Modern Slavery Statement

According to section 54(1) of the UK Modern Slavery Act 2015, on behalf of Gen II Fund Services, LLC (“Gen II”) and all legal entities which are direct or indirect subsidiaries of we declare our stance and approach to human trafficking and modern slavery as follows. Gen II has taken steps to ensure that human trafficking and modern slavery is not taking place in any supply chains or in any part of its business for the financial year 2024/2025. This declaration will be refreshed annually.

Gen II is an independent provider of administration, accounting, management and governance services to fund managers, and financial institutions with a specialism in private equity and real estate activity with several international offices, including the United Kingdom. Gen II employees act with integrity in all client and business relationships, demonstrating professional standards that put the client first. Gen II looks to be a dynamic and progressive employer committed to excellence through nurturing our people, supporting our clients’ ambitions, consistently delivering the highest quality work, and doing right by our communities. This includes ensuring that unlawful child labor, human trafficking and modern slavery do not take place in our supply chain or our business. Gen II is active in the financial services sector which is lower risk in terms of such activities occurring and has a relatively small supply-chain.

Through policies and procedures, training and ongoing oversight of employees and business relationships, Gen II seeks to raise and maintain awareness of the risks of human trafficking and modern slavery. This extends to due diligence undertaken on potential new clients and supply chain partners and undertaking a regular review of existing relationships to identify any potential changes. Entities or individuals who are involved in modern slavery and human trafficking; may have derived their source of wealth from such activities or who are connected to entities known to be involved in such activities are not acceptable. Gen II maintains a list of prohibited and high-risk sectors, products and delivery channels which is reviewed at least annually and includes a prohibition of undertaking any activities which may be connected to human trafficking or modern slavery.

Employees receive training and are required to raise concerns or suspicions of any such activity either through the Whistleblowing Policy or directly to the Financial Crime team in Group Risk.

Gen II has in place a detailed vendor management due diligence process and seeks to only deal with reputable third-party firms. We conduct a risk-based review of vendors and sub-contractors, ensuring that such firms adhere to relevant laws and regulations, including those of human trafficking and modern slavery.