Modern Slavery Act Statement

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (the “Act”) and constitutes the slavery and trafficking statement for Elan Capital Management (London) Ltd (“ECM London”) and Elan Capital Management (Technologies) Limited (“ECM Tech”) (together, “Elan”) for the last financial year ending 31 March.

OVERVIEW

Elan recognises the importance of ensuring that our business is conducted in a responsible way. We welcome the Modern Slavery Act and the transparency it encourages and take a zero-tolerance approach to modern slavery occurring in our business or supply chains.

BUSINESS STRUCTURE

Elan is a global investment management firm headquartered in London with affiliates in Helsinki and Singapore.

ECM London provides investment management services to an alternative investment fund which pursues investment strategies that involve investing in a wide range of securities and instruments in various jurisdictions. ECM London is authorised and regulated by the Financial Conduct Authority in the UK. ECM Tech is a wholly owned subsidiary of ECM London. Both entities have their principal places of business in London. 

SUPPLY CHAINS AND DUE DILIGENCE

As an investment management firm, Elan has a relatively simple supply chain. Our business model relies on internal operations engaging professional staff (investment, risk, compliance, operations, technology and support functions) and a network of third-party service providers, which includes technology service companies, institutional financial firms, professional services companies and financial data providers professional services.

Elan employs a highly skilled workforce and all staff are remunerated in line with other financial services firms, in excess of applicable legal requirements. Our Head of HR is responsible for overseeing staff well-being, and promoting high standards of health, safety, and ethical conduct at work. All staff are protected under applicable laws and regulations, which are fully reflected in the Firm’s policies and procedures.

Our trading counterparties are highly regulated and the majority of our third-party service providers also employ highly skilled staff in developed markets. As such, we consider the risk of slavery or human trafficking existing within our business or supply chain to be low.

Elan also has a number of service providers in relation to non-core functions, such as stationery, cleaning, refurbishment and maintenance suppliers, where the risk of modern slavery could be considered to be higher. Elan will not knowingly engage with, or support, suppliers that are involved in modern slavery or human trafficking. We take a risk-based approach to identifying, assessing and managing modern slavery risks across our supply chain, recognising that such risks may evolve over time and differ by supplier type, geography and service model.

We undertake a proportionate due diligence approach in relation to all new suppliers to assess inherent and emerging risks. This includes reviewing publicly available information to assess a service provider’s good standing, including consideration of any indicators of modern slavery, human rights concerns or broader reputational risk. Where relevant risk indicators are identified, we undertake further assessment and consider appropriate escalation or enhanced due diligence measures. Where necessary, we will take appropriate and proportionate action, which may include engagement with the supplier to seek remediation, or termination of the relationship where remediation is not feasible.

POLICIES AND PROCEDURES

Elan has several internal policies designed to address our commitment in related areas. These include the following:

·         Employee Handbook (the “Employee Handbook”), which includes information on the standards expected of all of our employees, including Elan’s commitment to oppose modern slavery

·         Anti-Bribery Policy, which outlines our zero-tolerance approach to bribery and corruption in our business activities and provides information for staff on preventing instances from occurring

·         Equal Opportunities Policy, which re-iterates our commitment to fairness and tackling any instances of discrimination, harassment and victimisation

·         Speak Up Policy, which allows our employees to raise questions or issues of concern safely and confidentially, which would include any issues relating to modern slavery

·         Third Party Risk Management Policy, which sets out our risk-based approach to the identification, assessment and ongoing management of risks associated with our service providers

Members of staff are required to review and attest to the compliance policies upon joining the firm and on a periodic basis thereafter.

TRAINING

Staff are provided with induction training on joining Elan and must complete ongoing training covering a variety of areas, including financial crime concepts such as AML, anti-bribery and corruption, and the prevention of the facilitation of tax evasion as well as whistleblowing and complaints. In 2025, all staff were provided with a recap on modern slavery and our obligations thereunder. We continue to develop and deliver targeted training to relevant staff to increase awareness of the Act’s requirements and enhance their ability to identify potential slavery and human trafficking within our supply chain.

IMPLEMENTATION

Our Compliance Committee takes responsibility for implementing the objectives considered in this statement.

The Head of Compliance will monitor progress of our efforts in this area and issues (should they arise) and report back to our Chief Operating Officer (“COO”) and the Compliance Committee directly.

We recognise that effective modern slavery risk management is an ongoing process that evolves as risks and best practices develop. Over the coming year we will:

  • Continue to refine our risk assessment methodology.

  • Provide enhanced refresher training to staff involved in the procurement of third party services.

  • Benchmark our practices against recognised frameworks and peer disclosures to identify areas for improvement.

MONITORING AND REPORTING

Our Speak Up Policy allows our employees to file reports openly, confidentially, or anonymously. This supports our aim of increasing transparency within our business on these important issues.

If issues are identified in relation to modern slavery, these will be reported to our COO.

More general issues in relation to the running of this policy will be reported back to the Compliance Committee on a quarterly basis.

Approved on 2 February 2026 by the Directors of ECM London.
Approved on 2 February 2026 by the Directors of ECM Tech.

Signed by Duncan Tiplady
Director & COO of ECM London
Director of ECM Tech