Modern Slavery Statement
Integrum Holdings LP (the “Firm” or “Integrum”) is committed to ensuring that acts of human trafficking and modern slavery form no part of its business or supply chains. Integrum acknowledges its responsibility under the United Kingdom Modern Slavery Act 2015 (the “Act” or “MSA”) and will take steps to seek to ensure transparency within its own organization and with suppliers of goods and services with whom it contracts.
References in this statement to “Integrum,” “we” and “our” are references to Integrum and its subsidiaries.
UK MODERN SLAVERY ACT
The MSA requires large organizations doing business in the United Kingdom to publish a disclosure statement detailing the steps being taken to monitor and address the risks of modern slavery and human trafficking in its business and supply chains. In this Statement, we use the term "modern slavery," which includes slavery, servitude and forced or compulsory labor and human trafficking, all of which are abuses of a person's freedoms and rights.
In accordance with Section 54 of the Act, Integrum has prepared this United Kingdom Modern Slavery Act Transparency Statement for its most recent financial year ending September 30, 2022.
INTEGRUM’S SUPPLY CHAIN
Integrum’s supply chain is relatively short and consists predominantly of the purchase of professional services (i.e., lawyers, accountants, auditors, fund administrators and other third-party consultants) and business supplies (i.e., IT/technology providers, office equipment, office maintenance/cleaning services and travel services).
The Firm has undertaken a review of its supplier base to prevent modern slavery and human trafficking in its own operations and supply chain. This involved taking a risk-based approach to assess the likelihood of the existence of modern slavery within its supply chains. The criteria used for assessing suppliers included:
- the nature of the services being provided (i.e., the likelihood of employees being engaged on higher risk short-term contracts or providing physical labor)
- the primary geographies from which the supplier operates
- overall profile of supplier, including internal policies and procedures to mitigate the risk
Integrum considers the risk of modern slavery and human trafficking within our supply chains to be low, based on our risk assessment and due diligence. Primarily, services received are professional advisory services which support transactions and due diligence services across the Firm.
Should Integrum identify a reasonable cause for concern that a supplier represents a modern slavery and/or human trafficking risk, the Firm will either request that the supplier addresses these concerns within a pre-determined time period, or discontinue their engagement altogether, depending on nature of the issues identified. Integrum may also report any such supplier to the relevant authorities, where appropriate. To date, Integrum has not identified any cause for concern about compliance with the Firm’s expectations amongst its suppliers.
Integrum recognizes that the impact of MSA extends beyond Integrum’s own supply chain to portfolio companies we invest in. Portfolio companies will not generally fall under Integrum’s supply chain, and it is the responsibility of each portfolio company to comply with its obligations, where applicable, under the MSA. We factor MSA issues into our investment process and due diligence process.
Integrum will continue to promote awareness of the MSA, and take steps to educate and train our staff, including Integrum’s Management Committee of the MSA and its implications. In addition to our own staff, we strive to raise awareness of the MSA and its requirements within our supply chain and across our portfolio companies.
Integrum is emphatically committed to taking positive steps pursuant to its aim of prohibiting any form of modern slavery and/or human trafficking within its own business and supply chains.