SLAVERY AND HUMAN TRAFFICKING STATEMENT PURSUANT TO SECTION 54, PART 6 OF THE MODERN SLAVERY ACT 2015 (the “Act”)

This statement relates to the financial year ended 31 December 2021 and sets out the steps that Lion Capital LLP (“Lion Capital”, the “Firm” or “we”) has taken and intends to take to ensure that slavery and human trafficking is not taking place in its business or supply chains.

Our structure, business and supply chains

The Firm is a global consumer-focused investor, with offices in London and New York. The Firm provides investment management services to various investment funds established in the United Kingdom (the “Funds”), which focus on making investments in Europe and North America.

As a private equity investor, our immediate supply chain is relatively short, consisting mainly of professional services firms.

The Funds that we manage invest in a number of portfolio companies. Though these portfolio companies do not form part of the Firm’s supply chain, we are committed to taking steps to confirm that each portfolio company’s management team understands any responsibilities it has under the Act and the need for it to put in place its own effective controls and training to protect against modern slavery being present in its own business and supply chains.

To this end, we have written to the management of those portfolio companies that we consider may be subject to the Act, to ensure that they understand their obligations under the Act. In addition, we have representation on each portfolio company board and, although not a standing agenda item, ensuring compliance with the Act and limiting the risk of modern slavery and human trafficking taking place in their business and supply chains remains a key consideration of the companies’ boards.

Policy Statement

In pursuit of best-in-class approach, Lion Capital is a signatory of the six UN supported Principles for Responsible Investment.  The Firm is a responsible investment fund manager that strives to maintain the highest standards of integrity and professionalism in the conduct of its business.  Lion Capital expects all of its portfolio companies and employees to comply with ESG-related legislation at a local, national and international level, including but not limited to applicable environmental, health and safety, anti-bribery and corruption and human rights legislation.

Lion Capital portfolio companies are actively involved in a collaboration project (“Not for Sale”) which raises awareness about human trafficking and, as an active board member of “Not for Sale”, Lion Capital has promoted the prevention of human trafficking at various investor meetings and conferences.

 Our approach to due diligence

As part of the Firm’s standard investment due diligence process, Lion employs external advisers to conduct site visits, management interviews and public searches to diagnose any potential environmental/social liabilities, and ensure portfolio company compliance with Lion’s philosophy in these areas.  At the point that a Fund acquires a portfolio company, we ensure that such portfolio company’s management team is aware of their potential obligations under the Act.

We do not consider that the relationships within our immediate supply chain give rise to material risks in this area.  However, we will be requiring key suppliers to confirm that their activities accord with the requirements of the Act.

We also have a dedicated Compliance Officer, who oversees the above process.

Training

The Firm has provided details of this policy to all relevant staff.  We ensure that all employees, on joining the Firm and periodically thereafter, review and familiarise themselves with the Firm’s policies to ensure that they can identify situations where there is a risk of modern slavery or human trafficking.

Further steps

Additional steps that we take in order to ensure that modern slavery and human trafficking is not taking place in our business or supply chains are:

• to develop and enhance existing policies (if any) or create new policies relating to slavery and human trafficking, in order to provide a framework for identifying and monitoring activities within our business and supply chains that may be in breach of such policies;

 

• to review our due diligence processes to ensure that they comply with our policies on slavery and human trafficking; and

 

• to review current training provided in respect of our policies and their implementation and ensure the applicable level of training is delivered to employees so that they are more effective in identifying the existence or risk of slavery and human trafficking as part of the investment due diligence process.

 

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Lion Capital LLP’s slavery and human trafficking statement for the financial year ended 31 December 2021.  It has been endorsed by the Operating Committee on behalf of the Firm.

 

Robert Darwent

Designated Member

 

8 November 2022