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 which has been informed by industry leading groups such as the British Private Equity & Venture Capital Association.
Our approach
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. All GHO employees are required to comply with applicable laws, which would include those related to modern slavery GHO’s whistleblowing procedures ensure that employees with concerns will not be victimised or penalised for raising them, and reports can be submitted anonymously.
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 reviewing their own modern slavery statements or directly asking them to confirm that they implement ethical and sustainable business practices.
GHO’s compliance function may also carry out risk-based compliance checks on new suppliers.
Training and awareness
Relevant members of GHO’s executive and compliance staff have received training on modern slavery risk and their responsibilities under the MSA. In addition, 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 compliance with applicable laws and regulations relating to modern slavery within GHO.
GHO has transaction due diligence processes which assess both potential investments and counterparties, consisting of Know-Your-Client processes and responsible investing due diligence provided by third party specialists. These processes assess and can help mitigate the risk of GHO facilitating the financing of cases of modern slavery.
Portfolio companies
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 that are monitored throughout our portfolio quarterly and annually.
In respect of the financial year ending 31 December 2024, GHO has taken the following steps:
- Continued to monitor GHO’s compliance with applicable laws and regulations relating to modern slavery.
- Upgraded our standard responsible investing due diligence scope to include human rights review of target companies’ and their supply chains.
- Monitored our portfolio companies’ implementation of human rights policies, including modern slavery risk considerations, within their own operations.
- Reviewed and expanded our set of human-rights related metrics for our portfolio companies.
During the course of 2025, GHO intends to:
- Continue to collaborate with industry associations (such as the UNPRI and the Institutional Limited Partners Association (“ILPA”)) and review their best practice guidance.
- Continue to support our portfolio companies to undertake an annual Labour & Human Rights assessment and monitor their implementation of human rights policies, including modern slavery risk considerations, within their own operations.
- Reassess key GHO suppliers’ approach to modern slavery, based on their level of risk, and uplift our processes for assessing modern slavery risks during supplier procurement and onboarding.
- Review how our portfolio companies monitor and report on identified human rights or modern slavery incidences.
- Support portfolio companies in mitigating risks that have been identified through the anti-bribery and corruption risk assessment.
Statement Approval
This Statement was approved and signed by Andrea Ponti, Managing Partner and a member of the Executive Leadership Team of GHO on 27 June 2025. This Statement is made pursuant to section 54 of the MSA for the financial year ended 31 December 2024.