Modern Slavery and Human Trafficking Statement

November 2021

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking (together “modern slavery”).

Growth Capital Partners LLP (“GCP”) is committed to improving its practices to combat slavery and human trafficking wherever possible. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes to our slavery and human trafficking statement for the financial year ending March 2021.

Organisational structure

GCP is a sub-threshold Alternative Investment Fund Manager that is appropriately authorised and regulated by the Financial Conduct Authority (FRN: 501399). The Firm is based in the United Kingdom.

Supply chains

As an Alternative Investment Fund Manager, GCP’s supply chain primarily consists of professional services firms, recruitment agencies, information technology providers and third-party facilities providers.

Policies and procedures

GCP is committed to ensuring that there is no modern slavery or human trafficking in its supply chain or any other part of its business. The Firm’s senior management has considered its obligation to report on the measures in place to ensure that all parts of the business and supply chain are slavery free. Counterparty take-on and review procedures have been updated where relevant to ensure due consideration is given to identifying and tackling modern slavery issues.

Suppliers adherence to Modern Slavery and Human Trafficking requirements

GCP has a zero-tolerance policy to slavery and human trafficking; the Firm will assess suppliers on an annual basis to ensure they remain in good standing. This assessment has been updated to ensure that modern slavery and human trafficking are considered, with potential issues documented and immediately raised to senior management for its consideration.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in the supply chain and throughout GCP’s business. Employees will be provided with practical guidance on what to look out for and who to contact should they have any concerns.

Effectiveness in combating slavery and human trafficking

GCP’s senior management and wider team are committed to ensuring the effectiveness of the Firm’s Modern Slavery and Human Trafficking mitigation arrangements. The Firm will continue to assess and, where necessary, enhance these arrangements going forward.

Should you have any questions regarding the Firm’s approach to Modern Slavery and Human Trafficking please contact the Firm’s Compliance Officer, John Marsh, at john.marsh@growthcapital.co.uk.