Modern Slavery and Human Trafficking Statement for the G.A. Entities
Effective as of November 1, 2021
The UK Modern Slavery Act (“MSA”) requires certain businesses operating in the United Kingdom (“UK”) to report annually on the steps that they have taken during the preceding financial year to prevent slavery and human trafficking taking place in their own business as well as in their supply chains.
General Atlantic is a leading global growth equity firm with more than four decades of experience providing capital and strategic support for over 400 growth companies throughout its history. Established in 1980 to partner with visionary entrepreneurs and deliver lasting impact, the firm combines a collaborative global approach, sector specific expertise, a long-term investment horizon and a deep understanding of growth drivers to partner with great entrepreneurs and management teams to scale innovative businesses around the world. General Atlantic has offices
in New York, Amsterdam, Beijing, Hong Kong, Jakarta, London, Mexico City, Mumbai, Munich, Palo Alto, São Paulo, Shanghai, Singapore and Stamford. For more information on General Atlantic, please visit the website: www.generalatlantic.com.
General Atlantic currently operates an office in London under the name General Atlantic (UK), LLP (together with its subsidiaries, “GA UK”). GA UK provides investment advisory and transaction arrangement services to General Atlantic Service Company, L.P. and its subsidiaries, which acts as an investment advisor to its clients. GA UK is authorized and regulated by the Financial Conduct Authority in the UK. This statement is published on behalf of GA UK and the General Atlantic group entities (this “MSA Statement”).
We have a robust recruitment and onboarding process with checks built in to ensure all individuals whom we hire have the right to work in the jurisdiction where they are located, are paid a fair salary, and are treated equally and fairly in compliance with applicable laws, rules and regulations and in accordance with the standards by which all General Atlantic employees are expected to conduct business. We seek to provide and maintain safe and healthy working conditions for all employees, and our Employee Handbook(s) and/or employment contracts (as applicable) prohibit any sort of offensive, intimidating, malicious or insulting behaviour, such as bullying and harassment. These policies are distributed to new employees when they join and are accessible to relevant personnel on General Atlantic’s document sharing platform.
General Atlantic also has a grievance mechanism for employees to report violations of law or our policies. General Atlantic’s Internal Reporting Policy and Procedures provides that any employee, who comes forward with genuinely-held concerns, will not be retaliated against as a result of such action.
In addition, starting in 2021, General Atlantic’s policy on Modern Slavery will be made available to all employees through General Atlantic’s internal portal for employees to review and access.
Supply Chain Review
We believe that the risk of modern slavery in our vendor base is low. Our key vendors include professional services firms, such as legal, investment banking, accounting and other consulting firms, and providers of research and data analytics, software and information technology services. These types of vendors and the nature of the work that they perform for us do not present the indicia most often associated with modern slavery. We believe that the risk of modern slavery at these vendors is minimal with respect to the services that they provide to us.
To a lesser extent, our service vendors include airlines, hotels, restaurants and food services, cleaning, and car services. We also purchase from retailers off-the-shelf goods such as office equipment and supplies. We believe that the risk of modern slavery at these vendors is low with respect to the goods and services we purchase from them due to the particular vendors and/or the location of performance. However, given the nature of our business relationships with these vendors, we have limited ability to assess their employment practices or supply chains. We have a large vendor base; accordingly, we do not describe in this Statement all of the types of vendors that we do business with.
To help ensure that vendors are aware of our policies and expectations relating to modern slavery, this MSA Statement is available to our vendors on our website. We also have the grievance mechanisms described earlier in this MSA Statement, which apply to grievances against vendors and suppliers.
No incidents of modern slavery in our supply chain were brought to our attention in 2021. If cases of modern slavery are uncovered at any point, General Atlantic would determine the appropriate course of action on a case-by-case basis. In cases where the issue cannot be resolved to General Atlantic’s satisfaction, we may seek to terminate the arrangement with the vendor.
Adherence to Our Expectations by Vendors
Moving forward, depending on the risk factors presented by a particular vendor, Legal & Compliance may perform a compliance check on new or renewing vendors, including GA UK vendors, to mitigate third-party risk. The check may be performed using the compliance portal of a well-known provider of risk solutions and the vendor may be screened against international sanctions or watch lists and/or for reputational issues, bribery and corruption risks, litigation, or negative press, any of which may indicate indicia of modern slavery or other behavior that is inconsistent with our business principles. Where we believe there may be a higher risk of harmful practices within a sector or jurisdiction that a vendor operates in, we may also seek contractual representations from those vendors regarding their own compliance with the Modern Slavery Act.
Through internal discussions and formal approval of this MSA Statement, we have educated senior management and other employees involved in supply chain oversight about modern slavery risk and our related policies and procedures. We have provided copies of this MSA Statement to the Management Committee, heads of business units, Human Capital, Legal & Compliance, employees in the GA UK office, and office managers.
In addition, environmental, social and governance (“ESG”) and diversity and inclusion issues are a dynamic element of General Atlantic’s business. As part of these efforts, General Atlantic educates its personnel on employment issues such as harassment and bullying, having an open and inclusive work environment, and unconscious bias; and ESG issues such as supply chain monitoring and fair labor practices.