Modern Slavery Statement
Introduction
This statement is made subject to section 54 of the UK Modern Slavery Act 2015 (the “Act”) by Waterland Private Equity Investments B.V. (“Waterland”) on behalf of itself, its funds under management and its advisory offices over the financial year of 2024 which ended on 31st December 2024. Waterland is a Dutch-based private equity fund manager currently managing ten private equity funds with total investor commitments of € 15 billion, licensed in The Netherlands as an alternative investment fund manager under the AIFMD. Waterland has advisory offices in Belgium (Antwerp), Germany (Hamburg and Munich), Poland (Warsaw), Denmark (Copenhagen), Norway (Oslo), Switzerland (Zurich), the United Kingdom (London and Manchester), Ireland (Dublin), France (Paris) and Spain (Barcelona). As a private equity fund manager, Waterland’s actions around modern slavery have two components:
- ensuring slavery or human trafficking is not taking place in Waterland’s own supply chain; and
- for those companies in which funds under management of Waterland hold investments, Waterland exercises its influence to encourage the adoption of measures to reduce the risk of slavery and human trafficking.
In accordance with the Act, this statement relates to the above paragraph (i). Paragraph (ii) is part of Waterland’s Responsible Investment Policy which can be found on the Waterland website: Waterland’s responsible investing policy.
Supply chain
The Waterland workforce comprises of a diverse and highly skilled group of investment team members and support staff. The Waterland workforce is based in the European Union, the United Kingdom and Switzerland, and is working from an office environment. There is therefore a minimal risk of modern slavery in Waterland’s own operations and our focus is therefore on Waterland’s own supply chain.
Due to the nature of Waterland’s business as an alternative investment fund manager, the modern slavery and human trafficking risks within Waterland’s own supply chain are considered low. As an alternative investment fund manager, all of the material suppliers are professional service firms such as lawyers, accountants, corporate finance advisors and IT providers, which are considered to be of low risk for human trafficking and modern slavery. There may be a higher risk in the supply chains of Waterland’s suppliers, of which we have limited visibility. As part of the counterparty check, any suspicion of modern slavery or human trafficking will be investigated. Waterland’s risk assessments cover:
- ongoing monitoring and evaluation of suppliers;
- collaborating with suppliers to ensure compliance with ethical labor practices, if necessary.
Policies and procedures
Waterland’s Responsible Investment Policy is intended to ensure that Waterland contributes to the promotion of a sustainable future for businesses, society and the environment. This policy, as updated regularly, has been adopted throughout the whole organization.
Waterland has implemented a Code of Conduct throughout its organization to ensure all of its employees uphold high ethical standards. Waterland recognizes that modern slavery and human trafficking is an existing issue in today’s society. Waterland will do its utmost to prevent modern slavery and human trafficking in its business and own supply chain as it does not tolerate such behavior. Waterland is committed to acting ethically and with integrity in all its business dealings and relationships.
Governance and accountability
The board of directors of Waterland is responsible for overseeing the management of modern slavery risks and ensuring that adequate resources are allocated to prevent human trafficking and slavery within Waterland’s supply chain. This responsibility covers among others:
- regular review of supply chain due diligence processes;
- assessment of compliance with international best practices on modern slavery.
Risk assessments and due diligence
Waterland has adopted a proactive approach to identifying modern slavery risks by conducting regular risk assessments and engaging in dialogue with key suppliers, if necessary.
Key Performance Indicators
To support transparency and evaluate the effectiveness of Waterland’s approach, Waterland considers the following general indicators:
- observing whether key suppliers acknowledge or align with ethical labor standards;
- monitoring attendance among employees in compliance awareness sessions which includes modern slavery risks;
- maintaining oversight of any reported concerns related to modern slavery within Waterland’s supply chain.
These indicators are intended to provide insight and guide ongoing improvements.
Continuous improvement and engagement
Waterland aims to explore opportunities for enhancing its approach over time, where appropriate. This may include:
- awareness compliance sessions for employees which include modern slavery risks;
- engagement with stakeholders, including key suppliers and portfolio companies, to share best practices and encourage greater transparency.
Approval
This statement has been approved by the board of directors of Waterland on December 4, 2025 and signed by its director and CFO Mr. B.T. Elema on December 4, 2025.