Financial Year Ended 31 March 2021

Introduction

Hamilton Lane is committed to ensuring that acts of human trafficking and modern slavery form no part of  its  business  or  supply  chains.  Hamilton  Lane  acknowledges  its  responsibility  under  the  Modern  Slavery Act 2015 (the “Act” or “MSA”) and will take steps to seek to ensure transparency within its own organisation and with suppliers of goods and services with whom it contracts.

References  in  this  statement  to  “Hamilton  Lane,”  “we”  and  “our”  are  references  to Hamilton  Lane  Advisors, L.L.C. and its subsidiaries.

Hamilton Lane Overview

Hamilton Lane was founded in 1991 in Philadelphia, Pennsylvania as a private equity advisory firm for large public pension plans. We focused almost exclusively on advisory mandates until 1998, when we gained our first separate account client and launched our first fund-of-funds. Since that time, we have expanded into managing discretionary private markets plans for institutional investors globally, through both separately managed accounts and commingled funds.

Hamilton  Lane  is  a  recognized  leader  in  alternative  asset  management,  serving  some  of  the  most  sophisticated clients across the globe. As of 31st March 2022, we employ approximately 530 employees and  operate  across  20  global  offices  with  approximately  $106.4 billion  in  discretionary  assets  under  management and oversight of an additional $794.7 billion in advisory assets. We provide a wide array of discretionary and non-discretionary services tailored to address the needs of our clients, including strategic  portfolio  planning,  due  diligence,  legal,  monitoring  and  reporting,  board  presentations,  performance analysis and benchmarking.

Hamilton  Lane’s  clients  are  principally  institutional  investors  and  financial  institutions  who manage pension funds, endowments, foundations, and other large investment portfolios in markets across the globe.

Hamilton Lane’s Key Policies

Hamilton  Lane  has  adopted  other  relevant  policies  and  procedures,  which  reinforce  the  firm’s  fundamental values, including:

  • A Code of Ethics Policy, which describes the standards of behaviour expected from Hamilton Lane’s employees. All employees are required to certify that they have read and understood all of the provisions of our Code of Ethics;
  • A Whistleblowing Policy for the reporting of suspicious and illegal activity;
  • A Hiring Policy, which provides that recruitment of employees, is by written agreement in accordance with local employment law; and
  • The  ESG Committee focuses on the implementation of responsible investing and social responsibility policies at Hamilton Lane, is responsible for  our governance regarding these matters.  

Hamilton Lane’s Supply Chain

Hamilton  Lane’s  supply  chain  is  relatively  short  and  consists  predominantly  of  the  purchase  of  professional services (such as lawyers, accountants and other consultants) and business supplies (such as IT providers, office equipment, office maintenance/cleaning services and travel services).

We regard providers of professional advice generally as presenting particularly low risk and believe that there is a low overall risk of slavery or human trafficking in connection with our business and supply chain.

However, while we believe that our business and supply chain present particularly low risk there may be a higher risk deeper in the supply chains of our suppliers, of which we have limited visibility. The focus of our response is therefore on understanding the policies and procedures in place.

Hamilton Lane’s Policy on Modern Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or our supply chains. We are also committed to acting ethically and with integrity in all our business relationships and for this purpose, we regularly review the systems and controls we have in place to ensure that the risk of modern slavery and human trafficking in our business and supply chains is eliminated to the maximum possible extent.

Hamilton Lane’s Risk Assessment and Mitigation of Supply Chain Risk

We undertake the following steps as part of our efforts to eliminate slavery and human trafficking:

  • Conduct due diligence and monitoring of suppliers; 
  • Include standard questions and representations relating to MSA concerns in requests for proposal from prospective suppliers;
  • Continue to educate employees on MSA requirements by providing training for the relevant employees; and
  • Communicate with suppliers and employees to ensure they understand our obligations and expectations.

This statement is made in accordance with Section 54 (1) of the Modern Slavery Act 2015 of the United Kingdom  and constitutes Hamilton Lane’s modern slavery and trafficking statement for the financial year commencing 1st April 2021 and ending 31st March 2022.  

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