Modern Slavery and Human Trafficking Statement
For the fiscal year ended March 31, 2020
The commitment of StepStone Group LP and its consolidated subsidiaries (“StepStone”, “we”, “us”, “our”) seek to integrate responsible business across all aspects of how we conduct our business, including our operations and supply chains, and investments we advise on or manage for or on behalf of our clients
This Modern Slavery and Human Trafficking Statement (the “Statement”) sets out StepStone’s approach to combatting modern slavery and human trafficking as required by the United Kingdom Modern Slavery Act of 2015, the Australia Commonwealth Modern Slavery Act of 2018 and similar legislation enacted in other applicable jurisdictions.
StepStone’s position of not tolerating modern slavery and human trafficking is in alignment with our core belief that people matter. This belief guides how we run our operations, train and treat our employees, and how we work with clients and our vendors.
This Statement is being made by StepStone Group LP, a Delaware limited partnership, on behalf of itself and its consolidated subsidiaries, which include StepStone Europe Limited, private limited company incorporated under the laws of England and Wales, StepStone Group Europe LLP, a limited liability partnership organized under the Limited Liability Partnerships Act 2000 of the United Kingdom, StepStone Group Real Assets LP, a Delaware limited partnership, StepStone Group Real Estate LP, a Delaware limited partnership, Swiss Capital Alternative Investments AG, a Swiss company limited by shares, and Swiss Capital Invest Holding (Dublin) Limited, an Irish private company limited by shares.
In preparing this Statement, directors, officers, partners and relevant responsible investment-focused professionals of StepStone Group LP and relevant subsidiaries on whose behalf this Statement was made, were consulted and provided with an opportunity to review and input prior to the formal approval process taking place.
II. Overview of StepStone’s Organization
We are a global private markets investment firm focused on providing customized investment solutions and advisory and data services to our clients. Our clients include some of the world’s largest public and private defined benefit and defined contribution pension funds, sovereign wealth funds and insurance companies, as well as prominent endowments, foundations, family offices and high-net-worth and mass affluent individuals. We partner with our clients to develop and build private markets portfolios designed to meet their specific objectives across the private equity, infrastructure, private debt and real estate asset classes. These portfolios utilize several types of synergistic investment strategies with third-party fund managers, including commitments to funds, acquiring stakes in existing funds on the secondary market and investing directly into companies and properties.
We are headquartered in New York, had approximately 500 employees as of March 31, 2020, and have investment and implementation professionals in 13 countries, including the United Kingdom and Australia.
III. Risks of Modern Slavery Practices in StepStone’s Operations, Supply Chain and Investments
StepStone has evaluated how its operations, supply chains and investments may be exposed to modern slavery and human trafficking, and the level of such exposure.
StepStone recognizes that there is a risk that modern slavery practices exist in StepStone’s operations, supply chain and investments. This may include risks in our supply chain, particularly in relation to cleaning, catering and information technology procurement, and risks in our investment or advisory portfolios, particularly in relation to certain sectors (construction, agriculture and extractives) and emerging markets geographies in which we are invested, which represent a higher risk from a modern slavery perspective. We remain committed to addressing these risks, through the steps which are set out below.
We have reviewed and assessed our operations and supply chain looking to identify material risk exposure, and concluded that due to the nature of our business, we believe modern slavery risks are low with respect to our operations and supply chain.
IV. Policies and Practices in Relation to Slavery and Human Trafficking
We have taken steps to ensure that modern slavery and human trafficking are not taking place in our organization or supply chains and we have integrated considerations on modern slavery and human trafficking risks within the evaluation and management of investments on behalf of ourselves and our clients.
StepStone has a Code of Ethics, which describes the standards of behavior expected of our employees, including the maintenance of high ethical standards. Our Global Compliance Manual contains a whistleblower policy relating to the reporting and investigation of any improper or illegal activity, and we strictly prohibit any retaliation, unfavorable or adverse employment consequences, and any form of harassment against whistleblowers. This manual also includes a complaints procedure which provides a framework for the handling of complaint received from clients. The Code of Ethics and Global Compliance Manual are reviewed and updated annually.
StepStone is dedicated to promoting an atmosphere of diversity and equal opportunity, and our employee and partner handbooks prohibit discrimination and harassment against individuals based on their actual or perceived race, religious creed, color, national origin, ancestry, physical or mental disability, medical condition, genetic information, marital status (including registered domestic partnership status), sex (including gender identity and expression), age, sexual orientation, military and veteran status, or any other characteristic protected by law.
Responsible investing is a core tenet of StepStone’s investment philosophies. We believe that integrating environmental, social and governance (“ESG”) factors into our investment processes will improve long-term, risk-adjusted returns for our clients. This includes pre-investment screening and diligence of all material ESG risks and opportunities (including modern slavery and human trafficking) as well as post-investment active monitoring and engagement. We became a signatory to the United Nations Principles for Responsible Investment and created a StepStone Responsible Investment Committee (formerly known as ESG Committee) in 2013, and have since become a signatory to The Task Force on Climate-related Financial Disclosure as well as a member of the Global Real Estate Sustainability Benchmark and the Sustainable Accounting Standards Board.
StepStone has a Responsible Investment Policy that seeks to promote the consideration of ESG factors in its investment processes. The policy is approved by StepStone’s Executive Committee, enforced by the relevant investment committees, and is applied globally across all of StepStone’s asset classes and investment strategies. StepStone has a Responsible Investment Committee composed of senior employees across all asset classes, functions and regions. This committee is supported by five Responsible Investment Workgroups. In this manner, firm-wide coordination and consultation on ESG, including with respect to modern slavery and human trafficking matters, occurs among StepStone’s consolidated subsidiaries.
V. StepStone’s Supply Chain
StepStone’s supply chain predominantly comprises professional service providers such as lawyers, tax consultants, accountants, and administrators, or business vendors such as information technology service providers and suppliers of office equipment. Given the nature of StepStone’s business as a global private markets investment firm, we believe our supply chain is low risk in respect of modern slavery and human trafficking.
Nevertheless, StepStone continually seeks to improve its vendor and service provider due diligence processes, including by inquiring with respect to modern slavery and human trafficking. We query providers on whether they have a Modern Slavery statement, and if so, ask them to provide a copy; whether they use, and have relevant due diligence measures in place to prevent the use of, child labor, forced labor or human trafficking; and whether they have had any allegations, fines or warnings with respect to modern slavery, forced labor, child labor and human trafficking.
VI. Employees, Recruitment and Training
We follow local labor laws and practices, and due to the nature of our business and our employees, we believe modern slavery risks are low with respect to our hiring of employees. StepStone provides training to employees firmwide on modern slavery and human trafficking. StepStone seeks to ensure that employees are trained to identify, and know how to report and escalate, potential exposures relating to internal operations, supply chains or investments.
VII. Due Diligence in the Investment Process
StepStone’s direct co-investments are primarily minority, non-controlling investments in operating companies alongside a lead sponsor who generally has voting control over the company. We recognize the role we play in investing, or advising with respect to investments, in companies that are compliant with modern slavery and human trafficking legislation and regulations.
StepStone includes specific questions regarding modern slavery and human trafficking in its due diligence questionnaires in respect of potential investments being evaluated, and each investment memo presented to the relevant investment committee must contain a section dedicated to addressing responsible investment. An investment may be vetoed by the investment committee based on ESG grounds. Post-investment, StepStone is implementing ongoing monitoring for responsible investment matters and seeks to be engaged on ESG matters where it has a board seat or limited partner advisory committee membership. We also seek engagement with investment managers to advocate for and support their ESG process improvements.
VIII. Effectiveness of Steps Being Taken
As noted in section V, employees are trained to identify and support potential exposures to modern slavery. In the fiscal year ended March 31, 2020, we conducted over 10 training sessions in respect of ESG and responsible investment, which among other things, covered modern slavery and human trafficking, for both our employees generally as well as our investment teams. StepStone believes the actions that we take are commensurate with the risks presented by our business model and will continue to evaluate the effectiveness of our policies and procedures in combating modern slavery and human trafficking.
This Statement was prepared pursuant to Section 54(1) of the United Kingdom Modern Slavery Act of 2015 and s 14 of the Australia Commonwealth Modern Slavery Act of 2018 for the most recent fiscal year ended March 31, 2020. The board of directors of StepStone Group Holdings LLC approved this annual statement as of August 4, 2020.
STEPSTONE GROUP LP
By: STEPSTONE GROUP HOLDINGS LLC, its general partner
/s/ Monte Brem
Name: Monte Brem
Title: Co-CEO and Chairman
/s/ Scott Hart
Name: Scott Hart