. Further, where applicable, notices of the Company’s expectations are sent to certain providers in the Company’s existing supply chain. Many of our suppliers and contractors are financial and professional services organisations as set out above. As such we consider that, given the nature of the services that we offer, the risk of modern slavery or human trafficking in our business and its supply chain is low. EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING The Company uses the following types of key performance indicators to measure the effectiveness of any measures implemented in seeking to ensure compliance with the Act: Risk based approach to oversight of the Company’s third party service providers and suppliers to seek to ensure that resources are allocated appropriately. Risks considered include country risk, sector risk, transaction risk and business partnership Ongoing analysis and review of risk of slavery and human trafficking with appropriate reporting as required on the perceived risk and any action Honest and open communication with the relevant personnel of our service providers and suppliers to set the Company’s expectations of their compliance with the Completion of regular due diligence reviews on certain third party The Company has procedures in place to encourage the reporting of concerns and the protection of whistle blowers. TRAINING To seek to ensure the risks of modern slavery and human trafficking in the Company’s supply chains and business are understood, training is available to relevant members of staff. The Board of Directors have been briefed on the requirements of the Act. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Legg Mason & Co (UK) Limited’s slavery and human trafficking statement for the 2019/2020 financial year. The short delay in publishing this statement was due to additional time required to ensure compliance with relevant processes during Covid-19 in combination with the acquisition of Legg Mason by Franklin Resources on the 31st July 2020. This statement was approved by the Board of Legg Mason & Co (UK) Limited in November 2020. Ian Goodhew, Director Legg Mason & Co (UK) Limited 2020 Investments entail risks, the value of investments can go down as well as up and investors should be aware they might not get back the full value invested. United Kingdom Individual Investor This website is intended for residents of United Kingdom. OUR COMPANY Our Firm UK Profile Media Centre Contact Us PRODUCTS Franklin Templeton Mutual Fund Prices ETF Prices Investment Trust (TEMIT) Franklin Templeton Fund Charges and Costs Our Products FUND VIEWS INSIGHTS RESOURCES Literature Investor Education Investment Advice Your Account Careers Terms of Use Anti Corruption Privacy & Cookies Notice/Settings Security Policy Important Legal Information Support Modern Slavery Statement Copyright © 2021 Franklin Templeton. All Rights Reserved. TOP Franklin Templeton uses cookies to analyse website usage, personalise your website experience and assist in our marketing efforts. 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