Modern Slavery Act 2015 Statement

Statement pursuant to section 54 of the Modern Slavery Act 2015 of [Kirkoswald Capital Services (UK) Limited, Kirkoswald Asset Management Limited and Kirkoswald Capital Partners LLP] (“Kirkoswald”) for the year ended 2022.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015. Kirkoswald does not tolerate any slavery or human trafficking practices within its business or within its supply chains.

Whilst it is acknowledged that risk factors are present in all global supply chains and across all sectors, Kirkoswald considers that there is a relatively low risk of slavery, human trafficking and forced labour occurring within its business as a regulated, investment advisor or within its supply chain.

Kirkoswald has detailed below the following areas where it sees potential risks that continue to be assessed and managed:

Direct Risk: Kirkoswald complies with all applicable employment and human rights laws. Kirkoswald’s employees are highly skilled professionals and Kirkoswald has implemented procedures to ensure that the risk of employing a trafficked or exploited person within the business either directly, or through a subcontractor, recruitment agency or as a consultant is low.

Indirect Risk: Kirkoswald’s supply chain primarily consists of regulated financial services providers, professional advisors (lawyers, accountants etc) and IT infrastructure and office services. Kirkoswald regards each of these supplier categories to be at low risk of contravening the Act. Kirkoswald has a number of policies in place that are designed to ensure compliance with applicable laws and regulations including the Global Code of Ethics, Staff Handbook, Whistleblowing Policy. Anti-Money Laundering Policy, Anti-Bribery Policy, Tax Evasion and Complaints Policy.

Kirkoswald conducts initial and annual due diligence on its key service providers and it expects all providers to comply with all applicable laws and regulations in the conduct of their business. In terms of non-core contractors, e.g. office services, Kirkoswald uses referrals from reputable business organisations.

Kirkoswald provides initial and annual training to employees on topics related to modern slavery, including anti-money laundering, whistleblowing, anti-bribery and its Code of Ethics. Employees are reminded and encouraged to identify potential violations of its policies and/or applicable law and regulation, as well as to report suspicious behavior.

Kirkoswald will continue to seek to require that new and, on renewal of a relevant contract, existing suppliers provide confirmation of their compliance with the Modern Slavery Act.

Kirkoswald has submitted this statement on the UK Government Modern Slavery Statement registry and will be submitting future Statements online to enhance transparency and accessibility.

This Statement was approved by Kirkoswald’s Governing Body on January 17, 2023.