Modern Slavery Disclosure
Slavery and Human Trafficking Statement 2024/25
For the financial year ending September 30, 2025
Northleaf Capital Partners opposes slavery and human trafficking in all its forms. This statement outlines our commitment to ethical trading principles and sets out the steps that we are taking to ensure that slavery and human trafficking is not taking place in our business or our supply chains. Northleaf acknowledges its responsibility under the Modern Slavery Act 2015 and will
take steps to ensure transparency within its own organization and with suppliers of goods and services with whom it contracts.
References in this statement to “Northleaf,” “we” and “our” are references to Northleaf Capital Partners and its subsidiaries. Northleaf Capital Partners® and Northleaf® are registered trademarks of Northleaf Capital Partners Ltd. All rights reserved.
Northleaf Overview
Northleaf is a global private markets asset manager with US$31 billion in private equity, private credit and infrastructure commitments raised to date. Northleaf’s clients include public, corporate and multi-employer pension plans, endowments, foundations, financial institutions and family offices.
Northleaf’s investment program dates back to 1969 and the formation of TD Capital Private Equity Investors (TD Capital), a proprietary investment arm of TD Bank Group (TD), to invest in private equity funds and direct co-investments on behalf of TD’s balance sheet. Northleaf’s current team, investment strategy and track record began in 2002 with the launch of TD Capital’s first global private equity fund for third-party institutional investors. Northleaf became an independent firm in 2009 with the successful spin-out of TD Capital’s entire team, track record and global investment program. Northleaf launched its infrastructure program in 2010 and its private credit program in 2016. In 2020, Northleaf entered into a strategic partnership with Mackenzie Financial Corporation (Mackenzie) and Great-West Lifeco Inc. (Lifeco), members of the Power Corporation of Canada group of companies, whereby Mackenzie and Lifeco jointly acquired a voting and an economic interest in Northleaf.
The Northleaf team, with more than 300 employees across its ten offices in North America, the United Kingdom, Asia and Australia, is focused predominantly on sourcing, evaluating and across a range of global private markets investment strategies and a series of customized investment mandates tailored to meet the specific needs of institutional investors and family offices.
Northleaf’s Supply Chain
As a private markets asset manager, Northleaf’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 services). We regard the providers of our professional services and business supplies generally as presenting particularly low risk. We believe, therefore, that there is a low overall risk of slavery or human trafficking in connection with our business and supply chain. We expect all of our direct suppliers and investee companies/entities to conduct their own businesses in a manner which is both lawful and ethical, including adopting good business practices that prevent and eliminate modern slavery and human trafficking.
Northleaf’s Policies and Procedures
Investment Policies
We are committed to acting ethically and with integrity in all our business dealings. As outlined in our Mission Statement, since our founding, Northleaf has sought to align our interests with those of our investors, investment partners and employees. This alignment has allowed us to build and maintain a culture of ethical behaviour, transparency and social responsibility in both our
investment process and our operations.
To formalize this commitment, Northleaf has adopted a Responsible Investment Policy which applies across all investment activities firm wide. Northleaf believes that responsible corporate behaviour will have a positive influence on long-term financial performance and is committed to incorporating environmental, social and governance (ESG) factors into its investment processes at every level.
Northleaf’s Responsible Investment Policy has been developed having regard to a number of leading frameworks including those published by the Principles for Responsible Investment (PRI), the Task Force on Climate Related Financial Disclosures (TCFD), the Institutional Limited Partners Association (ILPA) and the Division for Sustainable Development Goals (DSDG) in the United Nations Department of Economic and Social Affairs (UNDESA). The Policy has also
been developed in accordance with the Ten Principles of the United Nations Global Compact, UN Guiding Principles on Business and Human Rights and OECD Guidelines for Multinational Enterprises (including the guideline Responsible Business Conduct for Institutional Investors).
Northleaf is a signatory to the Principles for Responsible Investment (PRI), which include commitments on social issues such as human rights, working conditions and modern slavery. Northleaf is committed to upholding the values of PRI and applying its principles across all of our investment activities firm wide. This includes seeking appropriate disclosures on working conditions and modern slavery from the entities in which we invest.
Northleaf evaluates ESG considerations at all stages of the investment process, from initial review and due diligence to post-investment monitoring, and works with our investment partners to understand, and even formalize, their own policies. After an investment is made, we continue to monitor for ESG matters to ensure our investors’ interests are protected.
Other Key Policies
Northleaf’s Code of Ethics and Conduct (the “Code”) clearly states that all employees are responsible for complying with the Code and reporting violations and suspected violations. Northleaf encourages a culture of openness and accountability. This Code ensures that our staff
can raise any concerns they have (including about slavery or human trafficking) confidentially with the comfort of knowing that such concerns will be dealt with appropriately and that staff will be protected from any reprisals for having disclosed their concerns.
We also adhere to all applicable employment laws relating to our employees’ terms and conditions, including pay, and all of our employees are paid at least any applicable minimum wage.
This statement is published pursuant to section 54(1) of the Modern Slavery Act 2015 on behalf of Northleaf Capital Partners and its subsidiaries for the financial year ending September 30, 2025.
Signed by:
“Jeffrey E. Pentland”, Managing Director & Chair of Northleaf’s Responsible Investment Committee
Date: March 6, 2026
