Modern Slavery Act Statement
ARGA Investment Management, LP (“ARGA”) is issuing this Modern Slavery Act transparency statement, pursuant to section 54(1) of the United Kingdom Modern Slavery Act of 2015, with respect to the financial year ending on December 31, 2022 as part of our commitment to high business standards.
ARGA Investment Management, LP (“ARGA” “we” or “the firm”) is an independent investment management firm focused on global equities. Founded in 2010 by A. Rama Krishna, CFA, who serves as Chief Investment Officer, ARGA invests in undervalued businesses using a disciplined investment approach based on fundamental research and present value. ARGA’s global organization is aligned around values, client service and results. ARGA is headquartered in Stamford, CT and has a subsidiary with two office locations in India, one in Chennai and one in Mumbai. ARGA also has a client-focused office in London, United Kingdom. No investment advisory services are carried out in our London or India offices.
ARGA is organized as a Delaware limited partnership.
ARGA offers investment advisory services to: private investment funds or pooled vehicles; separate managed accounts including pension plans, state or municipal government entities, foreign registered investment companies, family offices, corporate entities and other investment advisers; investment companies registered under the Investment Company Act of 1940 (the “1940 act”); open-ended investment companies with variable capital that are qualified as UCITS funds; and internal, single investor, proprietary funds.
Our Supply Chain
Our supply chain consists largely of regulated and/or professional service providers including legal, financial services (consultants, registered advisors, broker-dealer) and accounting. We also have agreements with technology firms to provide services and support for our technology systems. In more limited cases we contract for general office support services relating to cleaning, catering, printing, and mailing.
Ultimately, ARGA has a zero-tolerance policy approach to modern slavery and human trafficking and expects all parties in our supply chain to comply with our high ethical and business standards, including compliance with the Modern Slavery Act.
ARGA has assessed its business operations and concluded that the firm has a very low risk of exposure to modern slavery or human trafficking within its business or supply chains. Our business does not operate in any material way within one of the sectors deemed most at risk to human trafficking according to the United Nations Office on Drugs and Crime, including the agriculture, construction, apparel manufacturing, food services, domestic work, entertainment and sex industries.
ARGA maintains the following policies and procedures that help us uphold our high ethical standards and culture of compliance and serve to mitigate the risk of modern slavery and human trafficking:
Compliance Manual, Code of Conduct, Code of Ethics
ARGA’s Compliance Manual, Code of Conduct, and Code of Ethics describe in detail ARGA’s commitment to a fair and safe work environment for its employees and detail the legal and ethical standards by which all employees are required to abide. There is a procedure set forth allowing employees to report any legal and ethical violations that occur within the firm and employees are required complete an Annual Disciplinary Questionnaire reporting criminal history and civil judicial actions, among other things. All employees received compliance and ethics training initially and annually.
Vendor Due Diligence and Selection Procedure
ARGA abides by a due diligence procedure in the selection of any third-party vendor that serves to mitigate operational, financial reputational, and investment risk to the firm. This procedure helps to ensure that ARGA thoroughly investigate and select only reputable vendors who conduct their duties in accordance with applicable regulations and ARGA’s ethical standards. ARGA conducts ongoing due diligence on third-party vendors to ensure that they continue to meet the firm’s standards.
ARGA has developed and implemented an environmental, social, and governance (“ESG”) policy with respect to the companies in which we invest. The review framework serves to mitigate ESG risks, including those indicative of modern slavery and human trafficking. Specifically, part of our ESG review process includes an analysis of employee wages.
Our Goals for the Future
ARGA is committed to combating modern slavery and human trafficking by continuing to identify potential areas of risk within our business and supply chains and implementing responsive risk mitigation policies.
ARGA’s Modern Slavery Act statement has been approved by A. Rama Krishna, CFA, ARGA’s Founder & Chief Investment Officer.