This statement is made voluntarily by XY Capital Europe Limited (“XY Capital”). XY Capital is not required under Section of the Modern Slavery Act to produce an annual Modern Slavery Act Statement.

This statement will be reviewed annually and is publicly available on XY Capital’s website. It has been approved by a Director.

XY Capital is committed to the prevention of modern slavery in all its forms. It is XY Capital’s policy not to tolerate slavery and human trafficking practices within its business and supply chains.

XY Capital seeks to implement an appropriate risk-based approach to minimise the risk of slave labour. Whilst it is acknowledged that risk factors are present in all global supply chains and across all sectors, it is believed that the XY Capitals’ overall risk exposure to slavery, human trafficking and forced labour is low given the nature of the business undertaken (asset management services) and the skillset required (mainly skilled labour). Consideration will be given to this risk assessment as part of the annual review of this statement.

XY Capital’s primary suppliers include an administrator, a custodian, a broker and professional services firms that provide legal and tax advice and services. Where these suppliers are required to publish a Modern Slavery Statement or have voluntarily published a statement, XY Capital has reviewed it to ensure the supplier has taken steps to deal with modern slavery risks.

Given that XY Capital’s overall risk exposure to slavery, human trafficking and forced labour is low, there is no specific modern slavery and trafficking training provided to staff however, all staff are subject to a general code of conduct and are expected to act in an ethical manner.