Modern Slavery

1. Our organisation and supply chain

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 by HgCapital LLP (OC301825) and Hg Pooled Management Limited (02055886) (together, “Hg”) for the financial year ending 31 March 2026.

Hg is an investor in European and transatlantic technology and services businesses. We are an AI leader in private equity, helping to build sector-leading enterprises that supply critical applications or workflow services to deliver intelligent automation for their customers. Hg has approximately 410 employees across investment offices in London, Munich, Paris, New York, and San Francisco. Our supply chain is predominantly composed of professional and business services suppliers across the UK and Europe, including legal, financial, IT, facilities management, recruitment, travel, events, and office services. Supplier relationships are managed on a devolved basis across Hg’s functions, with Legal and Compliance providing oversight on contract terms and regulatory requirements.

Given the nature of our business and supply chain, we consider overall modern slavery risk to be relatively low. We consider facilities management, events and hospitality, recruitment agencies, and travel to be our higher-risk supplier categories, as these may involve lower-paid, temporary or migrant workers.

2. Our policies

The following policies are relevant to the prevention of modern slavery in our business and supply chain:

Responsible Investment Policy: includes an exclusion on investments in companies involved in harmful or exploitative forms of forced or child labour

Sustainability Policy: covers human rights and labour conditions, with reference to the UN Global Compact, OECD Guidelines and UN Guiding Principles on Business and Human Rights

Whistleblowing Policy: provides a confidential reporting mechanism for employees and others, including signposting to the Modern Slavery Helpline (0800 012 1700)

Hg Code of Ethics: Setting the expectation for Hg staff to act with competence, dignity, integrity, and in an ethical manner when dealing with the Hg Funds, Investors, the public, third-party service providers, and fellow Hg Staff.

The Responsible Investment Policy is publicly available on Hg’s website. All policies are available to employees on the Hg intranet.

3. Risk assessment

Modern slavery risk is considered within Hg’s broader risk management framework. During FY2026, modern slavery was not explicitly named as a standalone item on the Risk Register, but falls within the general ESG Risk entry, which covers risks arising from Hg’s activities having a negative ESG impact on the firm. The ESG Risk entry is owned by the Chief Sustainability Officer and reviewed at least annually. No specific modern slavery risks were reported during FY2026.

In assessing modern slavery risk across our supply chain, we consider: the nature of the workforce involved; the geographical location of the supplier; and whether the supplier is independently in scope of the Modern Slavery Act. On this basis, we consider facilities management, events and hospitality, recruitment agencies, and travel to be our higher-risk categories. Professional services firms, technology vendors, and other regulated providers operating in the UK and Europe are considered lower risk.

4. Steps taken in FY2026

During the financial year ending 31 March 2026, Hg took the following steps to address modern slavery risk:

Made modern slavery policies, guidance, and a Modern Slavery Factsheet available to all employees via the Hg intranet.

Delivered a sustainability training module, mandatory for all new joiners, which includes specific content on modern slavery and human trafficking. The module was updated during FY2026 at a 93.3% completion rate.

Considered modern slavery risk as part of the annual review of the ESG Risk entry on the Risk Register.

Conducted a review of higher-risk suppliers (facilities management, events and hospitality, recruitment agencies, and travel) with spend above £100k, assessing whether suppliers are in scope of the Modern Slavery Act and whether they have published current MSA statements. Of the 42 suppliers reviewed: 14 are large multinational organisations with current published statements; the remainder were confirmed as below the £36m MSA threshold and not legally required to publish statements. No in-scope suppliers without a published statement were identified. A separate review of 33 recruitment agencies used during FY2026 identified no gaps.

To the best of our knowledge, no incidents of modern slavery or human trafficking were identified in Hg’s business or supply chain during FY2026.

5. Looking ahead: FY2027 commitments

We acknowledge that our approach to modern slavery requires further development in a number of areas. During FY2027 we are committed to:

Adding modern slavery as a named item within the ESG Risk entry on the Risk Register, with a documented annual review outcome

Incorporating a modern slavery warranty into standard contract terms for higher-risk supplier categories, starting with contracts due for renewal in FY2027

Approval

This statement has been approved by the members of HgCapital LLP and the board of directors of Hg Pooled Management Limited.

Steven Batchelor – Designated Member of HgCapital LLP