Modern Slavery Statement

Modern Slavery Statement for the period ended 30 September 2022

Set out below is the Modern Slavery Statement of Gresham House plc (“Gresham House”) for the period ended 30 September 2022.

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

Gresham House is a specialist alternative asset manager, listed on the London Stock Exchange’s Alternative Investment Market (AIM).

We offer a broad range of funds, direct investments, and tailored investment opportunities, including co-investment, across five alternative investment strategies. Our clients include individual investors, financial advisers, institutional investors, charities and endowments, family offices, and business owners.

We are specialists in five key areas of alternative investment:

Strategic Equity

• Public Equity
• Private Equity

Real Assets

• Forestry
• New Energy & Sustainable Infrastructure
• Housing

Policy in respect of anti-slavery and human trafficking

Gresham House has in place policies that include commitments in respect of anti-slavery and human trafficking. It states that we take a zero-tolerance approach to any instances of slavery or human trafficking that are identified in our supply chain.

Gresham House also has in place a Modern Slavery Policy and 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.

Procedures

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

• risk assessments of our supply chain in relation to slavery and human trafficking giving consideration to country risk and product/service risk;
• following a risk-based approach, anti-slavery and human trafficking due diligence on our suppliers; and
• reporting procedures.

Training and communications

Gresham House has provided Modern Slavery training to all staff involved in procuring supplies for the business. We also make all such staff aware of “red flags” of slavery and human trafficking that they should consider when dealing with suppliers during contractual negotiations, site visits or any interaction with the supplier and its workers.

Business supply chains

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

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.

The New Energy team is increasingly focused on identifying and managing supply chain risks. A key sustainability objective identified by the team is to determine best-in-class suppliers to work with long-term and encourage more responsible supplier practices in order to reduce supply chain sustainability risks. Additionally, it has taken the following steps to enhance its supply chain due diligence and to tighten human rights-related requirements of suppliers:

• In the Renewables business, all contracts 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 operators of Gresham House managed Renewables projects have been asked to complete a questionnaire relating to both their own labour practices and supply chain management regarding material sourcing from China with an intention of reducing supply chain risks of modern slavery in this area.
• Gresham House Energy Storage Fund plc (GRID) has developed a Supply Chain Policy with a focus on labour and discrimination following allegations of forced labour in China in the battery supply chain.
• All new projects whose construction began from 2021 onwards use Lithium Iron Phosphate (LFP) battery chemistry instead of Nickel Manganese Cobalt (NMC). This is considered to reduce human rights risks linked to the extraction of cobalt in the Democratic Republic of Congo.
• The team has appointed a third-party provider to carry out a battery system supply chain audit for GRID to identify material sustainability-related risks and potential actions to remedy any issues identified.

Additionally, the team has collaborated with institutions across both the public and private sectors in the battery supply chain to identify solutions for how to create a more resilient and sustainable battery supply chain. It is also working to identify potential industry bodies and associations with whom it can work to drive the industry forward regarding the management of supply chain and other sustainability risks for New Energy assets.

We also review risks where construction services providers are appointed in the context of infrastructure and housing investments. We only work with those companies who themselves are committed to anti-slavery practices.

We also 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, as noted above, 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 this area.

Approval

This statement made pursuant to section 54(1) of the Modern Slavery Act 2015 for the period ending 30 September 2022 has been approved by the Board of Directors of Gresham House.

Kevin Acton, Director of Gresham House plc

30 September 2022