Modern Slavery Act

Modern Slavery Act Statement

Modern Slavery and Human Trafficking Statement Gresham International Group

Gresham International Group is committed to preventing modern slavery, forced labour, human trafficking, servitude, and all forms of exploitation within its business operations and supply chains. The Group adopts a zero-tolerance approach to modern slavery and is committed to acting ethically, transparently, and with integrity in all business relationships and in every jurisdiction in which it operates.

Gresham International Group operates internationally, providing advisory, compliance, consulting, digital asset, and associated professional services through a network of affiliated entities, partners, and service providers. Due to the international nature of its operations, the Group recognises that certain regions, industries, and outsourced activities may present an elevated risk of modern slavery and human rights abuses. The Group therefore maintains policies, contractual standards, and oversight procedures designed to mitigate such risks.

The Group has implemented internal policies and controls aimed at preventing modern slavery and human trafficking. These include a Code of Conduct applicable to directors, officers, employees, consultants, and representatives, supplier and partner due diligence standards, contractual provisions requiring compliance with labour and human rights laws, and reporting procedures that allow concerns to be raised confidentially and without fear of retaliation.

Risk-based due diligence is conducted on suppliers, partners, and counterparties, proportionate to the nature, location, and risk profile of the engagement. This may include background and reputational screening, verification of corporate and operational practices, contractual commitments to ethical labour standards, and ongoing monitoring of higher-risk relationships. Where appropriate, the Group reserves the right to suspend or terminate relationships where credible modern slavery concerns arise.

The Group periodically assesses where the risk of modern slavery may arise within its operations and supply chains, taking into account geographic risk, sector-specific risk, and reliance on third-party service providers. Where risks are identified, enhanced due diligence, contractual protections, and monitoring measures are applied to mitigate exposure.

Gresham International Group is committed to continuous improvement in preventing modern slavery and human trafficking. The effectiveness of its approach is monitored through management oversight, review of due diligence outcomes, internal compliance processes, and assessment of any reported concerns. Any substantiated breach of the Group’s standards is treated seriously and may result in disciplinary action, termination of relationships, and referral to appropriate authorities where required.

The Group promotes awareness of modern slavery risks across its operations. Relevant personnel and associates are expected to understand the indicators of exploitation, their responsibilities under applicable laws and internal policies, and the procedures for escalating concerns. Awareness initiatives may include internal briefings, compliance communications, and policy updates appropriate to role and risk exposure.

Gresham International Group remains committed to strengthening its practices, enhancing transparency, and working with partners who share its commitment to ethical business conduct and respect for human rights.