Modern Slavery Act Statement
Overview
At PSG, we recognise the importance of ensuring that our business is conducted responsibly. We welcome the Modern Slavery Act 2015 (the "MSA") and the transparency it encourages, and take a zero-tolerance approach to modern slavery occurring in our business or supply chains.
This statement is made pursuant to section 54(1) of the MSA and constitutes PSG's slavery and human trafficking statement for the financial year ending 31 December 2023. References to “we”, “us”, “our” or “PSG” are to PSG Equity LLP.
We expect all of our employees and suppliers to maintain high standards, including conducting our business with honesty and integrity. As part of our wider environment, social and governance (“ESG”) efforts, we have specific webpages outlining our ESG program and community initiatives, which consider what we view as our social responsibilities and outline our efforts across a number of areas relating to our impact on society as a whole.
Business Structure
PSG operates as a limited liability partnership owned by our Members, who, through a Management Committee, make management decisions on behalf of PSG.
PSG provides investment advisory services to our US parent company, PSG Equity L.L.C. Our parent company provides investment management services to investment vehicles that invest into software and technology-enabled services companies, with the aim of scaling and expanding these businesses. PSG is based in the UK and is regulated by the UK's Financial Conduct Authority.
Supply Chains
PSG takes a zero-tolerance approach to slavery and human trafficking in all its forms. We endeavour to ensure that our business and supply chains are conducted and managed responsibly, in line with the principles underpinning the MSA.
Given the nature of PSG's advisory business, we believe there is a relatively low risk of slavery or human trafficking in connection with our activities. The goods and services we typically procure are limited to areas relating to professional services such as office equipment, IT, advisory services and facility management.
Policies and Procedures
In addition to this statement, PSG has a number of existing policies and procedures which support our broader commitments in relation to human rights and fair treatment. These include:
- Government Reporting and Whistleblowing Policy, which includes information for reporting any suspected violations of law (including breaches of the MSA);
- Anti-Harassment and Equal Opportunity Policy;
- Anti-Bullying Policy;
- Anti-Bribery and Corruption Policy; and
- Health & Safety Policy.
Risk Management and Due Diligence
Despite our business having a relatively low risk of slavery or human trafficking, we understand that no business is completely risk-free. Therefore, consistent with the principles of the MSA and as part of our initiative to identify and manage risk:
- We look to build and improve our systems to better (a) identify and monitor potential risk areas in our supply chains and (b) train our employees as to these risks and the need to manage them.
- Where possible, we build long-standing relationships with our key suppliers and ensure that expectations of business behaviour are clear and consistent.
Implementation
Our Management Committee has responsibility for implementing the objectives considered in this statement.
Training
PSG will provide regular training and/or communication as necessary to educate relevant employees and Members 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, these may be reported to any governmental agency or entity (including using our whistleblowing procedures, which are further detailed in our Government Reporting and Whistleblowing Policy) and should be reported internally to PSG’s Chief Compliance Officer.
This statement will be reviewed annually and published on our website.
Approvals
The PSG Management Committee approved this statement on 19 August 2024.