Modern Slavery and Human Trafficking Statement

For the Financial Year Ending 31 December 2025

This statement is made pursuant to section 54(1) of the UK Modern Slavery Act 2015 and sets out the steps taken by Asterion Industrial Partners, SGEIC, S.A. through its UK Permanent Establishment (PE), during the financial year ending 31 December 2025 to ensure that modern slavery and human trafficking is not taking place in its business or supply chains.

1. What is Modern Slavery?

According to the UK’s Home Office Statutory Guidance in relation to Transparency in Supply Chains, modern slavery refers to situations of exploitation that a person cannot refuse or leave because of threats, violence, coercion, deception, and/or abuse of power. Modern slavery is a crime resulting in abhorrent abuse of human rights. It is constituted in the Modern Slavery Act 2015 by the offences of slavery, servitude and forced or compulsory labour and human trafficking.

2. Asterion’s Commitment

We are committed to preventing modern slavery and human trafficking in all areas of our business and supply chains. We uphold the principles of the Modern Slavery Act 2015 and expect the same standards from our suppliers and business partners.

3. Structure and Business

Asterion Industrial Partners SGEIC, S.A. is a company headquartered in Madrid, Spain with a presence in the UK through its UK Permanent Establishment and UK office located at 17 Grosvenor Gardens, London SW1W 0BD. Both Asterion and the UK PE operate in the finance industry.

Asterion manages three flagship funds as well as several coinvestment funds that all focus on infrastructure investments in the European mid-market. As of 31 December 2025, Asterion relies on nearly 70 professionals to operate.

As of 31 December 2025, the Asterion funds hold portfolio companies headquartered in Europe in the infrastructure space.

4. Supply Chain

Asterion’s supply chain primarily comprises professional and business services providers based in Europe, including legal advisors, financial consultants, IT service providers, and other firms supporting transaction execution and investment management. In addition, Asterion engages a limited number of vendors for operational support, such as office services, travel, facilities management, and catering.

5. Policies and Governance

We have implemented internal policies to mitigate the risk of modern slavery, including:

  • Vendor Selection Policy, which outlines Asterion’s vendor selection process including, as part of the selection criteria, the requirement to meet minimum ethical, environmental, social and governance standards, including respect for human rights and labour rights.
  • Internal Information and Informant Protection Procedure, which is one of the key elements for supervision, control and prevention in the area of regulatory compliance and internal conduct, enabling anonymous reporting of unethical behavior.
  • Human Resources Policy, which includes Asterion commitment to provide a favorable environment that facilitates equal opportunity, non-discrimination, diversity and inclusion, and prevent harassment.
  • Responsible Investment Policy, which outlines Asterion’s commitment to integrate a responsible approach to the investment process and the management of its operations through the consideration of environmental, social and governance (ESG) factors.
  • Criminal Prevention Policy, which includes Asterion’s commitment to undergoing business in compliance with the highest ethical standards including with respect to matters such as bribery and corruption.

Oversight is provided by the Compliance Officer based in Madrid, Spain.

6. Due Diligence

We carry out risk-based due diligence on key suppliers, contractors, and business partners, modulated depending on the level of risk, frequency of use and volume of services. For low-risk suppliers, we use a combination of reliance on their regulatory status and reputation and strive to include appropriate contractual undertakings relating to these matters in their engagement letters. For medium or higher risk suppliers, our diligence combines:

  • Supplier self-assessment questionnaires
  • Contractual obligations requiring compliance with anti-slavery laws
  • Ongoing monitoring and audit rights

7. Asterion Funds Portfolio Companies

Our fund portfolio companies do not fall under Asterion’s supply chain and it is the responsibility of each such portfolio company to comply with its obligations under applicable law and regulations.

Asterion integrates sustainability and human rights considerations into its investment processes, from due diligence through to ownership and exit. In line with our Responsible Investment Policy, we assess material ESG risks and opportunities at portfolio company level, excluding companies that violate human rights related issues including human right abuses, modern slavery, fair living wage and child labour, among others.

Our Investment Committee and ESG governance framework oversee the implementation of these standards. Where relevant, we support portfolio companies in strengthening their approach to labour conditions, supply chain oversight, and whistleblowing mechanisms.

While portfolio companies are responsible for their own compliance, Asterion engages actively to promote high standards of ethical and responsible business conduct across its portfolio.

8. Training

Asterion is committed to raising awareness among employees about the risks of modern slavery and human trafficking. Human rights considerations, including modern slavery, are embedded within our investment processes and reflected in several of our internal policies, as mentioned above.

All Asterion employees receive training on the Firm’s culture, values, and internal policies as part of their onboarding process, with periodic refresher sessions thereafter. In addition, guidance related to the UK Modern Slavery Act is provided to relevant staff to support awareness and compliance.

This ensures awareness and vigilance throughout our operations.

9. Effectiveness and KPIs

To measure the effectiveness of our efforts, we monitor:

  • Reports or incidents of modern slavery
  • Supplier non-compliance issues

No instances of modern slavery were reported in the year ending December 31, 2025.

10. Approval and Signature

This statement has been approved by the board of directors of Asterion Industrial Partners SGEIC, S.A. and by the UK management of the Permanent Establishment and is signed on its behalf by:

Arranzazu Mardía, Authorized Signatory of Asterion Industrial Partner, SGEIC, S.A. UK Permanent Establishment.