MODERN SLAVERY ACT (“MSA”) STATEMENT
Index Ventures (UK) LLP and Index Venture Services Limited, together "Index Ventures" (references to “we” or "our" should be construed accordingly).
At Index Ventures, we recognise the importance of ensuring that our business is conducted responsibly. We take a zero-tolerance approach to forced labour or human trafficking occurring in our business or supply chains. We are actively looking at ways to improve our practices and are committed to enhancing our diligence and vetting processes to better identify and mitigate various risks, including those of slavery or human trafficking, in our supply chain and business activities.
BUSINESS STRUCTURE AND SUPPLY CHAIN
As a venture capital business that is office based, we consider the risk of forced labour or human trafficking existing within our business to be relatively low. The goods and services we purchase from our suppliers are generally limited and primarily relate to property, catering, cleaning and facilities maintenance (i.e. ongoing supplier
We continue to evaluate direct suppliers as part of our third-party due diligence process, by: (i) carrying out research on the prospective supplier; (ii) asking the prospective supplier to complete our due diligence questionnaire (dependent on the contract value); (iii) seeking to amend supplier contracts to mitigate associated legal, regulatory, and ethical risks; and (iv) taking any other steps to satisfy ourselves as to the quality of the prospective supplier.
POLICIES AND PROCEDURES
We have in place a variety of policies and procedures designed to address our wider commitment to promoting responsible business practices:
- Compliance Manual (covering policies on (i) anti-bribery and corruption, (ii) gifts, entertainment and hospitality, (iii) anti-fraud, (iv) anti-money laundering, and (v) whistleblowing)
- Anti-Harassment Policy
- Bereavement Policy
- ESG Policy
- Data Protection Policy
In summary, as part of our initiative to identify and manage risk:
- We are looking to improve our existing systems to better (a) identify, assess and monitor potential higher risk areas in our supply chains, (b) mitigate the risk of slavery and human trafficking occurring in our supply chains through enhanced contract terms (where relevant), and (c) train our employees as to these risks and the need to manage them.
- We already carry out the due diligence measures on our suppliers as described above.
- We endeavour to build long-standing relationships with our key suppliers and ensure that expectations of business behaviour are clear and consistent.
Our Board is ultimately responsible for the implementation of the objectives
considered in this statement.
It is supported by legal and compliance teams, working with external legal and
compliance advisers as needed, in the achievement of these objectives. The
legal and compliance teams also monitor progress of our efforts in this area
and report back to the Board directly.
We provide our staff with regular training on a range of compliance matters, and we are considering supplementing this training by including the requirements under the MSA for all relevant members of staff.
MONITORING AND REPORTING
Any issues which are identified in relation to slavery and/or human trafficking must be reported to legal and compliance teams in the first instance. If material, they will also be reported to the Board.
This statement will be reviewed annually and published on our website.
The Board of Index Venture Services Limited approved this statement for itself and on behalf of Index Ventures (UK) LLP.
Signed for and on behalf of Index Ventures (UK) LLP and Index Venture Services Limited:
As the Corporate Member Representative of Index Ventures (UK) LLP and Director of Index Venture Services Limited
Date: September 2023