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Cedar Rock Capital
 
 

MODERN SLAVERY ACT TRANSPARENCY STATEMENT


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 2016. 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:

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 are introducing 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 have reviewed all suppliers paid in the last 18 months as the relevant supply chain for this purpose and have considered the geography of the supplier's services, the nature of the services (e.g. services that include physical labour/ manufacturing or professional services such as legal or consultancy) and other relevant factors such as the regulatory status of the supplier. This due diligence review has not raised any concerns.

Planned actions include enhanced checks and new contractual clauses with suppliers that are considered 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 is approved by the Board and signed on its behalf by:

Andy Brown
Chief Executive
April 2017

 

Cedar Rock Capital Limited
110 Wigmore Street
London W1U 3RW
United Kingdom
Tel: +44 (0) 20 7563 1100
Fax: +44 (0) 20 7563 1111

Issued by Cedar Rock Capital Limited ("Cedar Rock"), which is authorised and regulated by the Financial Conduct Authority. This is not a financial promotion for any of Cedar Rock's range of funds. Access to information about Cedar Rock's products is limited to persons who are professional clients and eligible counterparties as defined by the FCA in the United Kingdom and other professional persons to whom it is lawfully permitted to provide access. Investors should be aware that any investment within Cedar Rock's range of products may fall as well as rise and they may not be able to get back their capital invested.
Any person accessing this website acknowledges and agrees that any information on this website is not a recommendation to invest in any fund managed by Cedar Rock ("Fund") and that Cedar Rock is not hereby undertaking to provide any investment advice (impartial or otherwise) to any investor in a fiduciary capacity in connection with any investment in a Fund.

Registered Office: Cedar Rock Capital Limited, Suite 1, 3rd Floor, 11-12 St James's Square, London SW1Y 4LB
Registered in England No: 4466326