Modern Slavery and Human Trafficking Statement
1. Introduction
This statement is made by Scotland Fund in the spirit of section 54 of the Modern Slavery Act 2015. We publish this statement to make clear our position on, and approach to, modern slavery and human trafficking.
Scotland Fund has a zero-tolerance approach to modern slavery, human trafficking, forced labour, child labour, servitude, and any other form of human exploitation, in any part of our own operations or our supply chains.
2. Our Organisation
Scotland Fund is a private infrastructure and hospitality platform operating across the United Kingdom, with a particular focus on Scotland. Our activities involve working with portfolio companies, counterparties, professional advisers, service providers, and contractors across a range of sectors and geographies.
3. Our Policies
We maintain internal policies and procedures designed to prevent modern slavery and human trafficking in our operations and supply chains, including:
- A Modern Slavery and Human Trafficking Policy applicable to all directors, officers, employees, contractors, and secondees;
- A Code of Conduct setting out the ethical standards we expect of our people;
- A Whistleblowing Policy enabling anyone associated with our organisation to report concerns confidentially and without fear of retaliation;
- A Supplier Code of Conduct setting out the standards we expect of those who provide goods or services to us;
- An Anti-Bribery and Corruption Policy and a Sanctions and Financial Crime Policy that together reinforce our commitment to lawful and ethical conduct.
4. Due Diligence and Risk Assessment
We assess modern slavery risk as part of our broader due diligence on counterparties, portfolio companies, and suppliers. Our approach is risk-based and is informed by factors including sector, geography, workforce composition, and supply chain complexity.
We pay particular attention to sectors and activities historically associated with elevated modern slavery risk, including construction, facilities management, cleaning, security, hospitality operations, and labour-intensive supply chains.
Where we identify elevated risk, we conduct enhanced due diligence, which may include additional questionnaires, site visits, third-party screening, and contractual protections.
5. Contractual Protections
We seek to include in our contracts with counterparties, portfolio companies, suppliers, and service providers obligations to:
- Comply with all applicable anti-slavery and human trafficking laws, including the Modern Slavery Act 2015;
- Maintain their own policies and procedures to prevent modern slavery and human trafficking;
- Cooperate with our reasonable enquiries and audits in this area;
- Notify us promptly of any actual or suspected breach.
6. Training and Awareness
We make modern slavery and human trafficking awareness materials available to our people, and require those in higher-risk roles (including procurement, operations, and counterparty engagement) to complete training appropriate to their responsibilities.
7. Reporting Concerns
Anyone with concerns about modern slavery or human trafficking in our operations or supply chains is encouraged to report them, including anonymously, by emailing legal@scotlandfund.com. We investigate all reports and take appropriate action.
8. Review
This statement is reviewed at least annually and updated where necessary to reflect changes in our organisation, operations, supply chains, and risk profile.
9. Approval
This statement has been approved by the governing body of Scotland Fund.
Scotland Fund
Scottish Enterprise Technology Park
G75 0QU
United Kingdom
Email: legal@scotlandfund.com