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: