1. Introduction
This statement is made by Hengistbury Investment Partners LLP (“the Firm”) pursuant to section 54(1) of the Modern Slavery Act 2015 (“the Act”) and constitutes our slavery and human trafficking statement for the financial year ended 30 June 2024.
The Firm is committed to ensuring that modern slavery and human trafficking have no place in our business or supply chains. We recognise the importance of acting ethically in all our business dealings and relationships.
2. Our Structure and Supply Chain
The Firm is an independently owned and managed alternative investment management firm based in London, United Kingdom. The Firm’s business is the management of alternative investment funds and the provision of investment management services to professional clients.
Given the nature of our business as a financial services firm, our supply chain is principally composed of professional services providers, including legal advisors, accountants, fund administrators, technology providers, and other financial service intermediaries. These are predominantly UK and European Union based firms.
3. Policies
The Firm maintains a zero-tolerance approach to modern slavery and human trafficking. Our relevant policies include:
- Anti-Slavery Policy: sets out our commitment to acting ethically and with integrity in all our business relationships;
- Whistleblowing Policy: provides a mechanism for employees and contractors to raise concerns about illegal activities, including modern slavery, without fear of retaliation;
- Supplier Code of Conduct: establishes our expectations of suppliers with respect to human rights and labour standards.
4. Due Diligence
The Firm conducts appropriate due diligence when entering into relationships with new suppliers and service providers. This includes an assessment of the supplier’s own policies and practices relating to modern slavery where relevant and appropriate given the nature of the services provided.
We seek to engage suppliers that share our commitment to ethical business practices and, where applicable, that have published modern slavery statements of their own.
5. Risk Assessment
Having assessed our business and supply chain, we consider the risk of modern slavery in the Firm’s operations and immediate supply chain to be low, principally by reason of:
- The Firm’s small size and the professional nature of its staff and operations;
- The predominantly UK and EU-based nature of our supply chain;
- The professional services focus of our supplier relationships; and
- Applicable regulatory frameworks governing financial services firms in the United Kingdom.
We nonetheless remain vigilant and will continue to monitor and review this assessment on an ongoing basis.
6. Training and Awareness
The Firm ensures that relevant personnel are aware of the risks of modern slavery and human trafficking and the Firm’s obligations under the Act. We provide or facilitate access to training on modern slavery awareness as appropriate.
7. Approval
This statement has been approved by the management of Hengistbury Investment Partners LLP. It will be reviewed and updated annually.