Effective Date: January 2026
Policy Owner: Chief Operating Officer
Review Cycle: Annual
Croze Ventures maintains absolute commitment to ethical business conduct and human rights protection across all operations and relationships. We oppose slavery, servitude, forced labour, and human trafficking in all forms.
This Modern Slavery Statement establishes our commitment to preventing modern slavery in our operations and supply chains.
We operate in compliance with:
UK Modern Slavery Act 2015
Swiss Child Labour Law 2022
Brazilian Consolidation of Labour Laws (CLT) and constitutional prohibition of slave labour
Croze Ventures serves families who built wealth through enterprise and integrity. We protect that legacy through uncompromising ethical standards.
This policy applies to:
All Croze Ventures employees across Basel, London and São Paulo offices
All service providers, vendors and business partners
Investment due diligence and portfolio monitoring processes
Trust and entity administration activities
While Croze Ventures does not manufacture products or maintain complex supply chains, we recognize our responsibility to ensure our business relationships meet ethical labour standards.
Accountability:
Chief Operating Officer: Overall policy ownership and compliance oversight
Office Managing Directors: Local implementation in Basel, London and São Paulo
Compliance Officer: Monitoring, training and reporting
Investment Team: Due diligence integration for portfolio companies
Reporting:
The COO provides annual Modern Slavery Statement to the Board of Directors, published on the Croze Ventures website within six months of financial year-end.
Croze Ventures conducts annual risk assessments to identify potential modern slavery risks in:
Operations:
Employment practices across three jurisdictions
Office facilities and building services
Technology providers and data processors
Business Relationships:
Fund administrators and custodians
Legal and accounting firms
IT service providers and consultants
Office services (cleaning, security, catering)
Investment Portfolio:
Direct investments in operating businesses
Portfolio companies in high-risk sectors (agriculture, manufacturing, construction, hospitality)
Investments in jurisdictions with elevated modern slavery risks
Supply chain practices of underlying holdings
High-Risk Indicators:
Croze Ventures maintains heightened scrutiny for:
Labour-intensive industries
Operations in countries with weak labour law enforcement
Use of subcontractors and temporary labour
Migrant worker employment
Complex, multi-tier supply chains
5. Due Diligence Processes
Vendor Onboarding:
All new service providers undergo modern slavery screening:
Written confirmation of anti-slavery policies and compliance
Review of labour practices and employment standards
Assessment of subcontractor oversight procedures
Evaluation of modern slavery training programs
Site visits for material operational vendors
Contract Requirements:
Croze Ventures contracts include:
Explicit prohibition of modern slavery, child labour and human trafficking
Requirement to comply with applicable anti-slavery laws
Right to audit labour practices and employment records
Obligation to report suspected violations immediately
Termination rights for non-compliance
Investment Due Diligence:
ESG due diligence for investments includes:
Review of labour policies and employment practices
Assessment of supply chain transparency and oversight
Evaluation of human rights policies and grievance mechanisms
Third-party ESG research on modern slavery controversies
Management interviews on labour practices
Ongoing Monitoring:
Croze Ventures conducts:
Annual vendor compliance confirmations
Periodic audits of high-risk service providers
Continuous monitoring of portfolio company controversies
Review of modern slavery disclosure statements from fund managers
Investigation of any allegations or concerns
Modern slavery considerations integrate into investment decisions:
Exclusions:
Companies with confirmed modern slavery violations without adequate remediation
Investments in sectors with systemic forced labour concerns without robust mitigation
Engagement:
Active dialogue with portfolio companies on labour practices
Support for improved supply chain transparency and monitoring
Escalation to divestment when engagement fails
Manager Expectations:
Fund managers must demonstrate modern slavery risk assessment
Preference for managers with strong labour rights policies
Review of manager proxy voting on human rights issues
Croze Ventures provides modern slavery training to build organizational capability:
Employee Training:
Annual anti-slavery training for all employees
Specialized training for procurement and vendor management staff
Investment team training on labour rights due diligence
Country-specific training reflecting Basel, London and São Paulo contexts
Training Content:
Modern slavery definitions and forms
Risk indicators and warning signs
Reporting procedures and escalation protocols
Legal obligations under UK, Swiss and Brazilian law
Case studies and practical scenarios
Third-Party Awareness:
Communication of policy to all vendors and service providers
Expectation that partners implement their own anti-slavery measures
Resources and guidance for supplier compliance
Internal Reporting:
Croze Ventures maintains confidential channels for reporting concerns:
Direct reporting to Compliance Officer or COO
Anonymous whistleblower hotline (third-party managed)
Email reporting mechanism
Protection against retaliation for good-faith reports
Investigation Process:
All reports receive prompt investigation:
Initial assessment within 48 hours
Fact-gathering and evidence collection
Interview of relevant parties
Determination and remediation plan
Documentation and reporting to Board
Victim Support:
If modern slavery is identified:
Immediate steps to protect affected individuals
Coordination with law enforcement authorities
Access to support services and legal assistance
Remediation and prevention measures
Croze Ventures tracks modern slavery prevention through:
Coverage: Percentage of vendors with modern slavery contractual terms (Target: 100%)
Training: Percentage of employees completing annual training (Target: 100%)
Assessment: Number of high-risk vendors audited annually
Due Diligence: Percentage of investment opportunities with labour rights assessment
Incidents: Number of modern slavery concerns reported and investigated
Response Time: Average investigation completion time frame
Annual KPI reporting to Board of Directors.
Incident Response:
When modern slavery is identified in operations or business relationships:
Immediate suspension of relationship pending investigation
Cooperation with law enforcement and regulatory authorities
Support for affected individuals
Corrective action plan with defined timeline
Enhanced monitoring or relationship termination
Root cause analysis and preventive measures
Continuous Improvement:
Croze Ventures commits to ongoing enhancement:
Annual policy review incorporating regulatory developments
Evaluation of due diligence effectiveness
Adoption of industry best practices
Participation in anti-slavery initiatives and knowledge-sharing
Investment in screening tools and capabilities
United Kingdom (London Office):
Compliance with Modern Slavery Act 2015:
Annual modern slavery statement publication
Board-level approval of statement
Signature by Board director
Prominent website publication
Coverage of organization structure, policies, due diligence, risk assessment, effectiveness measurement and training
Switzerland (Basel Office):
Compliance with Swiss responsible business conduct requirements and Swiss Child Labour Law 2022:
Non-financial reporting on human rights impacts
Due diligence obligations regarding conflict minerals and child labour
Supply chain policy communication
Code of conduct integration with suppliers
Documentation of compliance management system
Brazil (São Paulo Office):
Compliance with Brazilian labour law:
Constitutional prohibition of slave labour (Article 149, Penal Code)
Ministry of Labour and Employment “Dirty List” screening
Labour inspection cooperation
Employee rights protection under CLT
Accountability:
Board of Directors: Ultimate oversight
Chief Operating Officer: Policy ownership and implementation
Office Managing Directors: Local execution and compliance
Compliance Officer: Monitoring, training, and reporting
Review and Amendment:
Annual policy review by COO and Compliance Officer
Updates to reflect legal changes and best practices
Material amendments require Board approval
Publication:
Policy available on Croze Ventures website
Modern Slavery Statement published annually
Distribution to all employees and material vendors
Policy Approval:
This Modern Slavery Statement has been approved by the Board of Directors of Croze Ventures.
Date: January 2026