Introduction

The UK Modern Slavery Act 2015 (“MSA”) was enacted in response to the international problem of modern slavery. The MSA creates two criminal offences of modern slavery: “slavery, servitude and forced or compulsory labour” and “human trafficking”.

CD&R LLP does not tolerate any form of modern slavery and our aim is to ensure that there is no slavery or human trafficking in any part of our business or our supply chains. We are committed to helping ensure that workers are not being exploited, that they are safe, and that relevant employment, health, safety and human rights laws and international standards are adhered to.

Section 54 of the MSA requires commercial organisations in the U.K. which have an annual turnover of greater than £36 million to publish a statement setting out the steps they have taken during the financial year to ensure that modern slavery is not occurring in their own business or their supply chains.

The financial year ending 31 March 2024 is the first time that CD&R LLP has met this turnover threshold and accordingly we have prepared this modern slavery transparency statement. In future years, we anticipate building on this statement and the initial work we have undertaken so far.

CD&R LLP’s structure and business

CD&R LLP is authorised and regulated by the UK Financial Conduct Authority. CD&R LLP’s primary business is advising our U.S. affiliate, Clayton, Dubilier & Rice, LLC (“CD&R”), in relation to potential investment opportunities in the U.K. and the rest of Europe.

Founded in 1978, CD&R is a leading private investment firm with a strategy of generating strong investment returns by building more robust and sustainable businesses through the combination of skilled investment experience and deep operating capabilities. In partnership with the management teams of its portfolio companies, CD&R takes a long-term view of value creation and emphasizes positive stewardship and impact. The firm invests in businesses that span a broad range of industries, including industrial, healthcare, consumer/retail, technology and financial services.

This MSA statement applies only to CD&R LLP. CD&R LLP does not have any subsidiaries. Funds managed by CD&R invest in a number of companies around the world.  As a general matter, these portfolio companies do not form part of CD&R LLP’s supply chain, unless they do in fact supply goods or services to CD&R LLP. Certain portfolio companies carry out business in the U.K. and meet the relevant turnover threshold in the MSA; these companies are responsible for their own compliance with the MSA.

Steps taken by CD&R LLP to address the MSA

Below is an outline of some of the steps that CD&R LLP has taken in relation to modern slavery for the 2023-2024 financial year.

1. Employment practices: We aim to hire high-performing staff for all roles and at all levels within CD&R LLP. In order to do so, we provide pay and benefits (both financial and non-financial) that are in line with the market, which is highly competitive in this area. All of our staff must comply with CD&R’s Global Code of Conduct, which requires them to act with integrity, competence, dignity and in an ethical manner when dealing with their colleagues and others. The employment contracts and agreements entered into by staff, together with UK employment laws, provide further protection of their legal rights.

2. Supply chain: Given the nature and location of our business, we believe that the risk of modern slavery in CD&R LLP’s supply chain is low. Our main suppliers are professional and business services firms (such as law firms, accounting firms, data and analytics providers, technology suppliers, advisory consultancies and travel agencies) and suppliers of office essentials (such as office supplies, catering, cleaning and maintenance services).

   CD&R LLP is considering how to implement proportionate measures to help ensure that our suppliers are taking measures to address the risk of modern slavery in their own operations and supply chain, such as obtaining appropriate contractual representations.

3. Staff training: CD&R LLP is considering how best to incorporate training for our staff to raise awareness of modern slavery and risks affecting CD&R LLP, to be provided both to new joiners and periodically to current staff where relevant.

This statement has been approved by the members of CD&R LLP and signed by David A. Novak.

CD&R LLP

9 October 2024