I.   Introduction

StepStone Group Inc. and its consolidated subsidiaries (“StepStone”, “we”, “us”, “our”) seek to integrate responsible business across all aspects of how we conduct our business, including our operations and supply chains, and investments we advise on or manage for or on behalf of our clients.

This Modern Slavery and Human Trafficking Statement (the “Statement”) sets out StepStone’s approach to combatting modern slavery and human trafficking as required by the United Kingdom Modern Slavery Act of 2015, the Australian Modern Slavery Act 2018 (Cth) and similar legislation enacted in other applicable jurisdictions.

StepStone’s position of not tolerating modern slavery and human trafficking is in alignment with our core belief that people matter. This belief guides how we run our operations, train and treat our employees, and how we work with our clients and vendors.

This Statement is being made by StepStone Group Inc., a Delaware corporation which has been listed on Nasdaq since 2020, on behalf of itself as the reporting entity and with reference to its consolidated subsidiaries, which include StepStone Group LP, a Delaware limited partnership, StepStone Europe Limited, a private limited company incorporated under the laws of England and Wales, StepStone Group Europe LLP, a limited liability partnership organized under the Limited Liability Partnerships Act 2000 of the United Kingdom, StepStone Group Real Assets LP, a Delaware limited partnership, StepStone Group Real Estate LP, a Delaware limited partnership, StepStone Group Private Debt AG (formerly Swiss Capital Alternative Investments AG), a Swiss company limited by shares, StepStone Group Europe Alternative Investments Limited, an Irish private company limited by shares, StepStone Group Private Wealth LLC (formerly StepStone Conversus LLC), a Delaware limited liability company, and StepStone Group Private Debt LLC, a Delaware limited liability company.

In preparing this Statement, directors, officers, partners and relevant responsible investment-focused professionals of StepStone Group Inc. and relevant subsidiaries were consulted in relation to the risks of modern slavery practices in their operations and supply chains and the actions taken to assess and address those risks, and provided with an opportunity to review and provide input prior to the formal approval process taking place.

II.   Overview of StepStone’s Organization

We are a global private markets investment firm focused on providing customized investment solutions and advisory, data and administrative services to our clients. Our clients include some of the world’s largest public and private defined benefit and defined contribution pension funds, sovereign wealth funds and insurance companies, as well as prominent endowments, foundations, family offices and private wealth clients, including high-net-worth and mass affluent individuals. We partner with our clients to develop and build private markets portfolios designed to meet their specific objectives across the private equity, infrastructure, private debt and real estate asset classes. These portfolios utilize several types of synergistic investment strategies with third-party fund managers, including commitments to funds, acquiring stakes in existing funds on the secondary market and investing directly into companies.

We are headquartered in New York, had approximately 980 employees as of March 31, 2024, and have investment and implementation professionals in 16 countries, including the United Kingdom and Australia. StepStone Group Europe LLP has its registered office in London, United Kingdom. StepStone Group LP has its Australian registered office in Warriewood, New South Wales.

III.     Risks of Modern Slavery Practices in StepStone’s Operations, Supply Chain and Investments

StepStone has evaluated how its operations, supply chains and investments may be exposed to modern slavery and human trafficking, and the level of such exposure.

StepStone recognizes that there is a risk that modern slavery practices exist in StepStone’s operations, supply chain and investments. This may include risks in our supply chain, particularly in relation to cleaning, catering and information technology procurement, and risks in our investment or advisory portfolios, particularly in relation to certain sectors (construction, agriculture and extractives) and emerging markets geographies in which we are invested, which represent a higher risk from a modern slavery perspective.

We remain committed to addressing these risks, through the steps which are set out below.

We have reviewed and assessed our operations and supply chain looking to identify material risk exposure, and concluded that due to the nature of our business, we believe modern slavery risks are low with respect to our operations and supply chain.

IV.   Policies and Practices in Relation to Slavery and Human Trafficking

We are committed to ensuring, to the extent practicable, that modern slavery and human trafficking are not taking place in our organization or supply chains and we have integrated considerations on modern slavery and human trafficking risks within the evaluation and management of investments on behalf of ourselves and our clients.

StepStone has a Code of Ethics, which describes the standards of behavior expected of our employees, including the maintenance of high ethical standards. Our Global Compliance Manual contains a whistleblower policy relating to the reporting and investigation of any improper or illegal activity, and we strictly prohibit any retaliation, unfavorable or adverse employment consequences, and any form of harassment against whistleblowers. The Global Compliance Manual also includes a complaint procedure which provides a framework for the handling of any complaints received from clients. The Code of Ethics and Global Compliance Manual are reviewed and updated annually.

StepStone is dedicated to promoting an atmosphere of diversity and equal opportunity, and our employee and partner handbooks prohibit discrimination and harassment against individuals based on their actual or perceived race, religious creed, color, national origin, ancestry, physical or mental disability, medical condition, genetic information, marital status (including registered domestic partnership status), sex (including gender identity and expression), age, sexual orientation, military and veteran status, or any other characteristic protected by law.

Responsible investing is a core tenet of StepStone’s investment philosophies. We believe that integrating environmental, social and governance (“ESG”) factors into our investment processes will improve long-term, risk-adjusted returns for our clients. This includes pre-investment screening and diligence of all material ESG risks and opportunities (including modern slavery and human trafficking) as well as post-investment active monitoring and engagement. We became a signatory to the United Nations Principles for Responsible Investment and created a StepStone Responsible Investment Committee (formerly known as ESG Committee) in 2017, and, subsequently, to The Task Force on Climate-related Financial Disclosure (prior to when it was disbanded in 2023), ESG Data Convergence Initiative, ILPA Diversity in Action Initiative, as well as a member of the Global Real Estate Sustainability Benchmark, the IFRS Sustainability Alliance, Invest Europe, Pensions for Purpose, Global Real Estate Benchmark, Initiative Climate International, and Institutional Investors Group on Climate Change. In addition, we became a partner of Ownership Works and VentureESG in 2022. For the fiscal year ended March 31, 2024, our Head of Responsible Investment joined the ESG Data Convergence Initiative’s Steering Committee and began serving as co-chair of the United Nations Principles for Responsible Investment’s Private Equity Advisory Committee.       

StepStone has a Responsible Investment Policy, a Climate Policy, and a Stewardship Policy. The aim of these policies is to promote the consideration of ESG factors in its investment processes. These policies are approved by StepStone’s Executive Committee, enforced by the relevant investment committees, and are applied globally across all of StepStone’s asset classes and investment strategies. StepStone has a Responsible Investment Committee composed of senior employees across all asset classes, functions and regions. This committee is supported by five Responsible Investment Workgroups. In this manner, firm-wide coordination and consultation on ESG, including with respect to modern slavery and human trafficking matters, occurs among StepStone’s consolidated subsidiaries.

V.   StepStone’s Supply Chain

StepStone’s supply chain predominantly comprises professional service providers such as lawyers, tax consultants, accountants, and administrators, or business vendors such as information technology service providers and suppliers of office equipment. Given the nature of StepStone’s business as a global private markets investment firm, we believe our supply chain is low risk in respect of modern slavery and human trafficking.

Nevertheless, StepStone conducts due diligence on its supply chain and continually seeks to improve its vendor and service provider due diligence processes, including by inquiring with respect to modern slavery and human trafficking. We query providers on whether they have a Modern Slavery statement, and if so, ask them to provide a copy; whether they use, and have relevant due diligence measures in place to prevent the use of, child labor, forced labor or human trafficking; and whether they have had any allegations, fines or warnings with respect to modern slavery, forced labor, child labor and human trafficking.

Should any instances of modern slavery be identified, we expect to take steps to work with our suppliers and vendors to remediate any issues, which may include termination of such relationship.

VI.   Employees, Recruitment and Training

We follow local labor laws and practices, and due to the nature of our business and our employees, we believe modern slavery risks are low with respect to our hiring of employees and overall operations. StepStone provides training to employees across the firm on modern slavery and human trafficking. StepStone seeks to ensure that employees are trained to identify, and know how to report and escalate, potential exposures relating to internal operations, supply chains or investments.

VII.     Due Diligence in the Investment Process

StepStone’s direct co-investments are primarily minority, non-controlling investments in operating companies alongside a lead sponsor who generally has voting control over the company. In addition to co-investments, StepStone directly invests in select privately held companies following an assessment of the company’s commitment to, among other things, ESG principles. While StepStone’s direct investments are primarily minority, non-controlling investments, StepStone occasionally appoints directors to serve on company boards. StepStone’s primary investments are investments in newly established private market funds which have not yet begun operation. Primary investments are made during an initial fundraising period in the form of capital commitments, which are then called down by the fund and utilized to finance investments in portfolio companies during a predefined period. We recognize the role we play in investing, or advising with respect to investments, in companies that are compliant with modern slavery and human trafficking legislation and regulations.

StepStone includes specific questions regarding modern slavery and human trafficking in its due diligence questionnaires in respect of potential investments (both fund and asset specific) being evaluated, and each investment memo presented to the relevant investment committee must contain a section dedicated to addressing responsible investment. An investment may be vetoed by the investment committee based on ESG grounds. Post-investment, StepStone implements ongoing monitoring for responsible investment matters and seeks to be engaged on ESG matters where it has a board seat or limited partner advisory committee membership. We also seek engagement with investment managers to advocate for and support their ESG process improvements.

VIII.     Effectiveness of Steps Being Taken

The ways in which we measure effectiveness of the actions we take to assess and address modern slavery risk include the following:

  • As noted in section V, employees are trained to identify and support potential exposures to modern slavery. We measure the frequency of these training sessions over time to assess the effectiveness of our awareness-raising activities. In the fiscal year that ended March 31, 2021, we conducted nine training sessions in respect of ESG and responsible investment, which among other things, covered modern slavery and human trafficking, for both investment team members, client-facing team members, and partners. In each of the fiscal years that ended March 31, 2022, and March 31, 2023, we conducted an additional eight trainings covering modern slavery and human trafficking, including firm-wide trainings and trainings specific to investment team members, client and vendor facing team members, and partners. During the fiscal year ended March 31, 2024, we conducted twelve additional training sessions in respect of ESG and responsible investment, six of which explicitly covered, among other things, modern slavery and human rights. Participants in these training sessions included investment team members, client-facing team members, responsible investment-focused professionals, and partners of the firm.
  • We evaluate the effectiveness of our policies and procedures in combating modern slavery and human trafficking by continually evaluating our due diligence process. In addition, we monitor our vendors, investors, and investments for any issues that may be connected to Modern Slavery and seek to understand how any such issue can be addressed and remedied.

IX.   Other

This Statement was prepared pursuant to Section 54(1) of the United Kingdom Modern Slavery Act of 2015 and s 13 of the Australian Modern Slavery Act 2018 (Cth) for the most recent fiscal year that ended March 31, 2024. The board of directors of StepStone Group Inc. approved this annual statement as of May 21, 2024.

STEPSTONE GROUP INC.

/s/ Monte Brem

      Name: Monte Brem

      Title: Chairperson of the Board of Directors

/s/ Scott Hart

      Name: Scott Hart

      Title: CEO and Director