Modern Slavery Statement 2026

The Charterhouse Modern Slavery Statement 2026

The Modern Slavery Act 2015 (“MSA 2015”) requires large commercial organisations to publish an annual statement on modern slavery and human trafficking. This statement is made pursuant to section 54(1) of the MSA 2015 and constitutes the slavery and human trafficking statement of [Charterhouse Capital Partners LLP] and its subsidiary undertakings (together, “Charterhouse” or the “Group”) for the financial year ending 31 March 2026 (the “Relevant Period”). It sets out the steps we have taken to ensure that slavery, servitude, forced and compulsory labour and human trafficking is not taking place in our own business operations or supply chains. 

Members of the Charterhouse Sustainability Committee (responsible for overseeing the environmental, social and governance considerations in our operations and business) have overseen the preparation of this slavery and human trafficking statement on behalf of Charterhouse for the Relevant Period.

ABOUT CHARTERHOUSE

Charterhouse was founded in 1934 and has an investment history of more than 90 years in the UK, and more than 40 years in continental Europe. It was one of the pioneers of the UK leveraged buyout industry in the 1980s and has managed eleven investment vehicles to date. All our investment activity is conducted through funds comprising limited partnerships whose General Partners / managing entities are wholly-owned subsidiaries of Charterhouse. The firm is headquartered in London, England with a satellite office in Paris, France and a representative team in China. As of 31 March 2026, the Group employed 64 people. Charterhouse’s business is the management of private equity funds which acquire and hold controlling interests in mid-market companies, predominantly in Western Europe, across sectors including business services, healthcare, consumer and industrials.

GROUP STRUCTURE

The Group is wholly-owned and controlled by its partners and consists mainly of UK registered entities. Several Group entities are authorised and regulated by the UK Financial Conduct Authority. The ultimate controlling entity of the Group is Watling Street Capital Partners LLP. The companies in which our funds invest are separate legal entities with their own management teams and are not part of the Group for the purposes of this statement. Portfolio companies which meet the MSA 2015 thresholds publish their own statements. We recognise, however, that our investment activities expose us to modern slavery risk in portfolio companies’ operations and supply chains, and we address this through our responsible investment approach described below.

POLICY ON MODERN SLAVERY AND HUMAN TRAFFICKING

We have been signatories of the Principles for Responsible Investment since 2013 and our commitment as responsible investors includes taking steps to address and mitigate the risks of any modern slavery or human trafficking in all parts of our business or our supply chains. We are committed to acting ethically and with integrity in all our business relationships and we take the opportunity to encourage others to do so. We regularly review the systems and controls we have in place to ensure that the risk of modern slavery and human trafficking in our business and supply chains is eliminated to the maximum possible extent.

During the Relevant Period, human rights and forced labour issues continue on a national and global scale, exacerbated by geopolitical developments and an increasing number of migrants seeking better economic opportunities, a situation which leaves women and children significantly exposed to the risk of human trafficking and forced labour in particular. We recognise our responsibility to understand supply chains of the firm and of our portfolio companies and to raise awareness to enhance engagement and transparency.

Our commitment is supported by the following policies, which are approved by The Charterhouse Executive Committee, reviewed regularly and communicated to all partners and employees: our Compliance Manual, which sets out the ethical standards expected of everyone at Charterhouse; our Responsible Investment Policy, which integrates human rights and modern slavery considerations into our investment process from pre-acquisition due diligence through to exit; our Whistleblowing Policy, which enables employees to raise concerns, including concerns about modern slavery, confidentially and without fear of retaliation; and our recruitment and employment policies, which include right-to-work checks and a commitment that directly employed staff and on-site contractors are paid at least the London Living Wage.  

SUPPLY CHAINS

Our suppliers are mostly UK-based, including a few multi-national companies with a UK-presence. As an investment business, our suppliers include professional services such as lawyers, accountants, other consultants, IT providers, office equipment, maintenance services, and transport.  Suppliers also include the businesses which help us run our premises, such as building managers, caterers, cleaners and security providers. During the Relevant Period, the Group engaged approximately 310 suppliers, approximately 97% of which (by spend) were based in the UK. Our operational supply chain is short and consists primarily of tier 1 suppliers of services rather than goods. We consider the categories with a higher inherent risk of modern slavery to be those relying on lower-skilled, outsourced or agency labour (cleaning, catering, security and building maintenance), and those whose own supply chains source goods from higher-risk jurisdictions (IT hardware, office equipment and branded merchandise).

MODERN SLAVERY DUE DILIGENCE UNDERTAKEN ACROSS OUR BUSINESS AND SUPPLY CHAINS

We have established long-term relationships with first-tier suppliers and, given the nature of our business, consider the risk of modern slavery and human trafficking arising from our suppliers providing these services to be low. In fact, we continuously seek ways to enhance our supplier engagement for example through continued dialogue with our cleaning services suppliers to ensure these remain on a salary which, as a minimum, meets the London Living Wage.

During the Relevant Period, we reviewed our relationship with key suppliers and assessed our current exposure to modern slavery and human trafficking risk by examining the level of maturity of addressing human rights risk for suppliers of the Charterhouse Group.  We also considered ways to improve the dialogue with suppliers should we identify any with a high-risk exposure to modern slavery and how our commitment and expectations could be better conveyed in supplier engagement.

The modern slavery risk to our sector is considered to be relatively low, and we deemed it appropriate to apply a risk-based approach to due diligence of our supply chain.

For the risk assessment of the Group’s own operations we: 

• focussed the bulk of our risk assessment analysis on high spend / high frequency suppliers, differentiating between low and significant modern slavery and human trafficking risks and prioritising any supplier for which an aggregate spend in excess of a monetary threshold was recorded in the Relevant Period; 
• considered other factors such as industry-specific risk, product risk and jurisdictional risk in relation to modern slavery / human trafficking exposure; 
• scrutinised modern slavery statements issued by our suppliers and identified certain suppliers who were required to provide information relating to steps they take to address modern slavery risk; and
• selected and engaged with suppliers which fell outside of the risk-based approach selection described above, but for which, based on advancing understanding of human rights risks in specific industries, engagement is necessary.

Where our assessment identified a supplier as higher risk, we sought to understand the actions embedded to mitigate the risk of forced labour and identify potential gaps. 

As responsible investors and a PRI signatory, we continuously seek to influence and support our portfolio companies to mitigate the risk of any modern slavery which may exist in their supply chains. We increasingly see the adoption of supplier codes of conduct and inclusion of human rights and environmental-related terms and conditions in supplier engagements. We have also conducted due diligence on supply chain analytical software products with a view to include this in our portfolio company toolkit to support the supplier screening, monitoring and engagement practices in this regard. Modern slavery and human rights risks are assessed as part of our pre-acquisition ESG due diligence. Material findings are reported to the Investment Committee and addressed in the post-acquisition value creation plan. During ownership, portfolio companies report annually on human rights and supply chain indicators through our ESG data collection process. 

During the Relevant Period, we have not been made aware of any slavery or human trafficking incidents in our supply chains at the firm itself or in its portfolio companies.

RISK ASSESSMENT AND MANAGEMENT

We assess modern slavery risk across three areas: (i) our own operations, which we consider low risk because our workforce consists predominantly of highly skilled, directly employed professionals in the UK and France; (ii) our operational supply chain, where risk is concentrated in outsourced facilities services (cleaning, catering, security and maintenance) and in the upstream supply chains of IT hardware and office equipment; and (iii) our portfolio companies, which represent our most significant potential exposure, particularly in sectors with labour-intensive operations, reliance on agency or migrant workers, or supply chains extending into higher-risk jurisdictions.

We manage these risks by prioritising engagement with the suppliers and portfolio companies assessed as highest risk, maintaining direct oversight of the pay and working conditions of on-site contractors, embedding modern slavery considerations in our investment due diligence and ownership processes, and escalating material issues to the Sustainability Committee and Portfolio Committee. If an instance of modern slavery were identified, we would work with the relevant supplier or portfolio company to remediate it, prioritising the welfare of affected individuals, and would consider terminating the relationship if appropriate action were not taken. 

MEASURING EFFECTIVENESS: KEY PERFORMANCE INDICATORS

Members of the Sustainability Committee monitor the effectiveness of our approach using the following key performance indicators for the Relevant Period:

• New investments subject to pre-acquisition modern slavery or human rights due diligence
• Portfolio companies with a modern slavery statement or human rights policy
• Partners and employees completing modern slavery training
• Modern slavery concerns reported (including via whistleblowing channels) and their outcome.

 TRAINING

We continued with our training programme during the Relevant Period, introducing individuals joining Charterhouse to our obligations and responsibilities to mitigate modern slavery risk in our businesses and supply chain. Modern Slavery training, as well as practical tools and support, was made available to all Charterhouse individuals to address modern slavery and human trafficking in the supply chains of our portfolio companies. During the Relevant Period, 100% of Charterhouse personnel completed internal compliance and modern slavery training covering how to recognise indicators of modern slavery, the risks relevant to our business, supply chains and portfolio, and how to report concerns. We also provided specialist speaker-led best practice guidance and insight to portfolio company management teams at our 2025 Sustainability Conference hosted for our portfolio companies.  

EVOLVING STEPS

We seek to build on the steps we have taken in the Relevant Period to improve the screening of and engagement with our suppliers, by updating the policies relating to responsible purchasing and supplier engagement. In doing so, we shall continue to gain a better understanding of high-risk suppliers’ actions taken to ensure that ethical standards are adopted beyond tier 1 of our supply chains. We shall continue to raise awareness of Charterhouse partners and employees and continue our support and work with our portfolio companies to enhance supply chain frameworks which address modern slavery and human trafficking risk. In the financial year ending 31 March 2027, we intend to measure effectiveness of our approach against indicators including priority suppliers assessed for modern slavery risk and higher-risk suppliers engaged / with agreed follow-up actions; seek to extend our risk assessment to tier 2 suppliers by evolving the high-risk tier 1 supplier engagement; and continue to deploy supply chain management in selected portfolio companies. 

APPROVAL

This statement was approved by members of the Sustainability Committee on 29 September 2026. It is signed on behalf of Charterhouse Capital Partners LLP and the Group in accordance with section 54(6) of the MSA 2015. 
 
Lionel Giacomotto
Managing Partner 

30 September 2026