Modern Slavery and Human Trafficking Statement

Last Updated: 24 April 2025

  1. Introduction

    Nocturnal Capital Partners maintains a zero-tolerance approach to modern slavery and human trafficking across our global operations and investment portfolio. This statement outlines our comprehensive framework for identifying, assessing, and addressing modern slavery risks in accordance with international standards including the UN Guiding Principles on Business and Human Rights.

  2. Organisational Structure and Scale

    Nocturnal Capital Partners operates as a global private equity platform with investments across Europe and strategic partnerships worldwide. Our business encompasses:

    • A diversified portfolio of companies across multiple sectors and jurisdictions

    • An extensive network of service providers and supply chain partners

    • Operations in both developed and emerging markets

  3. Comprehensive Risk Management Framework

    3.1 Global Supply Chain Oversight

    We maintain systematic monitoring of our extended supply chain through:

    • Centralised supplier due diligence and onboarding protocols

    • Regular risk assessments across all operational geographies

    • Sector-specific vulnerability analysis for high-risk industries

    3.2 Investment Integration

    Our ESG integration framework mandates:

    • Pre-acquisition human rights due diligence for all potential investments

    • Portfolio company compliance with our Anti-Slavery and Human Trafficking Policy

    • Annual audits of material labour practices across the portfolio

    • Board-level oversight of human rights performance

  4. Governance and Accountability

    4.1 Executive Oversight

    Our Anti-Slavery Steering Committee, comprising senior partners and legal counsel, meets quarterly to review risks and compliance.

    4.2 Policy Framework

    We maintain several interlocking policies:

    • Global Anti-Slavery and Human Trafficking Policy

    • Supplier Code of Conduct with mandatory compliance

    • Whistleblower Protection Policy with multi-language support

    • ESG Integration Standards for all investment activities

  5. Training and Capacity Building

    We invest significantly in awareness and capability development:

    • Mandatory modern slavery training for all employees

    • Specialized training for procurement and investment teams

    • Portfolio company executive education programs

    • Supplier workshops in high-risk jurisdictions

  6. Monitoring, Reporting and Continuous Improvement

    Our approach includes:

    • Annual modern slavery risk assessments

    • Independent third-party audits of high-risk operations

    • Portfolio company reporting against key performance indicators

    • Regular benchmarking against industry best practices

  7. Future Commitments

    In the coming years, we will enhance our program through:

    • Expansion of our supplier monitoring technology platform

    • Development of sector-specific risk assessment tools

    • Increased engagement with industry initiatives on human rights

    • Enhanced due diligence for emerging market investments

  8. Contact

    For questions regarding our modern slavery approach or to report concerns, please contact us:

    compliance@nocturnalpe.com

This statement is made pursuant to our commitment to international human rights standards and reflects our comprehensive approach to eradicating modern slavery from our operations and value chain.