Anti-Slavery Notice

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This statement is made in relation to Gladstone Capital Management LLP, pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) for its financial year ending 30 November 2021.

The purpose of this statement is to set out the steps that Gladstone has taken and continues to take to ensure that modern slavery or human trafficking does not take place in our business or our supply chain.

Gladstone is committed to acting ethically and with integrity.

Our Business and Supply Chain

Gladstone Management is a UK-based group whose sole business activity is investment management. The firm has given careful consideration to Section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015.

Gladstone Management does not tolerate modern slavery or human trafficking and takes a risk-based approach to its supply chain, including making inquiries where it is considered necessary to do so. The nature of our business means that the Firm does not have complex supply chains and does not procure material services from suppliers located in high-risk countries. Gladstone Management sources its services from the UK and other low-risk countries such as Ireland and the United States of America where modern slavery is not prevalent. Our suppliers are predominantly regulated financial and professional services companies, including banks, data service providers, technology providers, accountants and law firms. The Firm also engages suppliers of equipment, maintenance and support services for our office locations.

The firm believes that it undertakes appropriate due diligence in relation to new suppliers and expects our suppliers, and their supply chains, to comply with all relevant legislation and regulations in the countries in which they operate. The firm has an escalation policy that allows employees to report issues and concerns without reprisals for doing so. The Firm’s policies are periodically reviewed and, where necessary, updated to ensure the Firm’s continuing commitment to the Act.

The Firm has committed to the UK Stewardship Code and has published a statement on how the Firm integrates stewardship activities into its investment process. This statement sets out, amongst other things, how the Firm engages with the management of investee companies in relation to environmental, social and governance issues.

Training and Awareness

The Firm’s Staff Compliance Manual and Code of Ethics require staff to act with integrity and abide by the Firm’s policies and procedures. All staff are required to attest to this on a regular basis and are provided with appropriate ongoing training to ensure they are aware of their obligations to comply with the Firm’s policies and procedures, including with respect to the risk of modern slavery.

This statement will be reviewed annually and updated as required.