Modern Slavery Act Statement
In October 2015, the UK Modern Slavery Act (“MSA”) came into force, requiring 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 is being made on behalf of SLE and references to “we”, “us” or “our” are to SLE.
Although SLE is not technically required to publish a statement under the MSA, we have decided to publish this statement on a voluntary basis. This statement covers our financial year ending 31 December 2021.
SUPPLY CHAIN AND RISK ASSESSMENT
SLE takes a zero-tolerance approach to slavery and human trafficking in all its forms. We endeavour to ensure that our business and supply chains are conducted and managed responsibly, in line with the principles underpinning the MSA.
Given the nature of SLE’s advisory business, we believe there is a relatively low risk of slavery or human trafficking in connection with our activities. The goods and services we typically procure are limited to areas such as office equipment, IT, professional services, facility management and catering.
Nonetheless, we understand that no business is completely risk-free and so, consistent with the principles of the MSA and as part of our initiative to identify and manage risk:
We continually 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 (please see below for further information on our Whistleblowing procedures).
Where possible, we build long-standing relationships with our key suppliers and ensure that expectations of business behaviour are clear and consistent.
A number of our existing policies and procedures support our commitment in this area. These include:
- Compliance Manual, covering a number of different areas, which underpins our standards of behaviour and expectations of good business practice for all of our employees;
- Anti-bribery and Corruption Policy and Gifts and Entertainment Policy, which set out our zero-tolerance approach towards the receipt or request of bribes and other corrupt behaviour; and
- Whistleblowing procedure, which includes both internal and external contact information for reporting malpractice and raising concerns and allows for any actual or suspected issues to be raised in a confidential manner.
- We proactively support community organisations and develop relationships with organisations that are working to address issues that are a priority for our firm. Silver Lake supports community organisations such as 10,000 Black Interns, which the firm participates in.
Our SLE legal and compliance team take responsibility for implementing the objectives considered in this statement, monitoring progress of our efforts in this area and issues (should they arise) and report back to SLE’s Management Committee directly as appropriate.
Since our first MSA statement was published, we have used the following key performance indicators to track our progress toward increasing the awareness of and protecting against slavery and human trafficking arising in, or the supply chains to, our business:
- We provide training on slavery, human trafficking and the MSA to relevant SLE personnel (see below);
- We have incorporated a MSA section into our Silver Lake Europe LLP Compliance Manual, which is provided to all SLE employees; and
- We review suppliers to our business and the terms which we work with them on (see above).
These metrics will continue to be used going forward.
Our SLE legal and compliance team provide training to relevant SLE personnel to educate them on the importance of implementing and enforcing effective systems to ensure slavery and human trafficking is not taking place in our business or supply chains.
A MSA update is included in our annual compliance refresher, which highlights the key issues employees should be aware of and provides an overview of the key legislative framework in this area.
MONITORING AND REPORTING
If issues are identified in relation to modern slavery or human trafficking, these should be immediately reported to our legal and compliance team.
More general issues in relation to the running of this policy are reported back to the Management Committee as appropriate.
This statement is reviewed annually and is published on our website.
MANAGEMENT COMMITTEE APPROVAL
Silver Lake Europe LLP Management Committee approved this statement on 27 June 2022.
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 financial year ending 31 December 2021.