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