Modern slavery and human trafficking statement

Modern Slavery and Human Trafficking Statement for the Financial Year ended 31 December 2024

Sherwood Parentco Limited and its subsidiaries (the ‘Group’) takes its Environmental, Social and Governance (‘ESG’) responsibilities seriously and the business is run in a responsible and sustainable manner with a significant focus on the fair and ethical treatment of all stakeholders. The Group endeavors to ensure that slavery and human trafficking are not occurring within the business or its chosen supply chain partners. Throughout 2024 the Sustainability & ESG Committee continued to provide dedicated focus to the wide-ranging nature of topics covered by ESG, including the treatment of people, chaired by the Chief Risk and Governance Officer.

It is Group policy that all its current activities are carried out in developed countries with strong legislation governing human rights and that it complies with such legislation and associated practices. We are committed to opposing slavery and human trafficking in our direct operations and in the indirect operations of our supply chain. This position is supported by policies and practices, including our risk assessment of new and existing suppliers which address potential concerns relating to the treatment of people and result in a zero-tolerance approach to identified non-compliance.

Organisation Structure

This statement is made with respect to Sherwood Parentco Limited (a company registered in England and Wales with registered number 13299333 and with its registered office at Belvedere, 12 Booth Street, Manchester M2 4AW) and each of its subsidiary undertakings (as defined in the Companies Act 2006). Additional details relating to Group’s subsidiary undertakings can be found at note 21 of the Sherwood Parentco Limited Consolidated annual report and financial statements for the year ended 31 December 2024:

Financial Statements 31 December 2024

Supply Chains

The Group operates in the financial services industry and real estate markets, including hospitality and construction. Although the risk of modern slavery or human trafficking within its supply chain is low in relation to financial services, the growth of real estate within the organisation increases the risk of occurrence, as referenced in the UN Global Compact report on Forced Labour.

Nevertheless, the Group fully acknowledges the importance of rigorous due diligence of its business and supply chain Where relevant, contractual agreements include clauses relating to the UK Modern Slavery Act or equivalent for the relevant jurisdiction. In addition, as part of our Group ESG policy, the company is committed to developing an organisational culture which aligns with international best practices and The Ten Principles of the United Nations Global Compact, and the key focus areas of, Human Rights, Labour, Environment and Anti-Corruption.

The Group undertakes a risk assessment of all critical suppliers prior to their on-boarding, and this is supported by ongoing monitoring. This assessment includes Sub-Outsourcing, Information Security, Off-Shoring, Legal/Regulatory/Reputational, Modern Slavery, Environment and is updated regularly to reflect current regulations. The on-boarding process includes relevant due diligence for all suppliers.

The Group takes a zero-tolerance approach to slavery and human trafficking and should any instances of non-compliance with the Modern Slavery Act arise internally or in relation to any of our suppliers, then this will be acted upon immediately and appropriate action taken. Our risk management framework enables risks and incidents to be raised by employees and mitigation monitored both in country and at Group level in accordance with the governance requirements outlined in Group Policies.

During the 2024 financial year, we continued to further improve how we monitor and engage with our suppliers, through development of Supplier Policies and engagement methodology. This will remain a focus for 2025 and beyond.

Policies

Our Group ESG, Supplier Management and Supplier Code of Conduct policies are subject to annual review and approval by the Group’s Board. These policies outline our stance in relation to the commitment to compliance with the legislation governing human rights, across all geographies and jurisdictions. We encourage and empower our colleagues to raise concerns of any nature with the senior management of the business and the Group has a comprehensive Whistleblowing Policy in place that is specifically supported by a process which protects the anonymity of colleagues.

Actions

We continue to apply the following actions:

Assessment of slavery and trafficking in our supplier on-boarding and due diligence and in our investment process.
Reviewing and assessing critical suppliers periodically;
Understanding potential risk areas within our supply chains and ensuring adequate monitoring processes are in place;
Introducing greater visibility and control on third-party spend; and
Developing training to be provided to relevant employees to assist in the identification of slavery related risk factors to further encourage the raising of any concerns.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act and constitutes our slavery and human trafficking statement for the financial year ended 31 December 2024. This statement has been approved by the Group Board of directors and will be reviewed and updated annually.

Approved by the Board of Sherwood Parentco Limited in March 2025 and signed by Monique O’Keefe, Chief Risk and Governance Officer.

Sherwood Parentco Limited

Download the statement here