Modern Slavery Statement

for the period ended 31 December 2023

Modern Slavery Statement for the period ended 31 December 2023

Set out below is the Modern Slavery Statement of Gresham House plc (“Gresham House”) for the period ended 31 December 2023.

About Gresham House

The Gresham House Group comprises the following regulated investment management subsidiaries:

Gresham House Asset Management Limited
Traderisks Limited
ReSI Capital Management Limited
Gresham House Asset Management Ireland Limited

On 20 December 2023, Gresham House plc delisted from trading on the London Stock Exchange following its acquisition by Searchlight Capital Partners L.P.(Searchlight).

Gresham House is a specialist alternative asset manager, offering a broad range of funds, direct investments, and tailored investment opportunities, including co-investment, across six alternative investment strategies. Our clients include individual investors, financial advisers, institutional investors, charities and endowments, family offices, and business owners.

We are specialists in six key areas of alternative investment:

Strategic Equity

Public Equity
Private Equity

Real Assets

Forestry
New Energy
Sustainable Infrastructure
Housing

Strategic objectives linked to Modern Slavery

Our Corporate Sustainability Strategy (CSS) aims to support our strategic objective to become “The manager of choice for sustainable investment client solutions” by 2030. One of our Thematic priority topics within our CSS is supply chain sustainability and we have set the following objective for this topic:

Understand material ESG risks across the supply chain of our most at-risk investments and put in place policies and processes to manage and mitigate these.

One of the material ESG risks we have identified for some of our asset classes, particularly within Real Assets, is the risk of modern slavery within our supply chains. We are aiming to achieve this objective by 2025 and have started work on mapping our supply chains across our Real Assets.

Further work is planned in 2024 to identify where our greatest risks for modern slavery lie and put in place management and mitigation processes, where possible, to address these across all of our Real Assets.

Modern Slavery Policy & Processes

Policy

Gresham House has in place a Modern Slavery Policy that includes commitments in respect of slavery and human trafficking.
Gresham House also has in place Modern Slavery Procedures that outline our expectations in respect of practices concerning slavery and human trafficking prevention.
We encourage members of staff to report any suspected breaches of these policies and procedures to their managers and our Compliance Team.

Processes

In addition to our Modern Slavery Policy, we have put in place processes to identify risks of slavery and human trafficking in some of our supply chains, including:

In the Renewables business, all newly established EPC and O&M contracts now include clauses specifically mandating suppliers to declare that they have not been involved in any practices linked to modern slavery and that they will permit on-site audits at any time should the team have reason to suspect instances of slavery and human trafficking.
All main technology component providers of Gresham House managed New Energy projects are asked to complete an annual questionnaire relating to both their own labour practices and supply chain management regarding material sourcing from China. To mitigate the risk of low response rates, the team will mandate completion of the questionnaire as part of pre-qualification for new suppliers going forward.
Gresham House Energy Storage Fund plc (GRID) has developed a Supply Chain Policy with a focus on forced labour and discrimination. We plan to update this as part of the 2024 work plan (see below).
All new battery storage projects whose construction began from 2021 onwards use Lithium Iron Phosphate (LFP) battery chemistry instead of Nickel Manganese Cobalt (NMC) reducing our reliance on the extraction of cobalt in the Democratic Republic of Congo. However, we recognise modern slavery risks have not been eliminated through this change due to potential risks associated with other raw materials.
In 2022 we undertook an audit of our primary battery supplier, CATL, which verified that it had a framework in place to manage ESG risks, and that its policies were deemed to be satisfactory. This provided comfort to the GRID Board that its main supplier is committed to responsible business practices and has comprehensive policies in place.
In 2023 we built on this to identify a provider who could evolve our approach to supply chain management and we hope for the following work to be carried out in 2024 and beyond:
- - Review, evaluate and update our supply chain policies across each of our New Energy asset types, ensuring they effectively address material risks and upcoming regulation.
  - Undertake additional ESG due diligence on our core suppliers in line with our updated policies and industry standards.
In 2023, we joined Solar Energy UK’s Responsible Sourcing Steering Group. This group aims to work with key stakeholders and unravel the complexity of the sector’s supply chain, engaging with suppliers and business partners to implement a responsible sourcing programme. The Group developed a new responsible sourcing statement designed to promote the highest possible levels of transparency and sustainability throughout the solar value chain. It also developed the Solar Stewardship Initiative, a solar-specific supply chain assurance scheme with a dedicated environmental, social and governance standard.
The Housing division completed a high-level audit in 2022 of the house building contractors they work with to ensure they all have in place their own modern slavery policies.

Business supply chains

In assessing risk within our supply chains, we have identified our material suppliers within our business operations and our investments.

We recognise that office facility service providers, including cleaning services and IT service providers, as well as branded goods not for resale, may carry a higher risk of modern slavery practices. However, we consider the fact that our service providers are typically based in the UK, (which does not have high estimated prevalence of modern slavery according to the Global Slavery Index 2018) reduces Gresham House’s exposure to modern slavery practices in these areas.

We have engaged with building management at our London office to confirm that all their contractors, including cleaners, are paid above the London Living Wage.

Within our Strategic Equity business, our supply chain is relatively short and predominantly comprises highly skilled professionals. These include regulated professional advisers, and brokers, as well as suppliers of IT services and office equipment, and professional services from our lawyers, accountants and other advisers and consultants.
Within our Real Assets business, our supply chains are more complex and some are at higher risk of modern slavery due to the sector they work in and/or the region in which they operate. These include agricultural workers, construction workers and mineral suppliers further down our supply chains. The supply chains for Real Assets also include regulated professional advisers, as listed in the previous bullet, which we understand as being less at risk for modern slavery.

As Gresham House has a heavy reliance on third party providers, in 2023, we carried out the first annual review process of all high impact providers with a view to provide internal and external assurance. A questionnaire was sent to those providers with questions covering Finance, IT, Compliance, Resource & Staffing and Modern Slavery. Modern Slavery questions were included to ensure we at Gresham House were aware of any potential risks with our providers and enable us to set up additional monitoring if required.

There were no material findings in the results and each provider was categorised as ‘low risk’ in the modern slavery section. We will be carrying out the same exercise annually following a review of the questionnaire and the level of impact of our current service providers before distribution.

Internal training

Gresham House provided training on Modern Slavery in 2023. We will be reviewing the modern slavery training module for 2024 to ensure the training content is as relevant as possible to our business operations and asset classes.

Approval

This statement made pursuant to section 54(1) of the Modern Slavery Act 2015 for the period ending 31 December 2023 has been approved by the Board of Directors of Gresham House.

Kevin Acton, Director of Gresham House

30 June 2024