The UK Modern Slavery Act 2015 (“MSA”) requires certain organisations doing business in the United Kingdom to publish an annual “slavery and human trafficking” statement (this “Statement”) detailing the steps being taken to monitor and address the risks of slavery and human trafficking in its business and supply chains.
GHO Capital carries out business in the United Kingdom through GHO Capital Partners LLP (“GHO”, the “Firm” or “we”), which is authorised and regulated by the UK Financial Conduct Authority, which acts as the investment adviser to the manager of GHO’s funds.
We subscribe to the United Nations Principles of Responsible Investment (“UNPRI”) and are committed to ensuring that the investments advised on by GHO do not undertake any activities which we believe would be contrary to UNPRI or our responsible investing aims. Our approach to assessing investment opportunities is outlined in our Responsible Investing Policy & Principles which has been informed by industry leading groups such as the British Private Equity & Venture Capital Association and The Blueprint for Better Business.
Our business and organisation
GHO has a zero-tolerance approach to all forms of modern slavery and is committed to maintaining high ethical and business standards. This includes prohibiting any forms of modern slavery or human trafficking within its own business and supply chains.
GHO believes that there is a negligible risk of modern slavery in our workforce, which consists of skilled employees, partners and consultants with backgrounds in the healthcare and financial services sectors. GHO has rigorous hiring and employment practices in line with its regulatory and legal obligations and the business is entirely transparent in relation to employment practices.
GHO is committed to equal opportunity for employees and seeks to provide a safe and sustainable working environment for all employees. This includes strict rules in our Employee Handbook, which is made available to all team members. GHO’s whistleblowing procedures ensure that employees with concerns will not be victimised or penalised for raising them. GHO has not received any reports or allegations of modern slavery.
Given the nature of our business, the types of suppliers that we retain (and the nature of the work they do for GHO) do not present risks generally associated with modern slavery. As such, we believe that the risk of modern slavery at our suppliers is minimal.
The majority of GHO’s suppliers are professional service firms with skilled workforces in the investment banking, legal, consulting and accounting sectors, as well as providers of IT services.
GHO’s vendors also include hospitality providers such as hotels and cleaning service providers, as well as travel providers such as booking agents. GHO also purchases goods from off-the-shelf retailers, in particular for office supplies. Given the types of goods and services GHO purchases and the location of performance of such services, we believe that the risk of modern slavery is low. However, we survey our suppliers based on risk by asking them to confirm that they also implement ethical and sustainable business practices.
GHO’s compliance function may also carry out risk-based compliance checks on new suppliers.
Training and monitoring
Relevant members of GHO’s executive and compliance staff have received training on modern slavery risk and their responsibilities under the MSA. However, all of GHO’s employees are aware that they should not facilitate modern slavery of any kind, should be vigilant when entering into agreements and negotiating with suppliers and should report any concerns, including through GHO’s whistleblowing process. Employees are always encouraged to bring questions or concerns to GHO’s compliance personnel.
GHO’s compliance function will monitor the Firm’s progress in complying with applicable laws and regulations relating to modern slavery both within GHO and at its suppliers.
GHO has transaction due diligence processes which assess both potential investments and counterparties (including Know-Your-Client processes and responsible investing-specific due diligence provided by third party specialists) and these can assist with assessing and mitigating the risk of GHO facilitating the financing of cases of modern slavery.
Whilst portfolio companies in respect of which GHO provides investment advice do not fall within the Firm’s supply chain, we recognise the importance of engaging with each such company to encourage them to adopt responsible business and supplier processes.
We have an active responsible investing reporting programme which enables each portfolio company and GHO to perform better and drive value creation for stakeholders. This includes reporting on certain key performance indicators, including that supply chains are fully compliant with human rights laws.
Over the past 12 months, GHO has completed the following activities:
- Informed staff of the MSA and of the appropriate action to take if they suspect a case of slavery or human trafficking.
- Formalised a Diversity, Equity and Inclusion policy and commitments with all stakeholders.
- Trained relevant executive and compliance team members on modern day slavery.
- Conducted a review of portfolio companies’ policies and processes in relation to human rights laws.
- Introduced a modern slavery process for all material suppliers.
During 2023, we will:
- Continue to develop team and portfolio company awareness.
- Monitor the Firm’s progress in complying with applicable laws and regulations relating to modern slavery both within GHO and at its suppliers.
- Monitor and support the portfolio companies progress and action in taking modern slavery into account within their own operations and supply chains.