Modern slavery and human trafficking statement 2022

  1. Introduction

This statement sets out Pollen Street's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year ending 31 December 2022.

Pollen Street is a values based organisation and these values are embedded in all areas of our business:

  • EXPERT: We are true specialists, renowned for deep expertise and insight that creates advantage and drives success. We set the standard
  • CARING: Open and straightforward in our approach, we are as compassionate as we are committed. We are trusted because we care.
  • ENTERPRISING: We provoke, question and uncover. Creative, astute and resourceful, we work collectively to transform. We think differently.
  • PROGRESSIVE: Constantly pushing in pursuit of excellence, we see beyond boundaries. Driving growth and innovation to create impact and prosperity. We exist to empower
  • DRIVEN: Powered by an endless determination and passion for progress. Resolute and resourceful in our approach to exceeding expectations. We strive for more

Consistent with these values, and as part of the financial services industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.  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 ensure that our supply chains are free from slavery and human trafficking.

  1. About Pollen Street plc

Pollen Street plc is an asset management company that benefits from a complementary set of investment management activities and balance sheet activities.

Pollen Street was founded in 2013 and is an independent, alternative investment management company dedicated to investing in the financial and business services sectors. Pollen Street has extensive experience investing in both credit and private equity strategies and has a strong and consistent track record of delivering top tier returns.

The on balance sheet investment potrfolio invests in high quality, diversified and low risk asset based direct lending investments, with potential to generate high income returnsm together with strong capital preservation.

  1. Organisational structure and supply chains

The firm specialises on 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, it has a relatively straightforward supply chain compared to other sectors.

Our key suppliers are professional services firms who provide operational, commercial and financial advice for the review of investments made by the Funds. All suppliers are subject to a comprehensive and robust new vendor on-boarding process and on-going due diligence.

As part of our comprehensive investment due diligence process, we assess potential investees' approach to, and adherence with, the Modern Slavery policy and the necessary processes are in place to address Human Rights within their supply chain. For our existing investee companies and partners, as part of our wider ESG agenda, we seek to ensure these firms adopt best practice wherever our influence allows it. 

Pollen Street recognises the role it shares with its suppliers in tackling the growing issues of Modern Slavery. 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. Detailed background checks are carried out internally and by an independent firm prior to new employees commencing work with Pollen Street.

  1. Key policies

Pollen Street operates various practices, procedures and policies to ensure compliance with all human rights laws and UK employment laws. Key policies include the:

  • Code of Conduct and Ethics;
  • ESG Policy;
  • Disciplinary Policy and Procedure;
  • Equal Opportunities Policy; and
  • Whistleblowing Policy.

These are all set out in our staff handbook which is available to all employees.

  1. Counterparty adherence to Pollen Street values 

As mentioned previously, we do not tolerate slavery and human trafficking. We expect all potential and actual investments, all those in our supply chain and all our contractors and employees to comply with our values and we are progressing and revising our contracting processes to reflect this expectation. 

  1. Measuring effectiveness

In 2022 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.

  1. 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.

  1. Our commitment

We are committed to implementing and enforcing effective systems and controls to safeguard against slavery and human trafficking taking place anywhere in our business or supply chains.

This statement was approved by our Executive Committee, who review and update it annually.

Lindsey McMurray, Managing Partner

Date: 31 January 2023

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.