TDR Capital LLP (“TDR”) is committed to acting as a responsible business, employer and investor. This includes seeking to ensure that slavery and human trafficking are not taking place in any part of our business or supply chain; and seeking to ensure that the companies in which we invest are similarly committed to ensuring that slavery and human trafficking are not taking place in any part of their businesses or supply chains. This statement is intended to provide details of the steps we have taken as a business during the last financial year towards ensuring that slavery and human trafficking are not taking place in our organisation or in our supply chains.
2. Overview of TDR’s business and supply chain
TDR is a private equity fund manager which manages investment funds focussed on the European mid-market. TDR was founded in 2002 and has a team of 40 professionals based out of a single London office. TDR currently manages investment funds with over €8 billion of committed capital across three main buyout funds.
The businesses in which TDR-managed funds invest are primarily based in Europe but may have operations elsewhere in the world. The majority of the businesses in which TDR-managed funds invest fall within the threshold requirements for reporting under the MSA.
As a private equity fund manager, TDR’s supply chain comprises predominantly business and professional advisers.
3. TDR’s relevant principles and policies
In 2012 we launched our formal environmental, social and governance (“ESG”) policy and principles which are based on the UN Principles for Responsible Investing. Our ESG principles help form the basis of how we work, approach investments and manage our portfolio companies and they include undertakings to:
- seek to ensure compliance with laws and regulations including anti-corruption, social laws on workforce management and fair working practices with respect to human rights;
- incorporate ESG factors in due diligence, informing our decision on whether to invest in a business;
- seek to measure, report and improve on ESG issues and performance in portfolio companies.
Before we invest in a new business as part of our diligence we seek to identify key ESG factors relating to the business including reviewing the businesses approach to slavery and human trafficking issues. Where we identify material ESG weaknesses, we will seek to put in place a plan to be implemented immediately after our investment to strengthen our portfolio companies approach to ESG issues.
ESG risk factors, including the approach to human trafficking and slavery issues, are actively monitored at portfolio company level by the board who in turn are required to report to TDR as shareholders of the business.
4. TDR’s approach to MSA and related issues
In relation to TDR’s own business, we have reviewed our material suppliers (as an initial benchmark we have considered those with an annual spend of £50k or more) and assessed whether we consider there to be particular risks of slavery or human trafficking in relation to any of these suppliers.
Broadly speaking our material suppliers in the last 12 months fall into the following categories: business and professional advisers (approx. 30%), travel and other investment related expenses (approx. 30%), Recruitment and HR costs (approx. 10%), IT/technology (5%), cleaning and property related services (approx. 5%) and various others (approx. 20%).
The business and professional advisers with whom we work are generally large international professional service providers with substantial offices or operations in the UK who are themselves subject to MSA. We do not consider that our relationships with these professional or business advisers give rise to material risks in this area. Our travel and other investment related expenses typically relate to business travel and accommodation, generally with the supplier being international airlines or hotels. We do not consider that our relationship with these suppliers give rise to material risks in respect of MSA. Given the nature of the services provided by our recruitment and HR providers we do not consider that our supply relationships in these areas give rise to material risk in respect of MSA.
We believe that, given the nature of the service providers, our relationship with IT, cleaning and property service providers could give rise to risks in respect of MSA. To seek to manage this risk we engage such suppliers on long term on-going arrangements and use suppliers whom we consider to be reputable in the industry and we are now specifically looking to all material regular suppliers in these areas to confirm that their own business activities do not involve slavery or human trafficking.
In order to continue to monitor our own supply chain we have developed a MSA questionnaire designed to assess a company’s maturity of approach to managing the risks associated with modern slavery and a series of legal due diligence questions for use pre-investment as part of the diligence process.
We have also engaged with our portfolio companies to ensure that they have adequate policies in place to seek to identify MSA issues and have, where appropriate, shared our approach on MSA issues with them to help them formulate their own procedures.
We are developing specific policy wording in relation to the risks of modern slavery and human trafficking to include in our existing ESG policies and we will review existing and new contract terms with material suppliers whom we consider to have particular risks of slavery or human trafficking to ensure they address the requirements of MSA. As part of our on-going monitoring we will also consider adopting targeted training for members of staff who manage key supplier relationships.
This statement is made in accordance with section 54(1) of the MSA and constitutes TDR Capital LLP’s slavery and human trafficking statement for the financial year ending 31 December 2018. It has been approved by the Partners of TDR Capital LLP.
Blair Thompson, Partner