BENCHMARK CAPITAL LIMITED

MODERN SLAVERY STATEMENT

About this statement

In accordance with the Modern Slavery Act 2015, this statement sets out Benchmark Capitals actions to understand all modern slavery risks related to our business and to put in place steps to prevent slavery and human trafficking from taking place in our business and supply chains.

We aim for high standards of governance throughout our organisation and corporate responsibility matters enormously to us. We recognise the responsibility we have towards our clients and other stakeholders, including our employees and society as a whole.

Our commitment

Benchmark Capital is strongly opposed to slavery and human trafficking and will not knowingly support or conduct business with any organisation involved in such activities.

Our people

Our direct workforce is predominantly made up of professionally qualified and skilled employees and we consider the risk of modern slavery occurring within our business to be low. We are a living wage employer and have committed to meeting the living wage for all our employees and where applicable, we expect our suppliers to adopt the same principle. All new employees are signposted to our employee handbook which includes our Equal Opportunities Policy which makes it clear we oppose all forms of unfair discrimination or victimisation.

Our ethical standards

We promote high ethical standards and have an internal Whistleblowing policy whereby employees can raise suspected concerns regarding unethical behaviour or decisions that could indicate potential wrongdoing.

Due diligence is undertaken before entering a new client relationship and this is enhanced in high-risk countries.

Our suppliers

The Group relies on the use of third parties to support high quality, effective and efficient delivery of our services to clients and we expect all of our suppliers to operate in a responsible, ethical, open and transparent way and in compliance with all applicable laws and regulations.

As an asset management company with relatively simple supply chains predominantly comprising business and professional services organisations, we believe that there is limited risk of slavery or human trafficking taking place. The vast majority of our major suppliers are head quartered in low risk countries.

Material suppliers are reviewed annually in line with our policies and this includes assessment against service levels, operational risk, compliance with regulation, business continuity and contractual obligations. We take a risk based approach to supplier management and classification with criteria which includes business impact of failure, service complexity, regulatory requirements, brand/reputational impact and contract length used to determine appropriate on-going contract and performance management activities.

Monitoring and review of this statement

As attention on this topic grows and transparency improves, we will continue to strengthen our assessment of business practices and engage with companies where we believe tougher action is needed.

This policy is reviewed periodically by the board. Recommendations for any amendments are reported to the board.

Important Information: Issued by Benchmark Capital Limited, Sussex House, North Street, Horsham, West Sussex, RH12 1RQ. Registration in England No 09404621.