Modern Slavery Statement
Section 54(1) of the UK Modern Slavery Act 2015
MODERN SLAVERY ACT TRANSPARENCY STATEMENT
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (“the Act”) and constitutes the Modern Slavery Act transparency statement for the financial year ended 31 December 2021 for the Lodge Quai Group (“the Group” or “LQ”).
While the Group’s turnover is currently under the threshold required by the Act, the Group has nevertheless introduced this policy and annual statement on a voluntary basis as a matter of best practice. It is anticipated that overall turnover including in Group fund vehicles will in any event reach the threshold in the next 12-24 months.
ORGANISATIONAL STRUCTURE
LQA is an English Limited Partnership, authorised and regulated by the FCA and owned by its Limited Corporate Partners: Lodge Quai Capital Management Ltd and Lodge Quai Partners Ltd. It forms part of a wider group including Lodge Quai Services (Lux) S.a r.l. and various general partner, carried interest and fund vehicles. The majority of assets are investor assets in the fund vehicles.
LODGE QUAI
Lodge Quai. provides investment advisory services to the LQ Real Estate Funds. We invest in real estate related investments around the world with a primary focus on the European Union and U.K. Further investments are found in the U.S.A. and Australia. Our investments include Net Lease / sale and leaseback transactions, real estate private equity, mezzanine finance and debt with the goal of producing superior risk-adjusted investment returns for investors.
RISK ASSESSMENT
We believe that the sector and locations in which we operate represent a relatively low risk of modern slavery and human trafficking. Whilst we acknowledge that "increasingly complex and multi-tiered globalised supply chains, spanning multiple countries, now represent a potential site of risk for every multinational company”[i], our investment partners and service providers are generally considered relatively low risk in terms of sector and location of operations. Many of our suppliers are professional services firms, including banks, accountants and law firms.
Our investment partners, borrowers and investee companies, however, range from major multinational industrial concerns to smaller hotel, construction and primary care groups. Each has a different risk profile, some higher risk than others and our due diligence process must adapt accordingly in scope and depth of investigation.
DUE DILIGENCE
We will in future seek confirmation from our key suppliers and investee companies that neither they nor any company in their group has committed or been notified or placed under investigation for any offences relating to modern slavery or human trafficking. We will further seek confirmation that none of our key suppliers are aware of any circumstances within their supply chain that could give rise to an investigation or a prosecution for any offences relating to modern slavery or human trafficking.
We shall undertake due diligence prior to the appointment of any new supplier. We will ensure that each new supplier addresses the issue of modern slavery and human trafficking during our procurement process. We will also seek to ensure that relevant suppliers are obliged to inform us of any developments in respect of modern slavery or human trafficking either in their business or in their supply chain.
STAFF AWARENESS
We also provide relevant staff with appropriate training regarding the risks surrounding modern slavery and human trafficking in supply chains and the steps they should take to reduce those risks.
Matthew Gilpin
Group COO, Lodge Quai
05.02.22
[i] Forced Labour, Human Trafficking & the FTSE 100 – a Review of Company Disclosure and Recommendations for Investor Engagement