UK Modern Slavery Act – Transparency Statement

This annual transparency statement highlights the steps taken by Siguler Guff & Company, LP (“Siguler Guff” or the “Firm”), including all of its affiliates operating within the United Kingdom, during the 2016 fiscal year ended December 31, 2016, with respect to the prevention of slavery and human trafficking in its operations.

Siguler Guff acknowledges the importance of compliance with the UK Modern Slavery Act 2015 (“UK MSA”) and takes its commitments to understanding and preventing modern slavery very seriously.  Siguler Guff has attempted through all reasonable means to ensure that there is no modern slavery in the Firm or in its related supply chains.

Pursuant to Section 54 of the UK MSA, Siguler Guff is committed to upholding high ethical standards and responsible business practices in all aspects of the Firm’s operations and investment activities and has, through all reasonable means, attempted to ensure that there is no modern slavery in Siguler Guff or its related supply chains.

Siguler Guff has offices and business interests globally in New York, Boston, London, Moscow, Mumbai, São Paulo and Shanghai, and provides services to over 500 institutional clients, including corporate and public employee benefit plans, endowments, foundations, government agencies and financial institutions, and more than 600 family office and high net worth investors. The Firm primarily offers multi-strategy private equity investment services which includes distressed and special situations, distressed real estate, small business and emerging markets. The Firm’s UK subsidiary, Siguler Guff UK LLP, is authorised and regulated by the Financial Conduct Authority (“FCA”) (FRN: 471987).

Siguler Guff has implemented a responsible investing culture highlighted by an investment discipline that integrates environmental, social, and corporate governance (“ESG”) factors into each phase of the investment process, including sourcing, due diligence, negotiation of terms and conditions, monitoring of fund compliance, and remedial action, if and when required.  Siguler Guff defines ESG to include (i) credible allegations or findings (including allegations or findings by regulatory or law enforcement agencies, allegations contained in news accounts and allegations reported by whistleblowers) that a fund investment or a portfolio company in which one of the Firm’s funds has invested has materially violated any law or regulation relating to: protection of the environment; worker safety; fair wages and working conditions; collective bargaining; unlawful discrimination; child or forced labor; bribery or corruption; or product or drug safety, or (ii) any of the aforementioned allegations or findings regarding a company that is a material link in the supply chain of the Firm and with which the Firm has a direct supply chain relationship.

As part of its ESG policy, Siguler Guff maintains a Responsible Investment Committee (the “Committee”) comprising key professionals across the Firm’s investment, marketing/investor relations, and legal/compliance teams.  The Committee reviews the Firm’s ESG policies and discusses the management of any ESG issues identified.

Siguler Guff incorporates ESG considerations into all investment activities and seeks to capture the value and mitigate the risks related to these facts.  Siguler Guff is proud to be a signatory to the United Nations Principles for Responsible Investment (“UNPRI”) and believes UNPRI is a critical component for implementing ESG considerations into its investment process.

Siguler Guff will continue to comply with the requirements of the UK MSA and uphold its commitment to enforcing a robust policy designed to prevent violations involving slavery or human trafficking.

For additional information please contact compliance@sigulerguff.com.

This statement has been approved by the Firm’s partners who will review and update it annually.