Modern Slavery and Human Trafficking Statement

Last Updated: February 14, 2024

Greyhound Capital Management LLP (“Greyhound Capital” or “we”) is committed to preventing acts of modern slavery and human trafficking from occurring both within its business and through its supply chains. Although Greyhound Capital is not technically required to publish a statement under the United Kingdom Modern Slavery Act 2015, we have decided to publish this statement on a voluntary basis.

About Greyhound Capital

Greyhound Capital is an investment management firm, registered as a limited liability partnership and authorized and regulated by the United Kingdom Financial Conduct Authority. Greyhound Capital is also an Exempt Reporting Adviser with the United States Securities & Exchange Commission.

Greyhound Capital's principal activity is the provision of investment management services to both institutional clients and other sophisticated investors around the world.

Greyhound Capital is strongly opposed to slavery and human trafficking, and is committed to acting ethically and with integrity in all of its business dealings and relationships. This commitment is embedded in our culture, through our vision, mission and values. Our human rights principles are embedded in our firm-wide policies, procedures and codes of conduct.

Supply Chain and Risk Assessment

Greyhound Capital is committed to acting ethically and with the highest integrity. Greyhound Capital expects its employees, contractors, suppliers, counterparties and portfolio companies to prevent acts of modern slavery and human trafficking from occurring within both its business and supply chains and has policies in place to establish standards expected from across our business activities.

We have evaluated the nature and extent of our exposure to the risk of modern slavery and human trafficking. Given the nature of Greyhound Capital's business, we believe that there is a relatively low risk of slavery and human trafficking in connection with our activities. Nevertheless, we recognize that slavery and human trafficking can occur in a wide variety of situations, and we remain vigilant to the risk of modern slavery in our business.

We have undertaken a review of our supplier base, taking a risk-based approach to assess the likelihood of the existence of slavery within our supply chains, taking into consideration the nature of the services provided, their geographical location and their own likely supply chain. As a provider of financial services, a large proportion of the Company’s suppliers are “low risk” professional service providers. Those suppliers who were identified as “high risk” were contacted by us and notified of our expectations with regard to modern slavery and human trafficking and we have sought appropriate reassurances. To date, we have not identified any cause for concern about compliance with our expectations among our suppliers.

We will continue to assess our practices and engage with our people and vendors to raise awareness and manage the risk of modern slavery and human trafficking occurring in our organization and supply chain in light of changing global circumstances and an evolving global policy environment.

Staff Awareness

Our policies include our Whistleblowing Policy, which empowers our employees and contractors to report and escalate any concerns of unethical conduct, whether relating to modern slavery, human trafficking or other matters, without fear of retaliation.

Further, we continue to raise awareness and educate our employees in relation to the Modern Slavery Act’s implications across our business.

Approval

This statement has been approved by Greyhound Capital's Management Committee on behalf of Greyhound Capital Management LLP on February 14, 2024 and constitutes our slavery and human trafficking statement for the financial year ending December 31, 2023.

/s/ Pogos Saiadian