UK Modern Slavery Act Transparency Statement
Introduction
This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 (the “Modern Slavery Act”). It sets out the steps that we, Fortress Investment Group (UK) LTD ("FIG UK"), have taken to seek to ensure that modern slavery and human trafficking are not taking place in our business and supply chains during the most recently ended financial year, being December 31, 2023.
Organization’s Structure
FIG UK is a UK-based affiliate of Fortress Investment Group LLC (“Fortress”), a leading, highly diversified global investment manager with approximately $48billion of assets under management as of December 31, 2023. Fortress manages assets across a range of credit and real estate, fixed income & trading, lending, private equity, and permanent capital investment strategies. Fortress operates its business through FIG UK and other Fortress-affiliated investment advisers. FIG UK’s principal place of business is in London, and it is authorised and regulated by the Financial Conduct Authority in the UK. FIG UK primarily provides advisory services to an affiliated US registered investment adviser.
Supply Chain
As an investment advisory firm, we have relatively limited supply chains. Consequently, our assessment of the risk of modern slavery and human trafficking is based on the nature of our industry and the limited extent of our supply chains. In connection with our business activities, we engage external parties to provide support services such as office cleaning, catering and IT services. We also outsource some ancillary functions relating to our business to professional service firms, such as law firms, accounting/tax firms and recruitment firms.
We believe that the relative risk of exposure to modern slavery and human trafficking is low given the nature of the business undertaken by FIG UK’s supply chain. Notwithstanding the relatively low risk, we understand the importance of combatting modern slavery and human trafficking.
Policies and Procedures
In connection with our affiliation with Fortress, we are subject to a number of global measures as part of Fortress’s global commitment to the highest ethical standards of business conduct and to ensure compliance with applicable law and regulation. For example, all employees are required to comply with all policies and procedures set forth in the global Fortress Compliance Manual (which includes the Fortress Code of Ethics), the FIG UK Compliance Addendum and the Fortress Employee Handbook.
Further, we believe responsible investing involves incorporating Environmental, Social, and Governance (ESG) considerations in our investment decision making and asset management process. Please see https://www.fortress.com/responsibility for the Fortress Credit and Real Estate Funds ESG policy, which was adopted in 2019.
Due Diligence
FIG UK is committed to ensuring that modern slavery and human trafficking is not taking place in our business or our supply chains. We expect all of our suppliers, contractors, and other business partners to comply with the Modern Slavery Act and uphold the same high ethical standards as we do. We will not knowingly deal with, support, or purchase goods or services from anyone engaged in modern slavery or human trafficking. If at any point in time a higher risk of modern slavery or human trafficking is deemed to exist in our supply chain, we will promptly take appropriate measures. As necessary, we may perform due diligence on providers, which may include querying providers on whether they have relevant measures in place to prevent modern slavery and human trafficking in their business and whether they have had any allegations, fines, or warnings with respect to modern slavery and human trafficking. We will also work to identify any potential areas of risk in our supply chains based on the nature of the services being provided and the geographic location from where such services are being supplied.
Training and Communication
To the extent deemed appropriate, we will deliver targeted training to relevant personnel to educate them about the Modern Slavery Act in order to increase awareness of its requirements and enhance their ability to identify potential modern slavery and human trafficking within our supply chain.
Ongoing Review and Reporting
Our current whistleblowing policy establishes procedures for the submission of complaints by employees concerning known or suspected conduct that is potentially unethical or illegal.
If issues are identified in relation to modern slavery, these will be reviewed by our Legal and Compliance Department.
Board Approval
The Fortress Investment Group (UK) LTD Board of Directors approved this statement on June 30, 2024.
Signed on behalf of Fortress Investment Group (UK) LTD
Nick Fegan
Director, Fortress Investment Group (UK) LTD
June 30, 2024