For the financial year ending 31 March 2022.
The UK Modern Slavery Act 2015 (“the Act”) introduced a requirement for certain commercial organisations operating in the UK to report annually on the steps they have taken during the preceding financial year to ensure that slavery and human trafficking are not taking place in their own business or supply chains.
Organisation Structure and Supply Chains
Ancala Partners LLP (“Ancala”) is an independent infrastructure investment manager based in London. Ancala manages funds that invest in mid-market core infrastructure assets in the UK and Europe. Our key service providers are professional services firms who provide legal, regulatory, commercial and financial advice/services for the review and management of investments made by our funds or for Ancala’s day to day operations. We also have a limited number of suppliers, which aid the smooth operation of our office, such as cleaning and waste contractors and suppliers for goods such as stationary, IT equipment and utilities.
Policies in relation to slavery and human trafficking
Given the nature of our business, we consider our potential exposure to modern slavery to be low. Nevertheless, as an organisation we strive to conduct our business with the highest ethical and professional standards. We promote a zero-tolerance approach to modern slavery and human trafficking. We are committed to ensuring the protection of human rights in our business and operations. Although the risk of occurrence of human trafficking or slavery in our supply chain is limited, we expect our service providers and suppliers, or those that directly or indirectly supply them to share similar values.
Specific policies which we have implemented internally and in relation to our suppliers are our Code of Ethics, Staff Handbook, Whistleblowing Policy and our Supplier Code of Conduct. These all promote the fair treatment of all individuals and have a zero tolerance for slavery or any other human rights violations and encourage individuals to speak up if they become aware of or suspect any behaviour, which may be contrary to our policies and values.
Due Diligence Processes and Risk assessment and management key performance indicators to measure effectiveness of steps being taken
We take anti-slavery matters seriously and so we ensure that all our suppliers undergo a robust risk-based due diligence process and accept and acknowledge our Supplier Code of Conduct before we enter a relationship with them. This process has been designed in a way to help us determine whether the company matches Ancala’s values and policies in relation to modern slavery and other related matters, or not. Ancala reserves the right to not enter a relationship with a supplier, where it has reasonable grounds to suspect that the supplier makes use of forced labour.
We also apply this approach to our portfolio companies where modern slavery forms part of our environmental, social and governance key performance indicators. Indicators include inclusion and diversity promotion within an organisation, the enforcement of policies and procedures that do not tolerate behaviours violating the Act and general social and corporate responsibility.
Neither we nor, to the best of our knowledge, our key suppliers make use of forced labour.
Training on modern slavery and trafficking
All Ancala staff receive an update to our policies and procedures on at least an annual basis and they must acknowledge their understanding and compliance with those policies. Our Modern Slavery Statement, Code of Ethics, Supplier Code of Conduct and Whistleblowing Policies form part of this and they provide awareness on our values and expectations in relation to modern slavery and trafficking, amongst other related matters. Modern slavery and trafficking also fall under our due diligence when it comes to our portfolio companies, so it is a topic that we are consistently learning about and improving on to be able to make a positive impact on our assets as well.
Ancala has prepared this statement for the purposes of the Modern Slavery Act 2015. References in the statement to “forced labour” mean any conduct, which is an offence under Part I of that Act, including slavery, servitude, any type of forced or compulsory labour and trafficking for the purposes of exploitation.