UK Modern Slavery Act Statement
TSSP Europe, LLP (“TSSP Europe,” “we,” “us” and “our”) has published this Statement pursuant to section 54(1) of the UK Modern Slavery Act (the “Act”). This Statement relates to the financial year ended 31 March 2020.
The Act requires large organisations doing business in the United Kingdom, such as TSSP Europe, to produce a public “slavery and human trafficking statement.” The concept of “modern slavery” encapsulates behaviours such as forced, compulsory or coerced labour, deprivation of personal freedom or facilitating the movement of people for exploitation.
This Statement reports on facts, circumstances, and controls that were apparent during our most recent financial year that collectively function to provide us with confidence that slavery and human trafficking is not taking place in our own business supply chains or in any part of our own business.
OUR BUSINESS AND ORGANISATION
TSSP Europe is part of Sixth Street Partners (“Sixth Street”). Sixth Street is a global finance and investment platform with over $34 billion in assets under management as of 31 March 2020. Sixth Street carries on business in the United Kingdom and the European Union through TSSP Europe, which provides investment advisory and transaction arrangement services to certain affiliates of Sixth Street and is authorised and regulated by the Financial Conduct Authority.
Companies in which Sixth Street-sponsored investment vehicles invest are not within the scope of this Statement: Sixth Street portfolio companies that carry out business in the United Kingdom will be subject to their own obligations to comply with the Act.
We believe that there is negligible risk of modern slavery in our workforce. Our workforce consists almost entirely of skilled professionals, and a number of our workforce members are subject to professional regulation and regulatory oversight. We also maintain rigorous hiring practices.
We have policies that provide for the fair treatment of workers and compliance with applicable laws and set forth the standards by which all TSSP Europe personnel are expected to conduct business. We are committed to a policy of equal opportunity for all workers. We seek to provide and maintain safe and healthy working conditions for all workers, and our employee handbook explicitly prohibits any sort of offensive, intimidating, malicious or insulting behaviour, such as bullying and harassment.
We have a grievance mechanism for personnel to report potential or actual violations of law or our policies or other unethical behaviour. TSSP Europe’s Whistleblowing Policy encourages our personnel to report suspected wrongdoing and provides that any personnel who come forward with genuinely held concerns will not be dismissed or subjected to any detriment as a result of such action.
We review our policies regularly and are committed to making enhancements where appropriate.
Separately, Sixth Street routinely identifies and evaluates environmental, social and governance (“ESG”) issues as part of its investment process. Such assessments may identify risks relevant to whether a prospective portfolio company is engaging in or otherwise supporting forms of modern slavery. To the extent such risks were identified, they would be duly vetted and considered prior to the point Sixth Street opted to pursue the relevant investment opportunity.
OUR VENDORS AND VENDOR MANAGEMENT
We believe that the risk of modern slavery in our vendor base is low. The types of vendors that we retain and the nature of the work that they perform for us do not present the indicia most often associated with modern slavery and we seek, where possible, to build long-standing relationships with our key vendors and ensure that expectations of business conduct are clear and consistent.
The largest portion of our vendor spend is on professional services firms, such as investment banking, legal and accounting firms and other advisors and consultants, and providers of research and data analytics, software, and information technology services. Given the nature of the vendors and the services provided, and their own short, low-risk supply chains, we believe that the risk of modern slavery at these vendors is minimal with respect to the services that they provide to us.
To a lesser extent, our service vendors include airlines, hotels, restaurants and food services, cleaning, and car services. We also purchase from retailers off-the-shelf goods such as office equipment and supplies. We believe that the risk of modern slavery at these vendors is low with respect to the goods and services we purchase from them due to the particular vendors and/or the location of performance. However, given the nature of our business relationships with these vendors, we have limited ability to assess their employment practices or supply chains. We have a large vendor base; accordingly, we do not describe in this Statement all of the types of vendors that we do business with.
If a vendor is not in compliance with a contract, or additional risks are identified, we determine the appropriate course of action on a case-by-case basis. The vendor may be requested to remediate the issue identified. If we cannot resolve an issue with a vendor to our satisfaction, we may terminate our relationship with the vendor.
TRAINING AND REVIEW PROCESS
We have educated relevant internal executive and compliance personnel regarding modern slavery risk. From time to time, we intend to consider the need for additional training. In addition, to make certain that vendors and personnel are aware of our policies and expectations relating to modern slavery risks, this Statement is published on our website.
Personnel are trained on our policies and procedures and are encouraged to bring any questions or concerns pertaining to our policies or compliance with them to designated internal personnel.
IMPLEMENTATION AND MONITORING
Sixth Street’s Legal and Compliance and Human Capital Management teams will work together to implement the objectives considered in this Statement and monitor our compliance with this Statement and our related policies.
This Statement will be reviewed periodically (at a minimum, on an annual basis) at which time(s) we determine whether there have been any material changes to our modern slavery risk profile or our operations (or those of our vendors) that warrant updates to this Statement.
TSSP Europe is committed to implementing and enforcing systems and controls to safeguard against modern slavery, human trafficking, and harmful working practices.
This Statement has been approved by the Executive Committee of TSSP Europe and has been signed by a designated member of TSSP Europe. An executed copy is available upon request.