MODERN ANTI-SLAVERY & HUMAN TRAFFICKING STATEMENT

Strategic Corporate Services Limited – Vanuatu

INTRODUCTION

Strategic Corporate Services Limited (SCS Ltd) is committed to displaying integrity in regards to all aspects of its business operations, including respecting human rights. SCS Ltd recognises that modern slavery is a crime and a violation of fundamental human rights, and we are committed to acting ethically and operating with integrity in regards to all aspects of our business.

This is the third annual statement made on behalf of Strategic Corporate Services Limited and other associated companies pursuant to the United Kingdom’s Modern Slavery Act 2015, and in recognition of corresponding laws of EU member states. It sets out the steps that we have taken during the current financial year, and continue to take, to prevent modern slavery from taking place in our supply chain or within our business.

This modern slavery statement has been approved by the SCS Ltd board of directors on 6th April 2024 and covers all companies within and associated with Strategic Corporate Services Limited.

ORGANISATIONAL STRUCTURE AND BUSINESS MODEL

The financial services business of SCS Ltd is responsible for the administration of a wide variety of fiduciary services across a diverse range of asset classes, including real estate, private equity, renewables, hedge, debt, and other alternatives. Clients include a wide spectrum of fund managers from ‘first fund’ market entrants to large institutional managers.

The corporate services business of SCS Ltd provides company secretarial and administration services to a broad range of corporate clients spanning SMEs, public companies, multinationals, sovereign wealth funds, family offices, and private clients requiring corporate services. The private wealth and family office business of SCS Ltd provides a range of private client services, including the formation and administration of vehicles such as trusts, companies, and partnerships on behalf of predominantly high and ultra-high net worth individuals, including family offices.

SUPPLY CHAIN

SCS Ltd does not have a traditionally defined supply chain as the business model is to provide third-party administration services directly to our clients. Client and other financial institutions, with which we work, are still likely to employ lower-paid workers around the world in services such as security, cleaning, catering, and call centres. These types of jobs are traditionally considered higher risk, not least because the roles are often filled by migrant workers.

Our client and financial institution sector is not generally regarded as a sector where slavery and human trafficking is a significant problem. Due to the nature of the services SCS Ltd provides, it is unlikely that we would provide services in relation to client funds that have been generated through the exploitation of individuals either through slavery or human trafficking.

RELEVANT POLICIES

SCS Ltd does not currently have a dedicated anti-slavery and human trafficking policy; however, we operate a number of internal policies that reflect our zero-tolerance approach to modern slavery and demonstrate our commitment to ensure that we are conducting business in an ethical and transparent manner. The Group Corporate Social Responsibility Policy makes specific reference to the human rights of employees and to ethical purchasing where SCS Ltd aims to obtain and retain competitive goods and services and avoid, where known, any sources that may jeopardise human rights, safety, or the environment.

In addition, the employee staff handbook makes it abundantly clear that employees are expected to behave ethically and operate with integrity at all times. SCS Ltd’s policies and procedures are reviewed annually by the Board, and we remain satisfied that our policies are appropriate, effective, and sufficient to prevent modern slavery from taking place in our supply chain or within our business, given our activities.

DUE DILIGENCE AND AML PROCESS

SCS Ltd performs extensive due diligence on its clients based on jurisdictional requirements in line with The Financial Action Task Force (FATF – UK) recommendations and its regulatory requirements and operates with best-of-breed policy, procedures, and processes.

All staff are required to undertake an annual AML Training Module that includes an explanation of slavery and human trafficking and is designed to assist staff in identifying possible areas of risk. Additionally, clients are monitored utilizing a leading automated database to identify any areas of risk, which would include any prosecution or charges relating to slavery and human trafficking.

Any adverse findings or suspicion would be the subject of a formal risk escalation in accordance with our Risk Escalation Policy and Procedure and, where applicable, a suspicious activity report would be made to the relevant authority as any instance would be treated as a breach of law.

ONGOING EFFECTIVENESS

Due to our model and our approach to due diligence, client monitoring, and corporate governance, SCS Ltd has assessed that there is a very low risk that our business and supply chain could be involved directly or indirectly with slavery and human trafficking.

CONCLUSION

We are proud of the historical steps we have taken to combat any risk of modern slavery and human trafficking being present in our business and supply chains. We will continue to be vigilant, and we remain committed to reviewing and improving our practices further in this area in future years as our business grows and develops.

On a continuing basis, , we intend to undertake ongoing  reviews of the effectiveness of our Anti-Slavery policy and the values and behaviours which all SCS Ltd employees are expected to adhere to in order to reinforce our commitment to operate a culture of trust, openness, and integrity within our business.

We will continue to raise awareness as part of our wider approach to risk management, and SCS Ltd is committed to educating our employees in relation to the implications of the Modern Slavery Act across our business.