Modern slavery and human trafficking statement
Introduction
This statement sets out the actions taken by Pollen Street Group Limited ("Pollen Street") during the financial year ending 31 December 2024, to prevent modern slavery and human trafficking in our business operations and supply chain. It is made pursuant to section 54(1) of the Modern Slavery Act 2015 and reflects our ongoing commitment to identifying and mitigating modern slavery risks.
We maintain a zero-tolerance approach to all forms of modern slavery and human trafficking. Pollen Street is a values-driven organisation, and our values – Expert, Caring, Enterprising, Progressive, and Driven – underpin our approach to business and our responsibility to respect human rights. We remain committed to upholding the UN Guiding Principles on Business and Human Rights and to maintaining robust systems to prevent slavery and human trafficking in our business, investments and supply chains.
To date we have seen no evidence of modern slavery in our organisation or supply chains. However, we recognise that modern slavery is often a hidden crime, and we are committed to continuing to focus on understanding our risk exposure. We put in place measures to mitigate risk and to prevent slavery and human trafficking in all of our activities, and within our supply chain.
About Pollen Street Group Limited
Pollen Street Group Limited (the “Company” and together with its subsidiaries the “Group” or “Pollen Street”) is an alternative asset manager dedicated to investing within the financial and business services sectors across both Private Equity and Private Credit strategies. The business was founded in 2013 and has a team of over 90 professionals with offices in London and the US.
Organisational structure and supply chains
The firm specialises in investments in the financial and business services sector, with a primary focus across UK, Europe and USA markets. Pollen Street does not act as a producer, manufacturer, or retailer of any physical goods and, operating in the Financial Services sector, has a relatively straightforward supply chain compared to other sectors.
Our supply chain includes a range of service providers. These fall into two categories:
- Investment-related: Professional services firms who provide operational, commercial and financial advice for the review of investments made by the Funds.
- Operational: Building management, IT and hardware services, catering, cleaning, and waste removal. These latter categories may be considered higher risk from a modern slavery perspective.
Governance and policies
Ultimate responsibility for the Group’s Modern Slavery framework sits with the Board and its Executive Committee. Pollen Street operates various practices, procedures and policies to ensure compliance with all human rights laws and UK employment laws. Key policies available to all employees include:
- Code of Conduct and Ethics;
- ESG Policy;
- Disciplinary Policy and Procedure;
- Diversity, Equity & Inlcusion Policy; and
- Whistleblowing Policy.
Due Diligence & Investment screening
We apply a pre-engagement assessment as part of vendor onboarding on a proportionate and risk-based approach. Periodic reviews are undertaken where required, and these reviews are tailored to the risk profile of the vendor and the services provided.
As part of our investment due diligence, we assess potential investees’ approach to, and adherence with, the firm’s Modern Slavery policy and that necessary procedures are in place to address Human Rights within their supply chain. For our existing investee companies and partners, as part of our wider monitoring, we seek to ensure these firms adopt best practice wherever our influence allows it.
The Group has zero tolerance to Slavery and Human Trafficking and places a duty on all staff to report any potential infringement arising either internally or externally. Where relevant, third-party background checks are carried out prior to new employees and contractors commencing work with Pollen Street.
Training
To ensure a higher level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we require all relevant staff in our organisation to complete training on modern slavery as a module within our wider Continuing Professional Development programme.
Measuring effectiveness – Actions in 2024
In 2024 there were no reported instances of Modern Slavery within the Group, its investees, or its Supplier Relationships. The Group will continue to review and monitor its approach to Modern Slavery amongst all of our counterparties on a regular basis.
During 2024, 100% of new investees underwent Responsible Investment assessments as part of due diligence, including modern slavery and human rights.
As part of our community partnership with Human Rights Watch (HRW), two of their leaders lead a briefing for Pollen Street employees on practical strategies for holding companies accountable on labour and human-rights issues.
Future Steps
We are committed to maintaining robust, effective policies and regularly review and enhance our policies and procedures to reflect evolving best practices and regulatory expectations and to strengthen our modern slavery risk framework. In 2025, we will:
- Review and update our supplier onboarding processes as applicable, as part of the group’s vendor management review
- For high-risk suppliers, share notice requesting compliance with the UK Modern Slavery Act
- Assess any new geographic and business operations for any human rights risks
- Continue to review reporting and whistleblowing processes to escalate any identified violations
Approval
This statement was approved by the Executive Committee of Pollen Street Group Limited, and will be reviewed annually.
Lindsey McMurray, Managing Partner
Date: June 2025