Modern Slavery Act Statement

1. Triple Point Structure, Business and Supply Chains

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”), on behalf of Triple Point Group and any entities that adopt this policy from Triple Point as the investment manager for their company. In some instances, entities implement their own individual policies (see table on page 5).

Triple Point provides investment management services, raising capital from governmental clients, retail and institutional investors. Funds raised are primarily invested into four core sectors – real estate, debt, infrastructure and venture capital. Our business operates out of a single, London, UK office, directly employing 227 people (excluding 12 Partners) (as at 30 September 2024). The registered office is 1 King William Street, London, EC4N 7AF.

Triple Point has a corporate responsibility to respect human rights and manage modern slavery risk in all aspects of its business. Our approach to risk assessment and mitigation of human right respect breaches are outlined within this statement.

Triple Point identifies four core areas of activity where influence is held, and therefore have a responsibility, to respect human rights:

1. 1. Our colleagues
2. 2. Our supply chains
3. 3. Our clients
4. 4. Our investments

2. Policies

1. Our colleagues
We take the safety and wellbeing of our staff very seriously. As part of our HR policies and procedures, we only use reputable recruitment firms and comply with all relevant local laws and regulations. We are an accredited Living Wage employer and seek to appropriately and fairly remunerate staff. We achieve this by conducting regular benchmarking during an annual review process for all staff. We monitor guidelines, such as The London Living Wage, which would set a baseline minimum for even the most junior roles in the business, including short-term roles such as internships.

2. Our supply chains
The core of our supply chain consists of other regulated professional service providers (law firms, accountancy firms and banks). We operate in a highly regulated environment with robust compliance policies and procedures in place when selecting counterparties. We consider these regulated professions to have low risk to Modern Slavery exposure.

Where we are required to use other suppliers for example for catering or purchasing or servicing office equipment, suppliers are subject to a risk assessment and appropriate background checks. In addition, we seek to ensure that contractual provisions for all service providers incorporate Modern Slavery risk assurances.

For the procurement of all new suppliers, where the cost is over £10,000, an ESG supplier questionnaire must be completed. The questionnaire includes the requirement for each new supplier to confirm adherence with the Modern Slavery Act. The questionnaire is reviewed and approved by the sustainability team prior to contracting.

Our office is within a shared office block, with communal services provided for main reception, cleaning and security. We engage with the lease provider for evidence of best practice in office management for all these services, in particular requiring reassurance on the circumstances of those providing cleaning services.

3. Our Clients
Triple Point are committed to performing due diligence on all clients that we engage with. We ensure a Know Your Customer (KYC) process is undertaken to protect against risks of dealing with customers who are not whom they claim. We screen all our clients on an initial and ongoing basis against a range of databases, which include human rights and modern slavery indicators.

Whilst the risk of modern slavery is low across our client base, we recognise the importance of minimising risks appropriately and conducting thorough risk management.

4. Our Investments
We recognise that our core risk exposure lies in the investments we make rather than in our own supply chains.

In addressing our core risk exposure of Modern Slavery via the investments we make, we take a structured and careful approach.

Rationale for action in our investments
Human trafficking is one of the world’s fastest growing criminal industries. With approximately $150 billion in annual profits made from forced labour, much of this illicit money flows through the global financial system. Modern slavery often remains deliberately concealed, particularly within intricate global value chains and the broader financial ecosystem. Therefore, capital market actors may inadvertently support businesses reliant on forced labour or support an environment that might exacerbate labour exploitation.

Triple Point recognise we have a role as a responsible investor to manage this modern slavery risk. We understand investors are now expected to scrutinise all investments, no matter how small the stake, for exposure to Modern Slavery, which can hide deep in complex supply chains.

We believe that Modern Slavery can pose a material risk to the companies we invest in and consequently our own capital, and that of our clients, without appropriate due diligence on this issue.

A supply chain built on Modern Slavery is not sustainable and places a business model at risk, along with creating negative impacts on the lives of those subject to the practice.

Companies that do not provide a robust and appropriate Modern Slavery Act statement are, rightly, more likely to face greater scrutiny, not only from investors like ourselves, but also from Non Government Organisations, customers, business partners and public contracting authorities.

3. DUE DILIGENCE, RISK ASSESSMENT AND MANAGEMENT PROCESSES

We have developed an integrated approach to Modern Slavery risk assessment, which is embedded within the ESG integration approach we have adopted across all our investment strategies. This approach ensures that every investment is subject to a proportionate and appropriate level of environmental, social and governance (ESG) issue scrutiny, including relating to Modern Slavery exposure.

Size and sector of operation frame our due diligence and our efforts to improve corporate behaviour on this global challenge.

1. Company size
Where a company’s revenue requires it to publish a Modern Slavery Act Statement, we expect their statement to meet the highest levels of Government guidance, which includes comprehensive information on the following six areas:

i. structure of business
ii. supply chains
iii. policies
iv. due diligence
v. risk assessment and management
vi. effectiveness and training

For smaller companies, we adjust our expectations, by focusing on questions which look at governance, supply chain structure, business model and risk assessment; rather than explicitly expecting to see a Modern Slavery Statement.

2. Sector of operations
We consider sector to be a key indicator of potential exposure to modern slavery and use likely exposure of an investment to a high-risk sector to set the level of interrogation. We expect the most robust and sophisticated Modern Slavery response to come from those companies who operate in high-risk sectors, are large, and have complex supply chains.

Per-Strategy Risk Management Table

Investment strategy	Risk potential	Risk rationale	Management of risk	Further information
Triple Point Social Housing	Low/Mid	Presence of vulnerable workers in care/domestic work provision for social housing	Request Registered Providers supply a Modern Slavery Act statement; Regular site visits	Triple Point Social Housing REIT plc ESG Integration policy
Digital 9 Infrastructure PLC	Mid/High	Exposure to manufacturing and contractor relationships. Complex employment arrangements.	Due diligence on construction and contractor counterparties; monitor local regulations	Triple Point Digital 9 Infrastructure ESG integration policy
TP Leasing Limited	Mid	Exposure to manufacturing and complex UK corporate supply chains	Request MS Statement or query approach via Business and Human Rights’ registry	TPLL and TPLP Modern Slavery Act statements
Triple Point Lease Partners / Triple Point Navigator Trading Limited	Mid	Varied supply chains of small and large UK companies	Expect MS compliance in lending; Site monitoring; Enhanced portfolio review	Triple Point Navigator ESG Integration Policy
Triple Point Advancr Leasing PLC / Triple Point Income Service / Triple Point Income VCT E	Low/Mid	Exposure via infrastructure project maintenance	Request reporting from Ops & Maintenance contractors	Triple Point Energy Transition ESG Integration Policy
Triple Point Energy Transition strategy	Mid/High	Exposure via construction workers and practices	Due diligence on construction employment practices	Triple Point Energy Transition ESG Integration Policy
Triple Point VCT 2011 PLC (Venture share class)	Low/Mid	Varied supply chains of small UK companies	Sector-based interrogation of materials sourcing	Triple Point Ventures ESG Integration Policy
Triple Point Impact EIS / HNIP*	Mid	Construction worker employment practices	Request information from grant/loan applicants on responsible practices	Triple Point HNIP ESG Integration Policy
GHNF*	Mid	Construction worker employment practices	Request information from grant/loan applicants on responsible practices	Triple Point GHNF ESG Integration Policy