Modern Slavery Statement

for the period ended 31 December 2022

Modern Slavery Statement for the period ended 31 December 2022

Set out below is the Modern Slavery Statement of Gresham House plc (“Gresham House”) for the period ended 31 December 2022.

About Gresham House

The Gresham House Group comprises the following regulated investment management subsidiaries:

Gresham House Asset Management Limited
Traderisks Limited
ReSI Capital Management Limited
Gresham House Asset Management Ireland Limited

Gresham House is a specialist alternative asset manager, listed on the London Stock Exchange’s Alternative Investment Market (AIM).

We offer a broad range of funds, direct investments, and tailored investment opportunities, including co-investment, across five alternative investment strategies. Our clients include individual investors, financial advisers, institutional investors, charities and endowments, family offices, and business owners.

We are specialists in five key areas of alternative investment:

Strategic Equity

Public Equity
Private Equity

Real Assets

Forestry
New Energy & Sustainable Infrastructure
Housing

Strategic objectives linked to Modern Slavery

Our Corporate Sustainability Strategy (CSS) aims to support our strategic objective “to become a recognised leader in sustainable investment” by 2025. One of our Thematic priority topics within our CSS is Supply Chain Sustainability and we have set the following objective for this topic:

Understand material ESG risks across the supply chain of our most at-risk investments and put in place policies and processes to manage and mitigate these.

One of the material ESG risks we have identified for some of our asset classes, particularly within Real Assets, is the risk of modern slavery within our supply chains. We are aiming to achieve this objective by 2025 and have started work on mapping our supply chains across our Real Assets.

Further work will be carried out in 2023 and 2024 to identify where our greatest risks for modern slavery lie and put in place management and mitigation processes to address these across all our Real Assets.

Modern Slavery Policy & Processes

Policy

Gresham House has in place a Modern Slavery Policy that includes commitments in respect of slavery and human trafficking.
Gresham House also has in place Modern Slavery Procedures that outline our expectations in respect of practices concerning slavery and human trafficking prevention.
We encourage members of staff to report any suspected breaches of these policies and procedures to their managers and our Compliance Team.

Processes

In addition to our Modern Slavery Policy, we have put in place processes to identify risks of slavery and human trafficking in some of our supply chains, including:

In the Renewables business, all newly established contracts now include clauses specifically mandating suppliers to declare that they have not been involved in any practices linked to modern slavery and that they will permit on-site audits at any time should the team have reason to suspect instances of slavery and human trafficking.
All main technology component providers of Gresham House managed New Energy projects are asked to complete an annual questionnaire relating to both their own labour practices and supply chain management regarding material sourcing from China. To mitigate the risk of low response rates, the team will mandate completion of the questionnaire as part of pre-qualification for new suppliers going forward.
Gresham House Energy Storage Fund plc (GRID) has developed a Supply Chain Policy with a focus on forced labour and discrimination. This will be updated following the CATL supply chain audit that was completed in 2023 (see below).
All new battery storage projects whose construction began from 2021 onwards use Lithium Iron Phosphate (LFP) battery chemistry instead of Nickel Manganese Cobalt (NMC) reducing our reliance on the extraction of cobalt in the Democratic Republic of Congo. However, we recognise modern slavery risks have not been eliminated through this change due to potential risks associated with other raw materials.
In 2022, the New Energy team engaged RCS Global Group (RCS), a global responsible sourcing assurance and advisory business, to conduct an audit of CATL, the team’s primary supplier of batteries. The audit verified that CATL had a framework in place to manage ESG risks. This provided comfort to the GRID Board that its main supplier is committed to responsible business practices and has comprehensive policies in place. However, the audit highlighted that more work is required by CATL to ensure companies further down the supply chain meet the same standards.
Whilst the information did not impact on the team’s construction or asset management decisions, useful feedback was obtained that will lead to an update of the Supply Chain Policy. The study also provided a framework to carry out audits on future battery suppliers and the supply chain under CATL and other BESS suppliers.
The New Energy team has collaborated with institutions in the battery supply chain to identify solutions for how to create a more resilient and sustainable battery supply chain. For example, the team participated in 2022 to a Green Finance Institute battery workshop to discuss means of unlocking financial flows in the UK to the battery industry.
The Housing division completed a high-level audit of the house building contractors they work with to ensure they all have in place their own modern slavery policies.

Business supply chains

In assessing risk within our supply chains, we identified our material suppliers within our business operations and our investments.

We recognise that office facility service providers, including cleaning services and IT service providers, as well as branded goods not for resale, may carry a higher risk of modern slavery practices. However, we consider the fact that our service providers are typically based in the UK, (which does not have high estimated prevalence of modern slavery according to the Global Slavery Index 2018) reduces Gresham House’s exposure to modern slavery practices in these areas.

We have engaged with building management at our London office to confirm that all their contractors, including cleaners, are paid above the London Living Wage.

Within our Strategic Equity business, our supply chain is relatively short and predominantly comprises highly skilled professionals. These include regulated professional advisers, and brokers, as well as suppliers of IT services and office equipment, and professional services from our lawyers, accountants and other advisers and consultants.
Within our Real Assets business, our supply chains are more complex and some are at higher risk of modern slavery due to the sector they work in and/or the region in which they operate. These include agricultural workers, construction workers and mineral suppliers further down our supply chains. The supply chains for Real Assets also include regulated professional advisers, as listed in the previous bullet, which we understand as being less at risk for modern slavery.

Internal training

Gresham House did not provide training on Modern Slavery in 2022. We have recently started working with a new training provider who provided modern slavery training to all staff at the start of 2023.

Approval

This statement made pursuant to section 54(1) of the Modern Slavery Act 2015 for the period ending 31 December 2022 has been approved by the Board of Directors of Gresham House.

Kevin Acton, Director of Gresham House plc

30 June 2023