Triple Point Social Housing REIT : Modern Slavery Act Statement Dec 2023 View document

MODERN SLAVERY ACT STATEMENT

Updated as of

May 2023

MODERN SLAVERY ACT STATEMENT

1.	TRIPLE POINT STRUCTURE, BUSINESS AND SUPPLY CHAINS	2
2.	POLICIES	2
3.	DUE DILIGENCE, RISK ASSESSMENT AND MANAGEMENT PROCESSES	3
4.	ORGANISATIONAL EFFECTIVENESS AND TRACKING	6
5.	TRAINING	6

TRIPLE POINT INVESTMENT MANAGEMENT LLP - MODERN SLAVERY ACT STATEMENT

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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"). Triple Point LLP is a limited liability partnership domiciled and incorporated in England & Wales. Triple Point Investment Management LLP and Triple Point Administration LLP are subsidiary companies authorised and regulated by the Financial Conduct Authority. The registered office of all Triple Point entities is 1 King William Street, London, EC4N 7AF, collectively referred to as Triple Point Group.

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 236 people (as at 31 March 2023).

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.

This statement sets out steps taken by Triple Point LLP, Triple Point Investment Management LLP, Triple Point Administration LLP, all of which fall within the scope of section 54(2) of the Modern Slavery Act 2015.

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

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

2. POLICIES

Policies and standards

We have a number of Group policies and standards guided by international principles, that are in place to implement our commitment to operating responsibly and ethically as a business and investor.

These policies and procedures help us to embed human rights considerations into our operations and cover a number of critical areas.

• An employment verification process for all employees, including right to work checks prior to joining.
• Whistleblowing Policy (available on request) sets out the internal procedure for reporting and investigating concerns without fear of reprisals or detrimental treatment.
• ESG integration policies for each investment strategy, outlining each investment strategies approach to respecting human rights and protecting against modern slavery in investments

TRIPLE POINT INVESTMENT MANAGEMENT LLP - MODERN SLAVERY ACT STATEMENT

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3. DUE DILIGENCE, RISK ASSESSMENT AND MANAGEMENT PROCESSES

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 You 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

Guidance published by The Corporate Responsibility Coalition Ltd. (CORE) on behalf of the UK Government refers to a report by the Ethical Trading Initiative, which found that investor interest is increasingly a driver for companies to address modern slavery. Of over 70 leading brands and retailers that took part in the research, 25% now see investor concerns as a strong motivator, an increase from zero in 2015.

Triple Point recognise we have a role as a responsible investor to drive this agenda where we have influence to do so. 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 poses a material risk to the companies we invest in or lend to 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.

TRIPLE POINT INVESTMENT MANAGEMENT LLP - MODERN SLAVERY ACT STATEMENT

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3. DUE DILIGENCE, RISK ASSESSMENT AND MANAGEMENT PROCESSES

Investment Due Diligence and risk assessment

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 or loan 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:

1. structure of business
2. supply chains
3. policies
4. due diligence
5. risk assessment and management
6. 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.

Example questions include:

• Have you identified any modern slavery risks
  (including those related to raw materials, manufacturing/sourcing countries, workforce composition, or use of recruitment agencies)?
• Does the board discuss human rights issues regularly, including risks related to modern slavery?
• Describe the steps you are taking to manage the risk of forced labour in your direct operations and supply chains?
• Which stakeholders are you engaging with on modern slavery, and how?
• How are you engaging with peers on modern slavery (e.g. in sector or multi-stakeholder collaborations)?
• What processes does the company have in place to publicly respond to and investigate severe human rights related incidents?

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. We would expect reporting from such entities to go beyond tier 1 suppliers in their exposure management.

In line with Government-supported guidance from CORE, and their reference to the International Labour Organisations' sector identification, we consider the following to be sectors at high risk of forced labour and human trafficking:

• Agriculture
• Domestic Work
• Manufacturing
• Construction
• Hospitality
• Entertainment

Triple Point's investments are at risk of exposure to these sectors through our Real Estate investments (through domestic care workers

in our Specialist Supported Housing, and construction as a result of any renovation or new build work); our Energy and Infrastructure investments (where materials are sourced globally and through the possible use of construction workers who may be in debt bondage) and in the supply chains of the large and small companies we loan to or invest in, who have goods and services across a wide range of sectors.

Across our investment strategies we have varying levels of leverage and insight to tackle this challenge. The following table details the "per strategy" due diligence approach we

take to manage and minimise our exposure.

TRIPLE POINT INVESTMENT MANAGEMENT LLP - MODERN SLAVERY ACT STATEMENT

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3. DUE DILIGENCE, RISK ASSESSMENT AND MANAGEMENT PROCESSES

Investment	Risk	Risk
strategy	potential	rationale
Triple Point Social		Presence of vulnerable
Low/Mid	workers in care/domestic
Housing REIT	work provision for specialised
		supported housing

Management of risk

e.g. request all our Specialist Supported Housing Registered Providers supply a Modern Slavery Act statement

e.g. during regular site visits, the team seek reassurance that the policies are being followed and commitments adhered to

Further information

Triple Point Real Estate ESG Integration Policy

		Exposure to manufacturing and	e.g. due diligence on construction and
		contractor counterparties such as CIOB /
		contractor relationships. Complex	Triple Point Digital
Digital 9		Stronger
	employment arrangements in hiring	9 Infrastructure ESG
Mid/ High	Together training
Infrastructure PLC	construction workers and working	integration policy
	e.g. monitoring relevant foreign countries
		with contractors. Exposure to foreign
		approach and requirements for modern slavery
		employment practices.
		and ensuring all local regulations are adhered to
TP Leasing Limited			e.g. Request Modern Slavery Act
	Exposure to manufacturing	Statement or use the Business and
		Human Rights' Modern Slavery Act
		and to a range of large UK	Triple Point Generations
	Low/Mid	Registry, to check if a company has
	corporates with complex	ESG Integration Policy
Triple Point Lease		published their statement. Where there is
	supply chains.
	comparative data to determine the quality of
Partners
		behaviour, we will use it, such as KnowTheChain
Triple Point Navigator			e.g. in property lending we expect a modern
		slavery statement or equivalent measures
Trading Limited			demonstrating constructor compliance, plus
			on-going site monitoring
Triple Point Advancr		Exposure to varied supply	e.g. monitor either directly or via our client
	chains of both small UK	lending intermediaries, possible exposure to
Leasing PLC	Mid	companies and larger UK	modern slavery and either do not participate in	Triple Point Navigator
		corporates, through our	the loan, or use our influence to mitigate risk.	ESG Integration Policy
		lending processes.	Enhanced portfolio monitoring, with guidance
Triple Point Income			for teams to support in the identification of risks
		and potential mitigations which includes actively
Service
		tracking the real living wage employers and
			modern slavery policies.

Triple Point VCT 2011
PLC (share classes A		Exposure to manufacturing
& B)
Low/Mid	through maintenance of	e.g. reporting of issues requested from
VCT PLC (share classes	existing energy & infrastructure	Operations & Maintenance contractors
	projects
C,D,E)

Triple Point Infrastructure

• Energy ESG Integration Policy

Triple Point Energy		Exposure to manufacturing.	e.g. due diligence on construction
Mid/High	Complex employment	counterparties such as evidence of
Transition PLC	arrangements in hiring	implementation of CIOB/Stronger
		construction workers.	Together training
Triple Point VCT 2011
PLC (Venture share			e.g. proportionate (based on sector)
class)		Exposure to varied supply	Triple Point Ventures ESG
	Low/Mid	chains of small UK companies	interrogation of materials sourcing and	Integration Policy
Triple Point Impact EIS		management approaches

HNIP*		Exposure to manufacturing.
	Mid	Complex employment
	arrangements in hiring
GHNF*		construction workers.

e.g. request grant/loan applicants to provide information on their responsible construction practice

Triple Point HNIP ESG Integration Policy

Triple Point GHNF ESG Integration Policy

*HNIP (Heat Network Investment Project) is a UK Government initiative to create a thriving and commercial Heat Network marketplace. The programme supports projects through initial phases of construction to help bring them to market and compete with existing heating infrastructure. Triple Point manages the application and awards process for these loans and grants on behalf of the UK Government's Department of Business, Energy and Industrial Strategy (BEIS), in line with a clear set of eligibility criteria laid out by The Government. GHNF (Green Heat Network Fund) provides capital grant support for both the commercialisation and construction of new low- and zero-carbon heat networks, along with the retrofitting and expansion of existing ones. Schemes must deliver low carbon heat at a volume of heat that is consistent with our strategic objectives for heat network market growth in England. Triple Point are limited in their influence however have worked, and continue to, with DESNZ to embed high levels of ESG expectation in those projects selected, including relating to avoidance of Modern Slavery across both HNIP and GHNF.

In addition to assessing past performance and existing risks, Triple Point adopts a forward-looking approach by monitoring evolving issues. This takes place through updates and discussion at the Sustainable Investment Subgroup. The emerging risk assessment is conducted by the sustainability team at Triple Point and shared with the wider organisation through materiality assessments for each strategy.

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4. ORGANISATIONAL EFFECTIVENESS AND TRACKING

To date, there have been 0 breaches of the Modern Slavery Act across our colleagues, our supply chain or our clients.

For the management of risk associated with our investments, embedded within our ESG integration process is the tracking and reporting of all related issues, including steps to avoid exposure to Modern Slavery. Where red flags are raised or exposure identified this would be captured in the Investment Committee papers for management prior to investment, or if an issue were to come to light during the holding period, the issue would be captured for action in portfolio management reviews.

As part of our due diligence and portfolio management process, we look to engage with our investees wherever possible to raise awareness of ESG issues, including Modern Slavery, and to support improvements in management. We are also working to strengthen our quantitative tracking to enable more granular reporting at the investment level.

The due diligence and monitoring processes implemented for our investments have previously identified a single breach within our investment portfolio.

A corporate customer discovered that victims of trafficking and modern slavery had been working within their premises, and subsequently within Triple Points portfolio. On discovery, Triple Point ceased any further business, placing them on a red list. We sought to understand more about how the breach had happened and importantly what steps were being taken to ensure it would not happen again. We committed not to working with the business again until it demonstrated the required level of improved due diligence regarding the Modern Slavery Act.

Our ESG integration processes are reviewed each year and we use this process to continue to review and refine our management of Modern Slavery exposure.

We will update this statement annually and report on any significant exposure experienced and steps to mitigate. We will continue to work to improve identification of exposure, minimise risk, and influence best practice where we can.

5. TRAINING

As previously referred to, Triple Point operates in a highly regulated environment and has compliance policies and procedures in place, including guidance in relation to whistleblowing and raising concerns regarding business ethics. We ask all employees to commit to and observe the requirements of these policies and procedures and provide regular training on these issues.

Training on the Modern Slavery Act is included within our rolling programme of ESG training.

Summary

We commit to updating this statement annually and when material changes occur, to continue to refine our process, to share improvements and to report on failings.

This document is publically available on our website.

Ben Beaton & James Cranmer

Triple Point Managing Partners

May 2023

TRIPLE POINT INVESTMENT MANAGEMENT LLP - MODERN SLAVERY ACT STATEMENT

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Investments

with purpose for profit by people

From Triple Point

Something happens when people come together. From the connections we make spring ideas. Fresh solutions to big problems, from how to improve global communications and heat our homes, to how to support businesses and drive the economy. And from solutions like these flow opportunities to create value.

We call it the Triple Point. It's the place where people, purpose, and profit meet. Since 2004, we've been targeting this Triple Point in areas like digital infrastructure, energy efficiency and social housing, unlocking investment opportunities that make a difference.

Big problems create strong demand.

Strong demand drives good investments.

Good investments solve big problems.

It means that investors never have to choose between financial returns and social impact. You achieve one by achieving the other.

For more information about Triple Point please contact a member of the Team

Triple Point

1 King William Street

London

EC4N 7AF

Advisor and Investor Enquiries

020 7201 8990 [e-mail]

www.triplepoint.co.uk