Anti-Slavery Statement

Constantin Capital Limited is a single family office and forms part of a global family office structure made up of separate legal entities. This anti-slavery statement outlines our commitment to upholding ethical standards across all operations.

Our values-driven organization aspires to meet the highest professional, legal and ethical standards.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business.

At Constantin Capital Limited, we take our commitment to supporting human rights seriously. We back organisations that fight forced labour and child labour. We also support a range of philanthropic, civic and cultural groups through donations and pro bono work, both globally and locally.

This statement sets out our approach to modern slavery.

We provide specialized services and employ a professional workforce. For these reasons, the risk of modern slavery or human trafficking in our organisation is low.

Our supply chain is typical of a single-family office. It is mainly service-based, including professional advisory, administrative, travel and IT services, along with basic office supplies. We have reviewed our suppliers and consider the overall risk of modern slavery to be low because:

• The nature of the goods and services we procure (mostly services, mostly skilled professions).
• The locations from which we procure them (mostly in developed markets).
• Our procurement practices (for example, we agree to reasonable terms and ensure timely payment).

While the overall risk is low, these criteria also enable us to identify where the risk may be higher.

We are committed to preventing modern slavery and human trafficking in our business and supply chain. Our Supplier Code of Conduct sets out this commitment. It requires ethical behaviour, integrity and strong controls. These measures help ensure that slavery and human trafficking do not occur in any part of our supply chain.

We have embedded checks for modern slavery in our routine supplier due diligence process and have raised awareness of these issues with colleagues who manage the supplier vetting process.

Our due diligence process reflects the relative risk for potential suppliers and includes:

• Screening suppliers against global sanctions and enforcement lists such as OFAC and the World Bank Debarment List. We also review adverse media to identify risks, including human rights abuses, human trafficking and labour violations.
• Planning to include modern-slavery risk factors in our assessments, using criteria such as country of operation and government response, as measured by the Global Slavery Index.
  Suppliers identified as medium or high risk undergo further checks. Higher-risk or higher-spend suppliers are asked to complete a questionnaire on their policies relating to human rights, modern slavery, forced labour, child labour and human trafficking.
• Our supplier policy requires full compliance with all relevant laws on slavery, forced labour and human trafficking, including the UK Modern Slavery Act 2015. We expect all suppliers to adopt practices that ensure compliance with these standards.We do not engage with suppliers whom we know or believe fail to operate to similar ethical standards and treat their staff with respect.

We support our human rights related policies with internal guidelines, regular awareness and training. Every member of the organization has the right to raise concerns about values, ethics and professional conduct, without fear of retribution.

We remain committed to continually improving our practices to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement.