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The following statement is made in accordance with section 54 of the UK Modern Slavery Act 2015 (the “Act”). It sets out the steps that STAR Capital Partnership LLP and STAR Capital Partners Limited (together “STAR”), has taken to ensure that slavery and human trafficking are not taking place in its business or supply chains in the most recent audited financial year.
As an investment manager, STAR’s actions around modern slavery have two components:
In accordance with the Act, this statement covers the first of these, our own supply chain. A substantial part of our efforts regarding slavery and human trafficking is through our influence on the board of directors of portfolio companies of the investment funds managed or advised by STAR.
STAR Capital Partnership LLP and STAR Capital Partners Limited are UK investment managers headquartered in London. We manage and advise investment funds investing money from a group of investors, the majority of which is from pension funds, sovereign wealth funds and funds of funds. These funds invest predominantly in private companies headquartered in Western Europe. STAR’s workforce comprises a diverse and skilled group of professional finance, legal, compliance and operations personnel and is based entirely in Western Europe in an office setting. Given that, we consider there to be a minimal risk of modern slavery in our own operations and our focus regarding modern slavery is therefore on our supply chain.
The majority of our suppliers are located in the UK and Europe. As an investment firm, we work with a wide range of suppliers, including professional service providers such as legal, accounting, consultancy, and IT firms. Our supplier base also covers office equipment vendors, transport, and maintenance providers, as well as businesses that support our day-to-day operations, including catering and security services.
There may be a higher risk in the supply chains of our suppliers, of which we have limited visibility. The focus of our response is therefore on understanding the policies and procedures that our suppliers have put in place.
Responsible investment has long been a key focus for the STAR funds, as outlined in STAR’s Sustainability Policy available on the official STAR website. STAR is committed to being a responsible business owner, actively managing sustainability risks and opportunities both at STAR and across its portfolio companies.
The ultimate accountability for STAR’s sustainability strategy and policy lies with the Executive Board. The ESG Committee, led by STAR’s Sustainability & ESG Manager, regularly reports to the Executive Board to ensure ongoing oversight and progress.
As a firm, we take a zero-tolerance approach to slavery and forced labour in our business or its supply chain. Examples of the following policies in place relevant to modern slavery which we review, and update are presented below.
Sustainability Policy
Whistleblowing Policy
Equality, Diversity and Inclusion Policy
Stewardship Policy
Our due diligence on suppliers is based on an assessment of materiality. For material new suppliers, we review the supplier’s publicly available information regarding modern slavery and assess the adequacy of measures in place.
As responsible investors and signatories to the PRI, we actively seek to influence and assist our portfolio companies in mitigating the risk of modern slavery within their supply chains. We regularly observe a growing number of our portfolio companies adopting human rights policies and supplier codes of conduct. STAR actively supports these companies by sharing best practices and valuable insights to assist them in developing robust policies and effective implementation strategies.
During pre-investment due diligence, an assessment is conducted of the policies and processes that potential investments have in place to manage risks related to modern slavery and human rights. This includes evaluating how prospective companies identify, prevent, and address modern slavery and human rights impacts within their operations and supply chains.
During the relevant period, which corresponds to STAR’s financial year, we have neither identified nor been made aware of any instances of slavery or human trafficking within our firm’s supply chains or those of its portfolio companies.
We conduct a risk review of STAR’s most material suppliers by expenditure. For the material suppliers identified, we obtain and review their modern slavery statements and other materials such as corporate responsibility reports, where available. For those suppliers which may be deemed higher risk, we would engage in discussions to better understand their treatment of these issues.
During the relevant period we conducted an overall risk assessment of all suppliers used in relation to their modern slavery statements and risk profile.
The results of our supply chain review reinforced our view that there is a low risk of modern slavery in our suppliers, which are largely providers of professional services with employees based in Western Europe.
We have not become aware of any incidence of modern slavery in our supply chain in the year.
STAR conducts regular training for employees, which includes updates on the prevention of human trafficking and modern slavery.
This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes STAR’s slavery and human trafficking statement for the financial year ending 31 March 2025. It was approved by the members of STAR Capital Partnership LLP and the Executive Board of STAR Capital Partners Limited on 14th October 2025.
Signed by TM, Designated member of STAR Capital Partnership LLP and the Director of STAR Capital Partners Limited.
15th Floor, 33 Cavendish Square
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United Kingdom
Tel: +44 (0)20 7016 8500
e-mail: mail@star-capital.com
Important Notice: we have become aware that an organisation with a similar name has been targeting individuals in the UK through unsolicited calls to make cryptocurrency investments. Our firm, STAR Capital Partnership LLP, does not engage in this type of activity. Please see here for information on how to protect yourself from financial fraud and, if you have fallen victim to it, please report it to the UK Financial Conduct Authority by telephone or email: https://www.fca.org.uk/consumers/protect-yourself-scams.