Modern Slavery and Human Trafficking Statement

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes our group’s slavery and human trafficking statement for the financial year ending 31 December 2018.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We operate several internal policies to ensure that we are conducting business in an ethical and transparent manner. Additionally, Bregal is a signatory to the United Nations Principles for Responsible Investment (“UNPRI”), a voluntary framework for incorporating environmental, social, and governance (“ESG”) principles into investment decision making and ownership policies.

Such policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Business organisation, structure and supply chain

Bregal Investments is the private equity investment business of COFRA Holding AG, a European holding company for a privately-owned group of companies headquartered in Zug, Switzerland. We have over 145 employees worldwide with investment teams based in London, Munich and New York.

Our business relates to investments and professional services, so our supply chains primarily comprise professional services, information technology (including the supply of office electronic equipment), office supplies, facilities management and maintenance, catering and hospitality services, which support our investment management activities. Our supply chains are straightforward and relatively short, and we do not consider that our key suppliers give rise to material risk in connection with modern slavery, servitude or human trafficking. We expect all contractors to comply with our values and will seek to develop this understanding in future.

Our policies on slavery and human trafficking

We are committed to acting ethically with integrity and transparency in our business and supply chain dealings and to maintaining effective systems and controls to safeguard against any potential occurrence of modern slavery or human trafficking. Bregal Investments’ Compliance Manuals include the following policies and frameworks related to preventing any form of modern slavery and human trafficking activity:

  • Anti-Bribery Policy;
  • Internal Whistle-Blowing Procedures; and
  • Environmental, Social and Governance considerations.

Due diligence

Although our portfolio companies do not form part of our supply chain, we carry out due diligence into all aspects of the relevant businesses to identify any material risk areas including, but not limited to, those involving ESG and human rights.

We have in place policies and procedures to:

  • Identify and assess potential risk areas in our supply chains;
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains;
  • Monitor potential risk areas in our supply chains; and
  • Protect whistle-blowers.

We undertake additional background checks on relevant suppliers to confirm if any supplier has been named on international watch lists or has any negative ESG and human rights related press associated with its business. We have a dedicated compliance team, which consists of involvement from the Legal, Finance and ESG teams.

Staff found to be acting in breach with the principles as described in the compliance manual may be subject to disciplinary measures ranging from an official warning to suspension or dismissal, depending on the nature and severity of the breach. All staff are made aware that certain violations of the compliance manual may also lead to criminal prosecution.

Risk assessment

As far as we know, we do not have any slavery or human trafficking occurring in our own operations, our supply chain or our investments, and we understand that the industry we operate in is at a low risk of non-compliance.

Performance indicators

There have been no reports received from employees, the public, or law enforcement agencies to indicate that modern slavery or human trafficking has been identified.

Training

Existing Bregal employees sign Quarterly Compliance Attestations to confirm their compliance with the Firm’s compliance programme to preserve Bregal’s way of working, its reputation and its business culture. We also ensure compliance with our principles by conducting regular reviews.

Future steps

Bregal continues to raise awareness and educate our employees in relation to ESG and human rights’ implications across our business. We are committed to continuing to take positive steps in pursuit of our aim of prohibiting any form of slavery within our business or supply chains.

To maintain our culture of integrity and our adherence to laws and regulations, we will continue to search for new ways to maintain this culture and our commitment to ESG improvement initiatives and transmit our firm’s values to new employees and update any policy when relevant.

This statement was approved by the Bregal’s ESG Executive Committee.