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Modern Slavery Act Statement
Modern Slavery Statement
Year ended 31 December 2021
The Modern Slavery Act 2015 requires large commercial organisations operating in the UK to publish a slavery and human trafficking statement setting out the steps they have taken to ensure their business and supply chains are free from modern slavery.
This statement is made by BGF Group PLC in respect of itself and the following of its subsidiary undertakings (as defined in the Companies Act 2006): BGF Investment Management Limited, BGF Services Limited, and BGF Investments LP (together “BGF”).
It is made in respect of the financial year ended 31 December 2021.
About BGF’s structure and business
BGF Group PLC is the United Kingdom-based holding company of a group of companies involved in the management of multiple investment funds.
BGF provides long-term, patient capital that management teams use to execute their strategic plans. With a £2.5bn evergreen balance sheet BGF provides funding for growth and equity release via secondary share sales, typically making initial investments of between £2m and £10m in return for a minority stake.
To date, BGF has invested £3bn and has been recognised as the most active growth investor in the world, having backed over 460 companies since 2011.
As of January 2022, BGF had over 191 employees based in sixteen offices in the United Kingdom and Ireland.
Our commitment and policies
BGF is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or any part of its business and operates a zero-tolerance policy in this regard. BGF recognises the importance of the Modern Slavery Act as a tool in combating the widespread human rights abuses comprised in modern slavery.
We have a modern slavery policy to ensure employees are aware of the risks and steps to be taken in respect of modern slavery, alongside a number of other internal policies to ensure that we are conducting business in a transparent and ethical manner, including a recruitment policy, a code of conduct, an ethical standards policy and a whistle-blowing policy.
Being at the forefront of doing business the right way has always been a central part of the BGF model and it is for this reason that BGF became a signatory to the UN’s Principles for Responsible Investing in 2020.
As part of our wider commitment to ESG, in 2021 BGF has recruited its first Head of ESG and Responsible Investing who will have oversight of all ESG matters, including our efforts to combat modern slavery.
Our supply chain and due diligence
During the year, we completed a review of suppliers with whom BGF spent over £15,000 in the financial year, focussing on the:
- nature of the services provided by the supplier; and
- geography of the supplier’s services.
174 suppliers were considered in the review (out of an overall 523 suppliers with whom BGF transact) which involved the Compliance, Legal, HR, Finance and Facilities functions and comprised one-to-one briefings and consultations.
Our supply chain consists principally of regulated professional advisers, individual consultants, financial services firms and providers of office-related goods and services. Nearly all our suppliers are based in the United Kingdom (157 of those reviewed), with 17 based overseas and up to 5 of our UK based IT partners who outsource services overseas. The location of those suppliers and the ranking of each territory on the Global Slavery Index is set out below.
|Territory||% overall spend||GSI Index ranking|
|Hong Kong, China||0.3%||111|
We endeavour only to use reputable suppliers.
We are in the process of reviewing and enhancing the effectiveness of how we engage with our suppliers, which includes an assessment of the risks of modern slavery at the initial stage when onboarding new suppliers. We ensure that material suppliers are contractually obliged to comply with the provisions of the Modern Slavery Act. Looking forward, we are in the process of compiling a Supplier Code of Conduct which would include standards relating to modern slavery.
Assessment, management and effectiveness
Based on the review completed in 2021 and given the nature of our suppliers, we consider the risk of slavery or human trafficking within our supply chain to be low. We continue to assess this.
There are currently no known matters of concern in relation to BGF’s supply chain.
BGF makes minority investments in UK and Ireland based businesses. Although our investments are not part of our supply chain and we do not have control over those businesses, we seek to ensure compliance with laws, including the Modern Slavery Act, through warranties at the time of our initial investment and compliance undertakings thereafter. Under these portfolio companies are specifically required to comply with the Modern Slavery Act 2015 and report any concerns or suspicions regarding modern slavery.
This year we engaged with our portfolio of unquoted companies and conducted a survey of ESG (Environmental, Social and Governance) matters which included a review of the approach of those companies to modern slavery. The results of this showed that 23% of our portfolio are required to publish a modern slavery statement and an additional 16% of our portfolio companies voluntarily publish one.
We collect data from our portfolio annually to measure compliance with the Modern Slavery Act, amongst other ESG related factors.
Furthermore, ESG and Modern Slavery considerations have been incorporated into our investment process to ensure these are explicitly considered as part of the investment decision. We have been developing a pre-investment screening tool in order to refine this process which will be launched during 2022. As we have BGF representatives sat on the board of many of our portfolio companies, any modern slavery issues raised at board level will be reported to the Head of Compliance and we have processes in place to ensure they are given appropriate consideration by BGF to ensure the portfolio company manages the situation in a timely fashion. In 2021 no such instances were raised.
Our recruitment processes are transparent and we have comprehensive vetting procedures in place, involving the use of external service providers, in relation to the hiring of new employees. We are therefore able to confirm their identities, their right to work in the UK and ensure that their compensation is paid directly into a personal bank account. All employees are paid above the UK’s national living wage.
We provide our staff with training on a range of compliance matters, which includes their obligations under the Modern Slavery Act and test awareness of this through the annual compliance process. We also aim to increase awareness of these issues amongst those employees who sit on the boards of portfolio companies.
If issues are identified in relation to modern slavery, these will be dealt with by the Legal and Compliance teams.
Priorities for 2022
During the course of 2022, BGF intends to:
- Review and update this statement
- Continue to evaluate the risk of modern slavery and human trafficking in any new suppliers. In order to ensure a consistent approach across the business, organisational wide due diligence requirements will be embedded into an appropriate platform for efficient supplier onboarding
- Create and implement a standard Supplier Code of Conduct
- Continue to pro-actively engage with our investee companies to understand the steps they have taken to comply with the Modern Slavery Act
- Evolve our approach to ESG and the portfolio and as part of that, reflect on further ways in which we can ensure that portfolio companies under our stewardship are complying with modern slavery requirements
- Review our existing policies and processes and refine as required by any upcoming amendments to the Modern Slavery Act which are expected as a result of the Government’s response to the “Transparency in Supply Chains Consultation”
- Continue to train internally, including in relation to the upcoming amendments to the Modern Slavery Act
This statement was approved by BGF Group PLC’s board of directors on 20 January 2022 and was approved by the boards of each of BGF Investment Management Limited, BGF Services Limited and BGF GP Limited (the general partner of BGF Investments LP) on 20 January 2022.
Executive Chairman, BGF Group PLC
20 January 2022
 Pitchbook 2020 Annual Global League Table (defined as deals of at least $15m performed by a growth/expansion-tagged investor (per Pitchbook database), and tagged as growth/ expansion by Pitchbook)
 The GSI rating 2018 ranks 167 countries from 1 (most incidences of slavery) to 167 (least incidences).
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