DSW Venture Capital LLP Modern Slavery Statement
Introduction:
DSW Venture Capital LLP (“DSW Ventures”) is committed to acting ethically and with integrity in all our business dealings and relationships. We are committed to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking are not taking place anywhere in our own business or in any of our supply chains.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our company’s modern slavery and human trafficking statement, which was approved by the DSW Ventures board on 13 March 2025.
Our Business and Structure
DSW Ventures is a UK-based investment fund manager authorised and regulated by the Financial Conduct Authority. We specialise in investing venture capital in small, early-stage technology companies. We have a small team and operate entirely within the UK. Our business model involves managing funds on behalf of institutional and high-net-worth investors, and providing certain investment advisory services.
Our Supply Chains
As an investment fund manager, our direct supply chains are relatively limited. They primarily include:
- Professional service providers (legal, accounting, IT support)
- Suppliers of office space and associated services
- Software vendors
While our direct supply chains may present a lower risk of modern slavery, we are aware that modern slavery can exist in indirect supply chains related to the companies we invest in.
Our Policies on Modern Slavery
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. This anti-slavery statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Due Diligence Processes for Slavery and Human Trafficking
We undertake the following steps to mitigate the risk of modern slavery in our business and supply chains:
- Supplier Due Diligence: We conduct due diligence on our key suppliers, including assessing their modern slavery policies and practices where appropriate.
- Contractual Obligations: We aim to include clauses in our contracts with suppliers requiring them to comply with the Modern Slavery Act 2015.
- Investment Due Diligence: As part of our investment due diligence process, we consider environmental, social, and governance (ESG) factors, including the risks of modern slavery within investee companies. We acknowledge that the deeper supply chains of invested companies can present a higher risk.
- Employee Awareness: We are committed to raising awareness of modern slavery risks among our employees through the provision of associated training courses.
- Reporting Mechanisms: We encourage employees and stakeholders to report any concerns about modern slavery through our whistleblowing policy.
Risk Assessment
We have assessed the risk of modern slavery within our business and supply chains and believe that the risk is relatively low due to the nature of our operations. However, we recognise that no business is entirely risk-free and we remain vigilant.
Effectiveness
We will continue to review and improve our processes to ensure they remain effective in combating modern slavery. We will monitor the effectiveness of the steps we are taking through regular reviews of associated policies and procedures mentioned herein and any reported incidents through our whistleblowing hotline.
To the date of approval, no instances of modern slavery have been identified.
Keith Benson
Partner, DSW Ventures
13 March 2025