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Modern Slavery Act 2015
Slavery and human trafficking statement made pursuant to Section 54 of the Modern Slavery Act 2015 (“MSA”)
Introduction
This statement is made in accordance with section 54 of the UK Modern Slavery Act 2015 that requires commercial organisations operating in the UK to report annually on the steps they have taken during the previous year to ensure that slavery and human trafficking are not happening in their own business or their supply chain.
Organisation structure and supply chains
Limerston workforce comprises a diverse and highly experienced group of workers based in London and we consider that there is no risk of modern slavery in our own operations. Our suppliers are mostly professional and business service firms such as legal advisers, financial advisers and consultants. Therefore, we consider there is a minimal risk of modern slavery in our supply chain.
Policies
Limerston Capital has created a Modern Slavery Policy that sets out the expectations with regards to modern slavery and human trafficking, and directs employees to the whistleblowing policy should any employee have any concerns in relation to compliance with these expectations by the firm, any of its suppliers or the portfolio companies.
Due diligence, assessing and managing risk
Ahead of an acquisition there is a due diligence performed on the target company which covers several parts of the business, including the assessment of ESG policies such as Modern Slavery and during ownership we work with the company to keep up to date with regulation and the creation of policies and procedures to ensure that no form of human trafficking and slavery, including forced, compulsory or coerced labour and deprivation of personal freedom takes place, as we have a zero tolerance approach to slavery and forced labour.
An ESG questionnaire is sent yearly to all the platform companies to assess their compliance to ESG matters.
Training
Regular training will be provided to all staff both at Limerston and the portfolio companies.
Approval
This statement refers to the financial year ending 31 December 2020 and was approved by the Limerston Capital executive members.