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UK Modern Slavery Act Statement
February 2024
The Modern Slavery Act (“MSA”) was enacted by the UK Government in 2015 in an effort to confront all
forms of slavery, servitude, forced or compulsory labour and human trafficking. Section 54 of the MSA
requires commercial organisations of a certain size in the UK to prepare a slavery and human trafficking
statement for each financial year. In accordance with section 54 of the MSA, Starwood Capital Europe
Advisers, LLP (“Starwood Europe”) has prepared this statement for its most recent financial year ending
December 31, 2023.
Organisational Structure, Business and Supply Chains
Starwood Capital Group (“Starwood”) is a private investment firm with a primary focus on global realestate. Since its inception in 1991, the firm has invested in excess of $240 billion of assets, including
properties within every major real estate asset class.
Starwood’s activities in the UK are carried out by its local affiliates, including Starwood Europe, which isregulated by the Financial Conduct Authority. Starwood Europe provides advisory and certain otherservices to other Starwood sponsored vehicles, including its US affiliate Starwood Capital GroupManagement, L.L.C., a registered investment advisor with the Securities and Exchange Commission.
Policies
Starwood maintains an Environmental, Social and Governance (“ESG”) Policy that sets out the generalframework for the integration of ESG considerations into its corporate operating strategy and throughout
the lifecycle of its investments. As set out in the ESG Policy:▪

Starwood aims to integrate into its corporate operations ESG initiatives that support its growth,enhance its resilience, reduce its environmental impact, and positively contribute to the social andeconomic well-being of its employees and the communities in which it operates. In particular,
Starwood aims to observe fair labor practices and uphold internationally recognized human rights
principles across its business activities, including with respect to modern day slavery, and seeks toengage ethical and responsible business partners across its supply chain.

▪

Starwood believes that the thoughtful integration of financially material ESG factors throughout thelifecycle of its investments enhances its ability to manage risk, identify opportunities to create
financial value, and improve the long-term resilience of its investment portfolio. As such, Starwood
believes successful integration of material ESG factors is crucial to its ability to deliver results onbehalf of its investors and is consistent with its fiduciary duties and efforts to maximize risk-adjusted
returns. In particular, Starwood seeks to integrate consideration of factors including human rights,
labor standards, supply chain responsibility and procurement standards and requirements into its
investment processes, where those factors are financially material to a relevant investment.Starwood Europe applies the ESG Policy to its corporate operations and advisory services.
Further, Starwood Europe’s employment practices are in place to promote high and ethical standards that
foster safe, inclusive, and rewarding work environments for its employees. Starwood Europe’semployment practices are governed by its UK Employee Handbook and Compliance Manual, which
includes policies pertaining to diversity, equity and inclusion, harassment and discrimination, health &safety, flexible working, whistleblowing, employee personal data & privacy, and anti-bribery and anticorruption. Starwood Europe seeks to enhance hiring practices as appropriate.
Due Diligence Processes1
Starwood Europe seeks to undertake due diligence of its direct vendors and utilizes technology, humaninteraction and its due diligence procedures in furtherance of its goals. Starwood Europe’s vendor due
diligence framework generally involves the completion of a vendor intake questionnaire for certain newvendors that Starwood contracts with. This questionnaire enables Starwood Europe to assess reputational,
operational, transactional, compliance, financial, business continuity, cybersecurity, and country riskassociated with the vendor. Further, upon contracting with a vendor, Starwood Europe leverages a thirdparty service provider to monitor its largest direct vendors for material ESG risks.
Risk Assessment
Starwood Europe considers the risk of modern slavery and trafficking within its supply chain to be low as
determined through its vendor due diligence and monitoring process. A substantial number of its direct
suppliers and vendors are large or multinational professional and business services firms who provide
professional advisory services which support transactions and due diligence services associated therewith.
Starwood Europe seeks to develop relationships with suppliers and vendors who share similar values andconduct business in an ethical manner.
Performance Indicators
As of the date of this statement, Starwood Europe received no alerts of material vendor ESG risks from its
third-party service provider for the 2023 operating period.
Training
Starwood Europe seeks to provide training, manuals, and guidelines to Starwood Europe staff on certain
topics which may promote awareness of the MSA, in alignment with Starwood’s commitment to operate
ethically and in compliance with applicable law.
This statement was approved by the members of Starwood Capital Europe Advisers, LLP on __6__
February 2024.

The vendor due diligence and monitoring process described here is applicable to third-party vendors Starwood contracts with through its
accounts payable business functions in the UK, US, and Asia Pacific.
1

_______________________________________
Nick Antonopoulos, Chief Financial Officer
Designated Member

Date:

6 February 2024____