Introduction
The following statement is made in accordance with section 54 of the UK Modern Slavery Act 2015 (the “Act”). It sets out the steps that Montagu Private Equity LLP and other relevant group companies (“Montagu” or “we”) have taken to ensure that slavery and human trafficking are not taking place in its business or supply chains in the most recent audited financial year.
As an investment manager, Montagu’s actions around modern slavery have two components:
- Ensuring slavery or human trafficking is not taking place in Montagu’s own supply chain
- For those companies in which funds advised by Montagu hold investments, exercising our influence to encourage adoption of ESG policies and procedures.
In accordance with the Act, this statement covers the first of these, our own supply chain.
Organisation structure and supply chains
Montagu is a European investment manager headquartered in London, UK. We advise funds investing money from a group of investors, the majority of which is from insurers and pension funds. These funds invest in private companies, typically Northern European businesses with enterprise values between €200 million and €1 billion.
Our own workforce is diverse and highly skilled and is based predominantly in Western Europe in an office setting. Therefore, there is a minimal risk of modern slavery in our own operations and our focus regarding modern slavery is on our supply chain.
As an investment business, our material suppliers are professional service firms such as lawyers, accountants and corporate finance advisors, which we consider to have a low risk of human trafficking or modern slavery in their own operations. Montagu continues to incorporate human rights into supply chain assessments.
Policies in relation to slavery and human trafficking
As a firm, we take a zero-tolerance approach to slavery and forced labour in our business or supply chain. Montagu maintains the following policies which it believes are relevant in the detection and prevention of Modern Slavery: responsible investing policy; anti-bribery and sanctions policies within the Compliance Manual; whistleblowing policy within the Compliance Manual; and the anti-money laundering section of the Compliance Manual.
Due diligence processes
Montagu stays committed to ensuring that slavery or human trafficking is not taking place in Montagu’s own supply chain. Our due diligence on suppliers is based on assessment of materiality For material new and high risk suppliers, we review the supplier’s publicly available information regarding modern slavery and assess the adequacy of measures in place.
Risk assessment and management
As part of our continuous review of our supply chain, we have conducted a risk review over Montagu’s most material suppliers by risk category. For key suppliers, we may look to obtain their modern slavery statements and other materials such as corporate responsibility reports, where available. For those suppliers deemed highest risk we have had discussions to better understand their treatment of these issues.
Key performance indicators to measure effectiveness of steps being taken
There is a low risk of modern slavery in our Tier 1 suppliers, which are largely providers of services with employees based in Western Europe.
In 2022, there were no reported instances of modern slavery or human trafficking within Montagu, its investees, or its supplier relationships. Montagu will continue to review and monitor its approach to Modern Slavery amongst all of our counterparties on a regular basis.
Training on modern slavery and trafficking
As part of Montagu‘s compliance policies, we conduct training for employees, which includes updates on the prevention of human trafficking and modern slavery as applicable.
Approval
This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes Montagu’s slavery and human trafficking statement for the financial year ending 31 December 2022. It was approved on behalf of the Montagu Private Equity LLP Board on 25 April 2023.
Louise Denning
Designated Member, LLP