MODERN SLAVERY ACT TRANSPARENCY STATEMENT
19th April 2018
Introduction & Organisation
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (MSA) and constitutes Cedar Rock Capital
Limited's slavery and human trafficking statement for its financial year ending 31 October 2017. Cedar Rock Capital Limited
("Cedar Rock") provides discretionary asset management services to a small number of institutional clients. We operate from a
single London office with fewer than 10 staff.
Cedar Rock's policies relevant to slavery and human trafficking
We do not tolerate slavery or human trafficking anywhere in our supply chains or in any part of our business.
Actions taken or planned in relation to the MSA during the financial year
Staff related policies and training
Our recruitment processes include robust procedures for the vetting of new employees. Our staff have been made aware of the
requirements of the MSA and our related policies and procedures. We have introduced whistleblowing policies that are of relevance to the MSA.
Supply chains and due diligence procedures
We consider that the risk of slavery and human trafficking in our business is low given the nature of our services and straightforward supply chains;
we have therefore adopted a proportionate and risk based due diligence approach to assess the risk of modern slavery and human trafficking in our
supply chains. We consider all suppliers paid during the financial year as the relevant supply chain for this purpose and we assess the geography
of the supplier's services, the nature of the services (e.g. whether these are services that include physical labour/ manufacturing or alternatively
professional services such as legal or consultancy) and other relevant factors such as the regulatory status of the supplier, if any. This due diligence
review has not raised any concerns. We may require additional contractual clauses or written representations from suppliers where we consider these
to present a higher risk for MSA purposes. We have adopted as a policy to discontinue business with any supplier that informs us that they have concerns
about complying with the MSA. We may report a supplier to the UK police and/or take other steps as we may deem necessary should we become aware of a
supplier's inability to comply with the MSA.
This statement was approved by the Board at its meeting held on 19 April 2018 and is signed on its behalf by Andy Brown, Chief Executive