Modern Slavery Statement

Cheyne Capital is a diversified Alternative Investment Manager that manages a number of investment funds and vehicles. We do not deal in any hard goods or manufactured items, and have no offices in, nor purchase any goods directly from, any developing countries. Cheyne Capital does not have a traditional manufacturing supply chain. We do not purchase goods produced in developing countries for on-sale or integration into our products. Cheyne Capital oversees the provision of financial services to support the investment funds and vehicles it manages. Predominantly, this includes trading, execution, and marketing services, as well as oversight of fund administration and asset custody services. We also work with suppliers who support our office facilities.

We have assessed the risk of modern slavery to our business, and we do not believe we have any high-risk areas in relation to slavery, servitude, human trafficking or forced labour.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Cheyne Capital has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings, and to putting effective systems and controls in place to safeguard against any form of modern slavery within the business or our supply chain. To ensure compliance with this policy, we conduct regular checks on our supply chain, including by providing our suppliers with the Cheyne Supplier Code of Conduct, providing training to our staff, and operating a number of internal supporting policies. We may terminate any contract at any time should instances of modern slavery and/or human trafficking come to light.

We operate a number of internal policies and procedures to ensure we conduct business in an ethical and transparent manner. These include:

• Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery.
• Recruitment process. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees, to safeguard against human trafficking or individuals being forced to work against their will.
• Whistleblowing policy. We operate a whistleblowing policy so that all employees know they can raise concerns about how colleagues are being treated or about practices within our business or supply chain without fear of reprisals.
• Code of Business Conduct. This code explains how we behave as an organisation and how we expect our employees and suppliers to act.

The absence of any reports received from employees, suppliers, the public, or law enforcement agencies to indicate that modern slavery and/or human trafficking has been identified within our business or supply chain.