Modern slavery act

Modern Slavery and Human Trafficking Statement

Updated 23 June 2021

The UK Modern Slavery Act 2015 (“the Act”) introduced a requirement for covered commercial organisations operating in the UK to report annually on the steps that they have taken during the preceding financial year to ensure that slavery and human trafficking are not taking place in their own business or in their supply chains.

Set forth below are a policy statement and an overview of the steps taken ICG Enterprise Trust plc (“ICGET”) to ensure that modern slavery is not taking place in its business or supply chains.

ICG Enterprise Trust plc is an investment trust listed on the London Stock Exchange with a diversified portfolio of private equity assets. It is managed by ICG Alternative Investment Limited (the “Manager”), an independent entity. ICGET’s investment objective is to provide shareholders with long term capital growth through investment in unquoted companies, mainly through specialist funds but also directly.

Our Commitment

As an investment trust investing mainly in private equity funds, ICGET operates in a sector which is at relatively low risk of modern slavery occurring. Furthermore, ICGET primarily invests in Europe and the US. The majority of the countries in which the Company invests are ranked as low risk by the Global Slavery Index. Nevertheless, ICGET seeks to operate in line with all appropriate ethical and professional standards and takes its responsibility to its shareholders and suppliers seriously. The Board has a zero tolerance approach to modern slavery and human trafficking.

The Board’s approach to combatting Modern Slavery and Human Trafficking

The Board’s approach to combatting modern slavery and human trafficking is discussed further below under Board Awareness and Supply Chains. Further information on ESG and Responsible investment is discussed in our Annual Report.

Board Awareness

ICGET does not have any employees. All Non-Executive Directors have been made aware of the provisions of the Act and the Board has approved this statement. Jane Tufnell has been identified as the Director responsible for this area.

Supply Chains

ICGET has a number of outsourced and third party vendor relationships, the most material of which is with the Manager. Our key suppliers provide a range of financial and commercial services to ICGET. ICGET aims to deal with reputable and well-established suppliers of goods and services only and carries out risk-based due diligence depending on the criticality of the supplier. As part of its vendor oversight, ICGET will in future consider its key vendor relationships, and whether there are any particular locations or category of suppliers which present a higher risk of modern slavery, and where more therefore needs to be done to combat modern slavery. The Board has reviewed and noted the Manager’s anti-slavery practices as disclosed in its own statement available on www.icgam.com.

Signed on behalf of the Board

Jane Tufnell
Chair of the Board
Approved 23 June 2021