Trafalgar Square

Modern Slavery Statement

Modern Slavery Statement for the year ended 31 December 2020

Set out below is the Modern Slavery Statement of Gresham House plc (“Gresham House”) for the financial year ending 31 December 2020.

About Gresham House

The Gresham House Group comprises the following regulated investment management subsidiaries:

  • Gresham House Asset Management Limited
  • Traderisks Limited
  • Resi Capital Management Limited
  • Gresham House Asset Management Ireland Limited

Gresham House is a specialist alternative asset manager, listed on the London Stock Exchange’s Alternative Investment Market (AIM).

We offer a broad range of funds, direct investments, and tailored investment opportunities, including co-investment, across five alternative investment strategies. Our clients include individual investors, financial advisers, institutional investors, charities and endowments, family offices, and business owners.

We are specialists in five key areas of alternative investment:

Strategic Equity

  • Public Equity
  • Private Equity

Real Assets

  • Forestry
  • New Energy & Sustainable Infrastructure
  • Housing

Policy in respect of anti-slavery and human trafficking

Gresham House has in place policies that include commitments in respect of anti-slavery and human trafficking. It states that we take a zero-tolerance approach to any instances of slavery or human trafficking that are identified in our supply chain.

Gresham House also has in place a Modern Slavery Policy and Procedures that outline our expectations in respect of practices concerning slavery and human trafficking prevention.

We encourage members of staff to report any suspected breaches of these policies.


In addition to our Modern Slavery Policy, we have put in place processes and procedures to identify risks of slavery and human trafficking in our business and supply chains, including:

  • risk assessments of our supply chain in relation to slavery and human trafficking giving consideration to country risk and product/service risk;
  • following a risk-based approach, anti-slavery and human trafficking due diligence on our suppliers; and
  • reporting procedures.

Training and communications

Gresham House is in the course of rolling out Modern Slavery training to all staff involved in procuring supplies for the business. We also make all such staff aware of “red flags” of slavery and human trafficking that they should consider when dealing with suppliers during contractual negotiations, site visits or any interaction with the supplier and its workers.

Business supply chains

In assessing risk within our supply chains, we have identified our material suppliers within our business.

Within our Strategic Equity business, our supply chain is relatively short and predominantly comprises highly skilled professionals. These include regulated professional advisers, and brokers, as well as suppliers of IT services and office equipment, and professional services from our lawyers, accountants and other advisers and consultants.

We recognise that modern slavery risks may be elevated within aspects of our supply chains with regard to our Real Assets business such as solar, wind and battery storage where key components are sourced from suppliers based in China and East Asia. This is in relation to key components such as solar panels which are purchased from suppliers based in China. We note the recent concerns raised about forced labour in this supply chain and have taken steps to ensure that any panels purchased come from reliable suppliers and undertake a robust due diligence on them.

We also review risks where construction services providers are appointed in the context of infrastructure and housing investments.

We also recognise that office facility service providers, including cleaning services and IT service providers, as well as branded goods not for resale, may carry a higher risk of modern slavery practices. However, as noted above, we consider the fact that our service providers are typically based in the UK, (which does not have high estimated prevalence of modern slavery according to the Global Slavery Index 2018) reduces Gresham House’s exposure to modern slavery practices in this area.


This statement made pursuant to section 54(1) of the Modern Slavery Act 2015 for the financial year ending 31 December 2020 has been approved by the Board of Directors of Gresham House.

Kevin Acton, Director of Gresham House plc

30 June 2021