Financial Year Ended 31 March 2023
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 our responsibility under the Modern Slavery Act 2015 (the “Act” or “MSA”) and will take steps to seek to ensure transparency within our own organisation and with suppliers of goods and services with whom we contract.
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
We are a global private markets investment solutions provider with approximately $112 billion of assets under management (“AUM”), and approximately $745 billion of assets under advisement (“AUA”) as of March 31, 2023. We work with our clients to conceive, structure, build out, manage and monitor portfolios of private markets funds and direct investments, and we help them access a diversified set of such investment opportunities worldwide. Our clients are principally large, sophisticated, global investors that rely on our private markets expertise, deep industry relationships, differentiated investment access, risk management capabilities, proprietary data advantages and analytical tools to navigate the increasing complexity and opacity of private markets investing. While some maintain their own internal investment teams, our clients look to us for additional expertise, advice, and outsourcing capabilities. In addition to our institutional client base, we have a growing number of non-institutional clients stemming from the private wealth channel, which includes family offices and high-net-worth individuals, who utilize our products and services to gain access to the private markets.
We were founded in 1991 and have been dedicated to private markets investing for over three decades. We currently have over 600 employees, including 204 investment professionals, operating across 22 global offices servicing our clients throughout the world.
We offer a variety of investment solutions to address our clients’ needs across a range of private markets, including private equity, private credit, real estate, infrastructure, natural resources, growth equity, venture capital and impact. These solutions are constructed from a range of investment types, including primary investments in funds managed by third-party managers, direct investments alongside such funds and acquisitions of secondary stakes in such funds, with a number of our clients utilizing multiple investment types. These solutions are offered in a variety of formats covering some or all phases of private markets investment programs:
- Customized Separate Accounts: We design and build customized portfolios of private markets funds and direct investments to meet our clients’ specific portfolio objectives with regard to return, risk tolerance, diversification and liquidity. We generally have discretionary investment authority over our customized separate accounts, which comprised approximately $85 billion of our AUM as of March 31, 2023.
- Specialized Funds: We organize, invest and manage specialized primary, secondary and direct investment funds. Our specialized funds invest across a variety of private markets and include equity, equity-linked and credit funds offered on standard terms, as well as shorter duration, opportunistically oriented funds. We launched our first specialized fund in 1997. Since then, our product offerings have grown steadily and now include evergreen offerings that primarily invest in secondaries and direct investments in equity and credit and are available to certain high-net-worth individuals. Specialized funds comprised approximately $27 billion of our AUM as of March 31, 2023.
- Advisory Services: We offer investment advisory services to assist clients in developing and implementing their private markets investment programs. Our investment advisory services include asset allocation, strategic plan creation, development of investment policies and guidelines, the screening and recommending of investments, the monitoring of and reporting on investments and investment manager review and due diligence. Our advisory clients include some of the largest and most sophisticated private markets investors in the world. We had approximately $745 billion of AUA as of March 31, 2023.
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
- Our Responsible Investment Committee, which provides oversight on the implementation of ESG policies at Hamilton Lane.
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 2022 and ending 31st March 2023.