Modern Slavery Statement
This is the Charterhouse statement pursuant to section 54 of the Modern Slavery Act of 2015 (“MSA 2015”) for the financial year ending 31 March 2020. 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 ESG 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 Capital Partners LLP and its affiliated entities, together the “Group”, for the financial year ending March 2020 (the “Relevant Period”).
Charterhouse was founded in 1934 and has an investment history of more than 80 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 ten investment vehicles to date. All our investment activity is conducted through funds comprising limited partnerships whose General Partners are wholly-owned subsidiaries of Charterhouse. The main office is in London and we have an office in Paris.
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.
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.
We also believe that collaboration and sharing of best practice is essential in raising awareness and preventing modern slavery and human trafficking in businesses and supply chains. For example, during the Relevant Period we invited the CEO of an international NGO to speak to ESG-Live (peer-member group initiated to discuss practical ways to address ESG challenges). The speaker was able to highlight the human rights violations that this organisation had exposed in the bottom-tiers of global supply chains of many household brands. It was evident that had remained undetected due to a lack of due diligence.
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.
MODERN SLAVERY DUE DILIGENCE UNDERTAKEN ACROSS OUR BUSINESS AND SUPPLY CHAINS
We typically cultivate long-term relationships with first-tier suppliers, and we avoid making demands of our suppliers which might lead them to violate human rights. For example, we require our cleaning services suppliers to pay their personnel who provide services to Charterhouse a salary equivalent to at least the London Living Wage. We periodically review our relationship with key suppliers and assess their performance.
During the Relevant Period, we assessed our current exposure to modern slavery and human trafficking risk by examining the supply chain of the Charterhouse Group.
The modern slavery risk to our sector is considered to be relatively low, and we deemed it appropriate to apply risk-based due diligence in the examination of our supply chain.
For the relatively straight forward risk assessment in relation to 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 slavery and human trafficking risk, 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; and
- Scrutinised modern slavery statements issued by suppliers and identified certain suppliers who were required to provide information relating to steps they take to address modern slavery risk
As responsible investors and PRI signatories, we continuously seek to influence and support our portfolio companies to undertake steps to mitigate the risk of any modern slavery which may exist in their supply chains.
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.
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. All Charterhouse individuals also received training, featuring a case study to raise awareness, as well as practical tools and support to address modern slavery and human trafficking in businesses and supply chains.
In terms of our own operations and supply chain, we seek to enhance our policy by formally communicating our commitment and expectations to suppliers we engage with and which they need to uphold to prevent modern slavery and human trafficking in the supply chain. We recognise the
value of continuing the engagement and dialogue with high risk suppliers to understand their actions taken to ensure that ethical standards are adopted beyond tier 1 of our supply chains.
We aim to continue to engage with our portfolio companies to understand the modern slavery and human trafficking risk and support them in actions they can take to mitigate the supply risk.
This statement has been approved for distribution by the ESG Committee on behalf of the Charterhouse Group.