Modern Slavery Statement

1. Our commitment

Capital Custodian Authority Ltd is committed to preventing modern slavery and human trafficking in our own operations, in our supply chains, and in the businesses in which we invest. We consider forced labour, debt bondage and exploitative employment practices to be unacceptable in any part of our activities, and we expect the same standard of the companies we back and the suppliers we engage.

2. Our business and supply chains

We are a private equity firm operating from [offices in London and Manchester]. Our direct supply chain is limited and comprises professional services, technology, facilities and travel providers. The principal area of potential risk lies within the operations and supply chains of our portfolio companies, particularly those in industrial, logistics and facilities-related sectors.

3. Due diligence

Modern slavery risk is assessed during investment diligence and monitored after completion. Our approach includes:

• Pre-investment screening of labour practices and use of agency workers;
• Contractual commitments from suppliers to comply with the Modern Slavery Act 2015;
• Encouraging each portfolio company to adopt an appropriate policy, whistleblowing channel and supplier code of conduct;
• Annual review of portfolio company reporting on labour and human rights.

4. Training

All employees receive periodic training on identifying and reporting modern slavery risk. Investment professionals receive additional guidance on assessing labour practices during diligence.

5. Approval

This statement was approved by the board of Capital Custodian Authority Ltd on [date] pursuant to section 54 of the Modern Slavery Act 2015 [or, where turnover is below the statutory threshold, is published voluntarily]. It will be reviewed annually.