Modern Slavery

1. Introduction

Hg is committed to carrying out business responsibly which includes ensuring that slavery and human trafficking are not taking place in any part of our business. In addition, as an investor, we recognise the importance of engaging with the companies in which our funds invest to encourage them to take steps to adopt responsible business and supplier processes.

This statement is intended to provide details of the steps we have taken as a business during the last financial year towards ensuring that slavery and human trafficking are not taking place in our organisation or in our supply chain.

This statement covers the Hg group, including HgCapital LLP and Hg Pooled Management Limited. Directors and Board members representing both entities have reviewed and approved this statement.

2. Our organisation

Hg (including HgCapital LLP and Hg Pooled Management Limited) is a leading investor in software and services. With c.400 employees in five investment offices in the UK, Germany, France, the United States and additional offices in Luxembourg and Singapore. Hg has funds under management of >$100 billion (as of 28 July 2025), serving over 300 highly regarded institutional and sophisticated individual investors, including private and public pension funds, insurance companies, endowments and foundations. Hg has been a signatory of the United Nations-supported Principles for Responsible Investment (UNPRI) since 2012 and is committed to their six principles seeking to include sustainability risks, opportunities and impacts into our policies and practices.

As a financial services business, our supply chain is relatively short and predominantly comprises professional services spread across Europe and the USA including Belgium, Canada, Denmark, Ireland, Italy, France, Norway and Sweden.

As of August 2025, our funds have investments in over 50 technology and service companies. Some of these investment companies form part of our supply chain and we have identified that a number of them fall within the threshold of the requirements for reporting under the Modern Slavery Act in their own right.

Hg takes a collaborative approach to prevent, reduce and minimise the risks of modern slavery and human trafficking. Our Central Operations team own the supplier engagement and management process (Supplier Process) and work with several teams to inform their approach including, but not limited to Sustainability, Legal, Technology, Finance, Compliance, Human Resources, Marketing, Workspace and Client Services.

Risks are assessed and monitored throughout the year and reported on via the Risk Register to both the Audit and Risk Committee and the relevant Boards. Modern slavery risks are specifically considered, reviewed and approved at least annually on the Risk Register and ad hoc throughout the year if needed. Further detail on the Risk Management Framework is available in our Responsible Investment Policy, and TCFD report.

In 2025, Hg engaged an external third-party consultancy (the Consultancy) to support in the management of Hg’s end to end Supplier Process. This includes engagement and contract negotiation, onboarding, tracking progress, ongoing management and exit. Further, the Consultancy manages Hg’s contracts database which is provided by a separate external third-party.

A high-level overview of Hg’s supply chain is mapped out here.

Hg has 12 main categories of suppliers, detailed below:

1. Professional Services
External consultants or experts providing specialised business advisory or support.

2. Marketing
Suppliers delivering promotional services including media, branding, and campaigns.

3. IT & Telecommunications
Vendors for software, hardware, networks, and tech support services.

4. Facilities Management
Providers maintaining buildings, utilities, cleaning, and workplace infrastructure.

5. HR & Recruitment
Agencies for hiring, training, and workforce management services.

6. Travel & Accommodation
Vendors managing business travel, lodging, and related logistics services.

7. Office Supplies & Equipment
Suppliers of stationery, furniture, and general administrative consumables.

8. Utilities
Providers of energy, water, waste, and essential public services.

9. Financial Services
External partners offering insurance, audit, tax, and banking solutions.

10. Legal Services
Firms providing legal advice, representation, and compliance guidance.

11. Events & Hospitality
Vendors organising corporate events, catering, and conference support.

12. Training & Development
Suppliers delivering staff education, coaching, and skill development programs.

Looking ahead, Hg has a three-pronged approach to continuous development of our supplier process. Firstly, Hg reviews both our externalised Supplier Process’s workstreams and performance on an ongoing basis. Secondly, the Service Level Agreements which are in place with the Consultancy will be tracked on regularly. Finally, once the Consultancy’s Supplier Process procedures have been established, Hg will hold quarterly review meetings with the Consultancy.

3. Our policies

There are several Hg policies that work together to help prevent and reduce the risk of modern slavery in our business, portfolio and our supply chain:

1. Hg’s Responsible Investment Policy explains our approach to sustainability matters across our investment process. Hg’s investment strategy is to focus on software and services investments, and to follow our Responsible

Investment approach, as such Hg funds do not invest in companies that:

have production or other activities that involve harmful or exploitative forms of forced labour or child labour; or

are involved in technologies which have a negative impact on human rights; or

are, in the opinion of Hg’s Investment Committee, exploitative of vulnerable groups in society.

Further, our Sustainable Business Framework, the foundation of our portfolio engagements, takes external practices into account including the UN’s Convention Against Corruption and the UN’s Sustainable Development Goals.

2. Hg’s Sustainability Policy covers our approach to sustainability at a firm level, including matters such as human rights and labour conditions. Our sustainability policy references key standards such as the ten Principles of the UN Global Compact; the Organisation for Economic Cooperation and Development (“OECD”) Guidelines for Multinational Enterprises; the UN Guiding Principles on Business and Human Rights (“UNGP”), the International Bill of Human Rights and the ILO's Declaration on Fundamental Principles and Rights at Work. Together, these work to support businesses in preventing and mitigating adverse human rights impacts across their operations.

3. The Hg Culture Code briefly summarises Hg’s culture and outlines how this is the foundation upon which we build our success. It is embedded in the Employee Handbook which is accessible to all employees on Hg’s intranet and is encouraged to be read at the start of employment. The Handbook is reviewed throughout the year to ensure it is up to date and formally annually reviewed.

4. Hg’s Supplier Code of Conduct reiterates Hg’s commitment to forming structures and a culture that support established external structures including the ten principles of the UN Global Compact, the Organisation for Economic Cooperation and Development Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights. Launched in 2024, the Supplier Code of Conduct sets out the minimum standards expected of all suppliers, across key topics including modern slavery, when providing goods or services to Hg. It aims to create consistent high standards of conduct across our entire supply chain. It acts as an important tool in helping us to obtain greater oversight over our suppliers and in meeting our own legal and regulatory obligations.

5. Hg’s Whistleblowing Policy is annually reviewed and available on the Hg intranet. It comprises a summary with whistleblowing instructions followed by a more detailed overview and explanation.

These policies supplement our long-standing Guidelines for Business Conduct which form part of our Employee Handbook and emphasise the need for us to act with integrity, in accordance with laws, and in a manner which strengthens the trust of our stakeholders and enhances our reputation.

4. Our approach to assessing and managing risk

In 2024, to support Hg’s compliance with the Modern Slavery Act, we previously developed a supplier risk assessment tool (the Tool). The Tool, developed in tandem with multiple teams, was designed to identify any supplier contract with a heightened risk of modern slavery based on the supplier’s offering and location and flags further action, such as due diligence, is appropriate. However, since outsourcing the Supplier Process, risk assessments will be incorporated into that process. These externalised risk assessments are being developed by the Consultancy alongside Hg’s Central Operations and Workplace teams.

Whilst our methods of managing modern slavery are in development, our approach remains unchanged. As mentioned above in section (1), we assess modern slavery risks in three ways using assessment and reporting via Hg’s Risk Register, our Audit and Risk Committee and the Hg Board. More generally, we take four key considerations about a specific role and/or supplier: the level of knowledge and education required; whether it is a low paid role; if the supplier is a third party with a poor reputation who is not in scope of the Modern Slavery Act in their own right and, finally, the supplier or role’s geographical location.

We do not consider that our key relationships with professional or business services suppliers, such as our panel law firms and consultancy agreements, give rise to a material risk of modern slavery and human trafficking.

We manage the risk through the use of suppliers whom we consider to be reputable, and we request that material regular suppliers in these areas confirm that their own business activities do not involve slavery or human trafficking. Our Supplier Code of Conduct is available on Hg’s website. To the best of our knowledge, we are not aware of any incidents of modern slavery found within Hg or our supply chain.

5. Our due diligence processes

On a firm level, should a contract be flagged as having a heightened modern slavery risk, we contact the supplier to confirm that they:

Have taken steps, and describe those steps, to ensure neither slavery, forced labour nor human trafficking is taking place within the supplier’s own supply chain;

Have reviewed whether they are in scope of the Modern Slavery Act and, if so, share their annual statement with Hg; and

Pay their employees above the minimum wage.

Although not part of our supply chain, the investments made from the funds that we manage may potentially have greater impacts than our own business operations. Hg’s funds invest in software and services companies, predominately in the business-to-business space, that are headquartered in Northern Europe and North America. These businesses are not, in general, manufacturing or supplying physical products and therefore do not have complex supply chains, nor rely on raw materials or products. The portfolio companies within our funds have similar supply chains to Hg, which are relatively short and predominantly comprise large established hardware suppliers, as well as professional services, in the development and support of software products.

Before making any fund investment, we carry out due diligence into the relevant business, which includes a formal assessment of sustainability risks. Once invested, a further assessment, Hg’s Sustainability Diagnostic, is annually conducted to monitor sustainability performance and progress of the portfolio throughout the year, discussed more in section (7) below.

We share regular communications on a range of sustainability topics, including modern slavery, with our portfolio companies on our online collaboration platform, Hive. The portfolio companies actively communicate on this platform and via a new initiative: a Council of Sustainability Leads. The members create their own agenda of communications of relevant topical subjects and lead collaboration amongst the portfolio companies on the same. A recent example includes a post on suitable speakers on modern slavery risks.

6. Training

Modern Slavery and human rights related training is provided to Hg employees. The training works to ensure employees understand relevant Hg’s policies and can identify and manage sustainability related risks and opportunities within their activities:

Hg offers an online sustainability training module for its employees, which is required for all executives. The training was initially rolled out in 2022 and is accessible to all staff at all times. The course was last updated and redistributed to all employees in 2024. The course provides Hg employees an overall understanding of ESG and sustainability concepts and includes a specific mention of modern slavery and human trafficking risks.

Each Hg employee receives online training/staff attestation relating to Cybersecurity, Data Protection, Anti-Money Laundering, Anti-Bribery & Corruption, and Corporate Criminal Offence.

Sustainability related training on specific topics is provided on an as-needed basis. For example, in 2020 we rolled out external training on Anti-Competitive behaviour for Hg staff and portfolio companies.

Sustainability is sometimes covered at our firm-wide team meetings.

Hg’s Sustainability and Responsible Investment Policies, as well as other sustainability related materials including a Modern Slavery Act Factsheet, are always available on our intranet.

From a broader perspective, all new joiners to Hg receive induction training and must read the Compliance Manual and associated policies, which includes our Whistleblowing policy. Thereafter, Hg conducts annual refresher training.

Further, Hg conducts quarterly testing, for all staff, of key compliance policies and firm controls. Both the Compliance breach and firm disciplinary procedures are used when needed to ensure staff are compliant with the policies and training outlined above.

7. Our effectiveness in combating slavery and human trafficking

Previously, we had identified a small number of suppliers in potentially higher-risk areas, based on the products and/or services they supply to Hg. We have engaged with these suppliers to assess their compliance with the Modern Slavery Act. Now these suppliers, along with any newly onboarded suppliers, are now monitored using the new Supplier Process and existing Code of Conduct.

For the companies that our funds invest in, we have taken the following steps:

Carried out due diligence at the time of investment to be satisfied that their business operational activities did not involve forced or child labour.

Raised awareness of the issues and the requirements of the Modern Slavery Act.

For those which are subject to the Modern Slavery Act, we set out our expectations that they need to take steps to implement and enforce effective systems and controls to ensure they are both compliant with the Modern Slavery Act and that modern slavery is not taking place in their own business or their direct supply chains.

As mentioned in section (5), Due Diligence, above, Hg’s conducts a comprehensive Sustainability assessment of our funds’ portfolio companies as part of onboarding and annually thereafter. Our most recent assessment in 2024 covered ~100 ESG metrics, including human rights and modern slavery. The result of the annual assessment allows us to identify any gaps or areas for improvement across our portfolio.

8. Monitoring and Evaluation

Every year, Hg evaluates its approach to prevention of modern slavery. We look to improve upon our existing structures, for example by launching our supplier code of conduct, and incorporating our previous internal Procurement and Supplier Management Policy and Supplier Risk Assessment Tool into our new, externally managed Supplier Process.

Hg will monitor the following measurements to review progress in identifying and responding to the risks posed by modern slavery:

Processing of contracted suppliers using our Supplier Process

Completion of staff sustainability training

Resolution of any second-tier due diligence for higher-risk suppliers

In terms of accountability, ultimately Hg’s Board oversees the management of modern slavery risks by reviewing this statement on an ongoing basis. Tackling modern slavery risk requires input across Hg meaning that Central Operations oversee the Supplier Process, set out in (2) above, and receive input from several internal key teams including, but not limited to, Legal, Technology, Finance, Compliance, People, Marketing, Facilities and Client Services. Please see Section 4 above for more details.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015, the Transparency in Supply Chains guidance (March 2025) and constitutes Hg’s slavery and human trafficking statement for the financial year ending on the 31 March 2025. It has been approved by Hg’s Board and signed by Steven Batchelor on 14th of October 2025.

Steven Batchelor

Hg Partner and Board member