Modern Slavery Act and Human Trafficking Statement

January 2021

This statement is made pursuant to Section 54 of the UK Modern Slavery Act of 2015 (MSA) and provides an overview of our efforts to help eliminate the risk of modern slavery and human trafficking. GCM Investments UK LLP (Firm) is 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.

THE FIRM

The Firm forms part of GCM Grosvenor, a global alternative asset manager that invests on behalf of clients who seek allocations to alternative investments, such as hedge funds, private equity, real estate, and infrastructure. With approximately $59 billion in assets under management globally, we are part of one of the world’s largest and most diversified independent alternative asset management firms. GCM Grosvenor is headquartered in Chicago and has offices in New York, Los Angeles, London, Tokyo, Hong Kong, and Seoul.

Positively affecting our industry and people’s lives has been a cornerstone of the Firm’s culture for decades, and this core value continues to shape the Firm. The Firm seeks to engrain a welcoming and inclusive environment for all employees, constantly looking for ways to improve the communities in which we live and work.

POLICIES

Our Code of Ethics, our Employee Handbook, and other policies reflect GCM Grosvenor’s commitment to act ethically and with integrity across our business relationships.

Our Reporting Violations, Misconduct, and Legal or Ethical Concerns Policy details the manner in which employees can confidentially raise any issues, which the Firm will investigate and deal with appropriately. We have provided both internal and external contacts for employees to use should they feel the need to raise concerns.

SUPPLY CHAIN RISK ASSESSMENT

As an investment management firm, we have relatively simple supply chains largely comprised of business and professional services organizations, including banks, fund administrators, information service providers, lawyers, and consultants. In addition, we use suppliers for our offices, including for computers, telecommunication and other equipment, catering, stationery, and cleaning services. Where possible, we build long-standing relationships with our key suppliers and seek to ensure that expectations of business behaviour are clear and consistent. As a result, we believe that there is limited risk of slavery or human trafficking taking place within our business or supply chains.

DUE DILIGENCE PROCEDURES

In summary, as part of our initiative to identify and manage risk:

  • We seek to continuously improve our systems to better (a) identify, assess, and monitor potential higher risk areas in our supply chains, (b) mitigate the risk of slavery and human trafficking occurring in our supply chains through enhanced contract term controls (to the extent appropriate and obtainable), (c) train our employees as to these risks and the need to manage them, and (d) protect whistle blowers.
  • In addition, we perform due diligence on our suppliers to assess their compliance with the MSA

ESG INITIATIVES

The Firm is a signatory to the United Nations Principles for Responsible Investment (PRI). As a PRI signatory, we incorporate environmental, social, and governance (ESG) factors into our investment analysis and decision-making processes, which includes promotion of civil and human rights. This promotes upfront awareness of, and internal discussions on, potential issues from the initial screening stage. We request that investment managers and management teams provide updated responsible investing-related information in our year-end questionnaire, and we monitor ESG compliance regularly. The Firm has received an A+ PRI grading for our overarching approach to ESG strategy governance, and for ESG integration in private equity manager selection, approval, and monitoring.

We participate in various PRI-related activities, including the Hedge Fund Working Group, Infrastructure Advisory Committee, and Responsible Investment DDQ Working Group. We have hosted PRI staff in our office to discuss ESG trends and help develop responsible investment-related curriculum.

We also share knowledge among industry colleagues and employees. We have educated clients on responsible investing and discussed with investment managers and industry peers how to become PRI signatories. We have also spoken at, or participated in, conferences to promote responsible investing.

CORPORATE SOCIAL RESPONSIBILITY TEAM

GCM Grosvenor’s Corporate Social Responsibility Team is comprised of employees across disciplines, including executive leadership.

The Team’s key responsibility is to manage how ESG considerations factor into business decisions and our investment decision-making process. The Team also identifies initiatives and industry trends, develops recommendations and execution timelines, and monitors and reports on progress through key performance indicators. As a firm, we seek to actively support and improve the communities in which our employees and clients live and work and also foster further diversity and inclusion.

For further information on our Corporate Social Responsibility Initiatives, please see our dedicated page here.

INVESTMENT INITIATIVES

We continue to broaden and enhance our efforts in ESG-related investing in a number of ways. To improve ESG transparency and reporting from managers, we are expanding the means by which we assess and track how managers fit into our ESG framework across our investment verticals. We are working to better define industry best practices by increasing our participation in the PRI initiatives. We have also expanded our involvement in ESG-related activities through increased conference participation and additional industry affiliations.

IMPLEMENTATION

Our Compliance Team takes primary responsibility for implementing the objectives considered in this statement. We also expect our employees to be aware of our policies in this area and conduct themselves in an ethical and responsible way at all times. Compliance shall escalate, as necessary, any issues with respect to the MSA to the GCM Grosvenor Operations Committee.

TRAINING

Compliance will provide regular training as necessary to educate on the importance of implementing and enforcing effective systems to ensure slavery and human trafficking is not taking place in our supply chain.

MONITORING AND REPORTING

If issues are identified in relation to modern slavery and human trafficking, these must be immediately reported to compliance@gcmlp.com.

Jonathan R. Levin
President
Date: January 22, 2021