Introduction
MV Credit Partners LLP (“MV Credit”) strives to be a distinctive private credit specialist, driven by codes of conduct. We are committed to the ten principles of the United Nations Global Compact which relate to human rights, labour, environment and anti-corruption and we support the international agenda to abolish human trafficking, slavery, forced and child labour.
The statement sets down MV Credit's commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no form of slavery or human trafficking in our own business and supply chains.
This Modern Slavery and Human Trafficking Statement (” Statement”) relates to actions and activities, as required by the Modern Slavery Act 201 5 (the “Act”), during our financial year 2022.
Organisational Overview
MV Credit is an independently managed pan-European private credit specialist which invests across the capital structure, providing tailored fund solutions to investors. MV Credit is currently 100% owned by Natixis Investment Managers. MV Credit acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Act.
MV Credit strictly prohibits the use of modern slavery and human trafficking in all our operations and supply chain. We have been and will continue to be committed to operating our systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. MV Credit understands that this requires an ongoing review of both its internal practices and supply chains.
We do not enter into business with any other organisation, in the UK or abroad, which knowingly supports or is found to involve itself in slavery, servitude, forced or compulsory labour. We expect that our supply chain will hold their own supply chain to the same high standard.
No labour provided to MV Credit in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. We strictly adhere to all standards required in relation to the responsibilities under relevant employment legislation in the UK. The prevention, detection and reporting of modern slavery in any part of our company or supply chain is the responsibility of all those working for us or on our behalf. Employees must not engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this statement.
Key Vendors and Due Diligence Procedures
We are committed to ensuring that our supply chain is free of any slavery and/or human trafficking. We intend to govern all current and future third-party relationships with these slavery issues in mind. We will not knowingly support and/or do business with any suppliers who are involved in slavery.
To fulfil our obligations under the Act, MV Credit will:
- undertake due diligence procedures to assess the nature and extent of our exposure to the risk of slavery;
- request information regarding third party provider's working practices and require the relevant key vendors to confirm
that it is aware of, and complies with, its obligations under the Act; and - communicate to potential key vendors that we have a zero-tolerance policy with regards to slavery.
The above-mentioned processes aim to identify any slavery risks and can investigate and eradicate such risks.
Training
To raise awareness of the importance of these slavery issues, we are ensuring that key stakeholders (e.g., Employees) are provided with key reminders including relevant information and steps on how to identify, manage and report such risks.
Potential exposure
MV Credit considers its risk of exposure to slavery/human trafficking to be extremely limited. It does not conduct business or engage with any suppliers in high-risk geographies or industries. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
Monitoring and adherence
In accordance with section 54(4) of the Act, MV Credit has taken the following steps to ensure that modern slavery is not taking place:
- we have a Whistleblowing Policy in place to encourage the reporting of concerns and the protection of Whistle-blowers;
- MV Credit conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. Where possible, we build longstanding relationships with suppliers and make clear our expectations of business conduct. We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain;
- with regards to national or international supply chains, our point of contact is preferably with a UK or European company or branch and we expect these organisations to have appropriate anti-slavery and human trafficking policies and processes in place;
- if we find that individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. Any such action will focus on finding the most desirable outcome for those negatively impacted by the breach; and
- we have a robust recruitment process to ensure that individuals employed by us have the right to work in the relevant jurisdiction, are employed in accordance with the relevant employment legislation and are not subjected to human trafficking or forced labour.
Measuring Success
MV Credit has set the following key performance indicators to measure its success in ensuring modern slavery is not taking place in the company or its supply chain:
- ensure that the minimum employment age is adhered to in line with relevant legislation;
- ensure that the relevant ‘right to work' checks are duly completed.
- always apply at least national minimum wage thresholds in line with relevant legislation.
- ensure regular contact with third party providers including their understanding of, and compliance with, our
expectations; and - staff training levels.
As well as the above, MV Credit carries out due diligence in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains in relation to Key vendors, including conducting a review of the controls of its suppliers. We have not, to the best of our knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
Related policies
- Whistleblowing Policy
- Anti-Bribery and Corruption Policy
- Key Vendor Policy
Annual Review
This Statement will be reviewed and updated as required. MV Credit's Board endorses this Statement and is fully committed to its implementation. This Statement has been approved and authorised by MV Credit Partners LLP Board.
CEO, MV Credit Partners LLP
October 2023