2023 statement under Modern Slavery Act 2015 of IH International Advisors Ltd

This statement constitutes the slavery and human trafficking statement for IH International Advisors Ltd for the financial year ending 31st December 2023, (the "Relevant Year") as required by section 54 of the Modern Slavery Act 2015.

IH International Advisors Ltd (“IHIA Ltd”) is an investment advisory company operating out of London and (via its US subsidiary) New York).  The goal of IHIA Ltd is to create long-term value through private investments made by its affiliates. The cornerstones of IHIA Ltd’s operations is the investment advice (including but not limited to formulation of strategy, recommendation of specific investment opportunities and monitoring of portfolio investment performance to Inter Fund Management, an affiliated alternative investment manager established in Luxembourg for its affiliated regulated Investment Funds that invest in private assets globally.

During 2023 IHIA Ltd had an average of 19 direct employees. IHIA Ltd's supply chain is relatively simple and predominately comprises of business and professional services providers. 

Steps taken by IHIA Ltd during the Relevant Period to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its business:

IHIA Ltd conducts its activities in accordance with the Interogo Holding Code of Conduct which sets out the standards it expects from all those involved in its activities, including prohibiting forced labour, providing a safe and healthy working environment, prohibiting all forms of harassment and discrimination, and generally acting in an ethical, honest, fair and respectful manner.

The Interogo Holding Code of Conduct was updated in 2023.  As part of the 2024 annual declaration for the IHIA Ltd Code of Professional Conduct and Compliance Manual, all employees will be required to understand and agree to adhere to the Interogo Holding Code of Conduct. IHIA Ltd’s consultants are contractually obliged to comply with the Interogo Holding Code of Conduct and new employees are also required to sign an annual declaration of acceptance and adherence.

For IHIA Ltd’s own operations, IHIA Ltd has assessed the risk of modern slavery arising in the delivery of services by its material suppliers. IHIA Ltd does not believe that its material suppliers pose a significant risk in this regard, as these predominantly relate to the provision of business and professional services. The main risks arising from IHIA Ltd’s operations are in relation to facilities management.  The supplier of cleaning services to IHIA Ltd’s office pays the minimum Living Wage for London.  Facilities management services affecting the common parts of the building in which IHIA Ltd’s office is located, are provided as part of our office lease arrangements. 

Although not part of IHIA Ltd’s supply chain, the investments it advises on have potentially greater impacts than its direct operations. It is the responsibility of IHIA Ltd’s investment partners and their underlying companies to comply with their own obligations under the MSA or equivalent local laws (where relevant). Nevertheless, before advising on any investment commitment, IHIA Ltd conducts due diligence on the environmental, social and governance (ESG) practices of potential investment partners. This includes a review of each partner’s investment activities to understand the level of inherent risk from a sector/geography perspective regarding modern slavery, and desktop reviews and media screening to assess if their, or their portfolio companies’, business activities have been subject to allegations of modern slavery. IHIA Ltd also communicates to them its expectations as an advisor to an affiliated investor regarding these topics.

Based on the work undertaken to date, IHIA Ltd is not aware of any instances of modern slavery or human trafficking in its operations or supply chain.

During 2024, IHIA Ltd intends to:

· Continue to engage with our investment partners on their ESG approaches and monitor the extent to which underlying portfolio companies are implementing responsible supply chain policies; 

· Inform and train all relevant staff on the MSA and its implications for how we conduct our business; and

· Add an MSA clause to material supplier contracts where we consider that there is a higher risk of modern slavery arising.

This statement was approved by the IHIA Ltd Board of Directors on 26 March 2024.