SILVER LAKE EUROPE LLP - MODERN SLAVERY ACT STATEMENT
In October 2015, the UK Modern Slavery Act (“MSA”) came into force and requires large organisations doing business in the United Kingdom to produce a public “slavery and human trafficking statement”. The concept of “modern slavery” encapsulates behaviours such as forced, compulsory or coerced labour, deprivation of personal freedom or facilitating the movement of people for exploitation.
Silver Lake Europe LLP (“SLE”) acts as a sub-advisor to Silver Lake’s US affiliates in relation to the investment of European based assets of Silver Lake managed funds. SLE is based in the U.K. and authorised and regulated by the U.K. Financial Conduct Authority. This statement, which is being made on behalf of SLE, is being made on a voluntary basis. References to “we”, “us” or “our” are to SLE.
Given the nature of SLE’s advisory business, we believe there is a low risk of slavery or human trafficking in connection with these activities. The goods and services we typically procure are limited to areas such as office equipment, IT, professional services, facility management and catering.
Consistent with the principles of the MSA and as part of our initiative to identify and manage risk:
• We will look to better (a) identify, assess and monitor potential higher risk areas in the supply chains to our business, (b) mitigate the risk of slavery and human trafficking occurring in these supply chains through enhanced contract terms (to the extent appropriate and obtainable), (c) train relevant employees as to these risks and the need to manage them and (d) protect whistle blowers.
• Where possible, we build long-standing relationships with our key suppliers and ensure that expectations of business behaviour are clear and consistent.
Our SLE legal and compliance team will take responsibility for implementing the objectives considered in this statement, monitor progress of our efforts in this area and issues (should they arise) and report back to SLE’s Management Committee directly as appropriate.
We will use the following key performance indicators as indicia of progress toward increasing awareness of and protecting against slavery and human trafficking in our advisory business or the supply chains to our business:
• training on modern slavery (see below);
• incorporating MSA considerations in our Silver Lake Europe LLP Compliance Manual; and
• reviewing existing suppliers to our business.
Our SLE legal and compliance team will provide training to relevant SLE personnel to educate on
the importance of implementing and enforcing effective systems to ensure slavery and human trafficking is not taking place in the supply chains to our business.
MONITORING AND REPORTING
If issues are identified in relation to the MSA, these will be immediately reported to SLE’s Compliance Officer.
More general issues in relation to the running of this policy will be reported back to the Management Committee as appropriate.
This statement will be reviewed periodically and published on our website.
MANAGEMENT COMMITTEE APPROVAL
Silver Lake Europe LLP Management Committee approved this statement.
This statement is made on a voluntary basis pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our group's slavery and human trafficking statement for the current financial year.