Modern Slavery and Human Trafficking Statement

For the Financial Year Ending 31 December 2024

This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and outlines the steps Kedalion Capital Management LLP has taken to prevent modern slavery and human trafficking in our operations and supply chains.

1. Our Business and Structure

Kedalion Capital Management LLP is a UK-based hedge fund manager authorised and regulated by the Financial Conduct Authority. We manage investment funds on behalf of institutional and professional clients globally. Our business is office-based and operates within the financial services sector, which is considered low risk in relation to modern slavery and human trafficking.

2. Our Commitment

We are committed to conducting our business ethically and with integrity. We have a zero-tolerance approach to slavery, forced labour, and human trafficking in any part of our operations or supply chains.

3. Our Supply Chains

While our direct operations are typically limited to regulated financial institutions or professional services, we work with a range of suppliers including IT services, legal advisors, consultants, and facilities providers. We recognize that some of these sectors may carry a higher risk of modern slavery, particularly where third-party service providers employ subcontracted or low-wage labour.

4. Policies and Governance

We have implemented policies that reflect our commitment to preventing modern slavery, including:

  • Modern Slavery Policy – Outlines our expectations for ethical behaviour among staff and suppliers.
  • Supplier Code of Conduct – Outlines our expectations of key suppliers to operate in compliance with modern slavery laws and ethical labour practices.
  • Whistleblowing Policy – Enables staff to report concerns confidentially, including any related to human rights violations.

5. Monitoring and effectiveness

We conduct risk assessments of our supply chains to identify areas of potential vulnerability. For suppliers operating in higher-risk jurisdictions or industries, we may:

  • Request further information or compliance confirmations
  • Require contractual commitments regarding labour standards
  • Decline to work with non-compliant suppliers

We assess our policies and procedures annually to ensure they remain effective. Key performance indicators include:

  • Number of suppliers reviewed for compliance
  • Number of reports or concerns raised
  • Actions taken in response to identified risks

6. Training and Awareness

We provide training to relevant staff to raise awareness of modern slavery and human trafficking, particularly those involved in procurement and supplier management.

8. Board Approval

This statement was approved by the Executive Committee of Kedalion Capital Management LLP on 19 September 2025.

Signed,

Joshua Silver
Chief Operating Officer
Kedalion Capital Management LLP
23 September 2025