Modern Slavery and Human Trafficking Statement

Bregal Investments (“Bregal”) 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. Bregal has over 180 employees worldwide with investment teams based in London, Milan, Munich, New York and Dallas.

Bregal is committed to ensuring that there is no modern slavery or human trafficking in any part of its business or supply chains. Bregal operate several internal policies to ensure that it conducts 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, and a proud sponsor of Level 20, which promotes gender diversity in European private equity.

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

Business Organisation, Structure and Supply Chain

Bregal’s business relates to investments and professional services, and its 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. Bregal’s supply chains are straightforward and relatively short, and Bregal does not consider its key suppliers give rise to material risk in connection with modern slavery, servitude or human trafficking. Bregal expects all contractors to comply with its values and will seek to develop this understanding in future.

Policies on Slavery and Human Trafficking

Bregal are committed to acting ethically with integrity and transparency in its 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’s 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
• ESG considerations.

Due Diligence

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

Bregal has in place policies and procedures to:

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

Bregal undertakes 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. Bregal has a dedicated compliance team, which consists of involvement from the Legal, Finance and ESG teams.

Staff found to be acting in breach of 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

To the best of its knowledge, Bregal does not have any slavery or human trafficking occurring in its own operations, supply chain or investments, and understand the industries it operates in are 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

All Bregal employees complete Quarterly Compliance Attestations to confirm compliance with the firm’s compliance programme in order to preserve Bregal’s way of working, its reputation and its business culture. Bregal also ensures compliance with its 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 its business. The firm is committed to continuing to take positive steps in pursuit of its aim of prohibiting any form of slavery within its business or supply chains.

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

This statement was last reviewed and approved by Bregal’s ESG Executive Committee in March 2022.