Modern Slavery
Modern Slavery and Human Trafficking Statement 2024 for Scipion Capital (UK) Ltd. and the Scipion Group
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps Scipion Capital (UK) Ltd (SCUKL) and its affiliates Scipion Capital Ltd. (SCL) and Scipion Capital (Suisse) S.A. (SCSSA and, together with SCUKL and SCL, the Scipion Group or Scipion) have taken to minimise the risk of modern slavery in the business and commercial activity of the Scipion Group.
Introduction
The Scipion Group is committed to preventing slavery and human trafficking occurring in relation to any of its business or commercial and financing activities.
SCL is one of Africa’s leading investment managers specialising in private credit, including structure trade and commodity finance, project finance, turnaround finance and debt advisory services.
Supported by a network of offices and advisors across Africa and with more than 150 years of collective senior management experience, the Scipion Group has invested more than USD 1bn in more than 15 countries.
Our organisational structure and operations
SCL is an Exempted Company in the Cayman Islands and is a registered person under the Securities Investment Business Act of the Cayman Islands and is regulated by the Cayman Islands Monetary Authority as provided for by such Act.
SCL is a limited liability company incorporated in England and is authorised and regulated by the FCA and provides investment advisory services to SCL.
SCSSA is a limited company incorporated in Switzerland and offers deal placement, investment due diligence, turnaround management or advice and restructuring of stressed loan positions.
Scipion, as a provider of investment management and advisory services, delivers those services to investors or participants in commodity trade financing. Such financing is extended by SPV companies subject to receipt of the investment management or advisory services of SCL.
Such financing is typically extended to obligors comprising commodity traders or producers predominantly (although not exclusively) in Africa. Those commodity traders and producers (collectively, Obligors) will typically then rely on a production workforce including (in the case of agricultural production) small hold farmers.
Risk: It is at this level involving the production workforce that Scipion assesses the risk of breach of the principles of the Modern Slavery Act 2015 is at its highest in Scipion business, commercial and financing activities.
Our commitment to the principles of the Modern Slavery Act 2015
The Scipion Group is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking.
As an equal opportunities employer, the Scipion Group is committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves and as such the Scipion Group has an established whistleblowing policy which all staff can access alongside all other company policies on the staff intranet.
Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK.
We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.
The Scipion Group’s commitment is to ensure that all those organisations that we or our finance vehicles directly contract with are aware of our policies in order to comply with the Modern Slavery Act. In particular, for the Scipion Group this involves ensuring that each Obligor complies with the principles of the Modern Slavery Act and relevant local labour legislation in their own country, and that such Obligor ensures that all organisations and individuals in their supply chain similarly comply.
For example, when evaluating a potential new financing opportunity for a commodity producer, Scipion conducts on-site due diligence visits with respect to each potential new Obligor and this extends to evaluation of their production site and practices down (in agricultural financing) to visiting individual smallholder farmers and ensuring all practices comply with the principles of the Modern Slavery Act.
In the event that a potential Obligor is unable to evidence such compliance then the Scipion Group would not advance commodity trade financing to them.
Existing Obligors will be subject to further due diligence visits by representatives of Scipion Capital to ensure compliance is maintained on an on-going basis.
Policies relating to slavery and human trafficking
Previous action
With the assistance of an external Technical Assistance programme, Scipion has developed and implements an Environmental Social Management System Programme (the “ESMS Programme”) for identifying and addressing E&S risks related to activities of Scipion’s Obligors.
Scipion’s Policy is underpinned by the ESMS Programme that provides a tailored framework with supporting procedures and tools to be implemented internally as well as with the involvement of Scipion’s Obligors/investors. Through the ESMS Programme, Scipion endorses best practices and puts in place necessary mechanisms and means allowing to attain its short-term and long-term E&S goals, including: defining internal roles and responsibilities, due diligence requirements, regular monitoring & reporting, stakeholder engagement and grievance procedures.
The ESMS Programme enables Scipion to improve its E&S performance through the systematic control and management of the E&S risks associated with the Obligors’ operations giving Investors comfort with respect to compliance with the ESMS Programme.
International Finance Corporation (IFC)
Scipion’s internal actions and investment practices are guided by the International Finance Corporation’s (the IFC) eight Performance Standards as an international benchmark for identifying and managing environmental and social risk. Scipion has adopted these standards as a key component of the Scipion’s environmental and social risk management which Obligors are to meet throughout the life of any form of investment and include IFC Performance Standard 2: Labour and Working Conditions.
IFC Performance Standard 2: Labour and Working Conditions requires focusing on ensuring the Fair treatment of workers, safe and healthy working conditions, refraining from child or forced labor, and identifying any risks the mitigation of which are fundamental to a successful workforce.
United Nations International Labour Organisation (UNILO)
As part of meeting requirement of certain Investors providing finance for Obligors, Scipion works closely with the UNILO, including observing compliance with the United Nation’s
Sustainable Development Goals (SDGs).
Scipion conducts all of its business in close compliance of the United Nations’ SDGs, to the extent applicable. This helps to assess the suitability of any Obligors and their compliance with Scipion’s principles. In addition, Scipion proactively creates business opportunities to address specific Sustainable Development Goals as the objective.
United Nations SDG 8 addresses Decent Work and Economic Growth.
Current action
The Scipion Group aim to take the following further steps over the course of the next financial year ending June 2025:
• To continue performing due diligence checks on existing Obligors;
• To expand to the extent possible the number of investors providing finance on an ESI basis, encompassing IFC and SDG standard relating to labour;
• To continue the implementation of the ESMS Programme to continue to improve E&S Performance of underlying Obligors and the Scipion Group’s own implementation of the ESMS Programme; and
• Run refresher training to ensure that relevant staff are up to speed with the latest on modern slavery and embed as part of induction processes.
This statement has been revised and approved in its revised form by the Board of Directors of SCUKL for the period from March 2025 to the conclusion of the financial year ending 31 June 2025.This statement will be reviewed and updated every year.