1. What is our Policy?

1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various

forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all

of which have in common the deprivation of a person's liberty by another in order to exploit

them for personal or commercial gain.

1.2 Our values include dedication to maintaining an honest and ethical practice that is built upon

integrity and an unwavering commitment to do the right thing. We are committed to

conducting our business and all our relationships based on integrity and without modern

slavery. We are also committed to ensuring there is transparency in our own business and

in our approach to tackling modern slavery throughout our supply chains, consistent with

the disclosure obligations under the Modern Slavery Act 2015 (MSA).

2. This anti-slavery and human trafficking policy (this Policy) applies to all employees (fulltime,

part-time and temporary and including when on secondment), officers and directors of

Tangency Capital Services Ltd. (collectively, we, us, our or TCS), as well as agents,

distributors, contractors and suppliers when acting on our behalf (each a Company


2.1 This Policy does not form part of any employee's contract of employment and we may

amend it at any time.

3. Who is responsible for this Policy?

3.1 Our Board of Directors has overall responsibility for overseeing that this Policy complies

with our legal and ethical obligations prohibiting modern slavery and that Company

Representatives comply with this Policy.

3.2 The Chief Operating Officer has primary and day-to-day responsibility for implementing this

Policy, monitoring its use and effectiveness, dealing with any queries about it, and reviewing

internal control systems and procedures to check they are effective in countering modern


3.3 Management at all levels are responsible for making arrangements for those reporting to

them understand and comply with this Policy and are given adequate and regular training

on it and the issue of modern slavery in our business and supply chains.

4. Every Company Representative has personal responsibility for complying with all applicable

anti-slavery laws and regulations and this Policy.

5. What does compliance with this Policy involve?

5.1 The prevention, detection and reporting of modern slavery anywhere in our business and

supply chains is the responsibility of all those working for us and under our control. Company

Representatives must avoid any activity that could lead to a breach of this Policy.


5.2 Likely conflicts with this Policy, whether current or future, must be notified as soon as

possible to the Chief Operating Officer. Company Representatives are encouraged to raise

concerns about any issue or suspicion of modern slavery in any parts of our business or

supply chains of any supplier tier at the earliest possible stage.

5.3 If any Company Representative is unsure about whether a particular act, the treatment of

workers more generally or their working conditions within any tier of TCS’ supply chains

constitutes any of the various forms of modern slavery, they should raise it with their line

manager (where applicable) or the Chief Operating Officer.

6. We aim to encourage openness and will support anyone who raises genuine concerns in

good faith under this Policy, even if they turn out to be mistaken. We are committed to

ensuring that no one suffers any detrimental treatment or retaliation as a result of any good

faith report he or she makes to us about modern slavery. Any Company Representative

responsible for retaliating against individuals who in good faith report known or suspected

violations of this Policy to us will be subject to disciplinary action, including dismissal where


7. What communication and training is available to support this Policy?

7.1 Training on this Policy, and on the risks of modern slavery, forms part of the induction

process for individuals who work for us, and regular training will be made available as


7.2 Company Representatives should be willing to discuss openly modern slavery with our

suppliers, contractors and business partners to check that they are aware of this Policy and,

as required by this Policy, about the measures which they themselves are taking to reduce

their modern slavery risks.

7.3 When entering into new supplier arrangements, we will, adopting a proportionate risk-based

approach, seek to ensure that our own standard anti-slavery clause or similar appears in all

supply contracts or that the supplier is aware of the MSA. The clause obliges suppliers to

confirm their adherence to this Policy and accept our right (where practicable) to audit their

anti-slavery activities and their own relationships, both routinely and at other times. Where

it is not practicable to negotiate this clause, the relevant supplier should be notified about

TCS’ commitment to eradicating modern slavery under this Policy.

8. What are the sanctions for breaches of this Policy?

8.1 TCS will take appropriate disciplinary and other action against any Company

Representative who:

(A) authorises or participates directly, and in certain circumstances, indirectly, in actions

breaching this Policy or any applicable anti-slavery laws or regulations;

(B) fails to report a breach of this Policy or any applicable anti-slavery laws or regulations

or withholds information concerning a breach they either know about or should have

known about;

(C) exhibits a lack of diligence and awareness about conduct that would constitute such

a violation;


(D) retaliates or attempts to retaliate, directly or indirectly (or encourages or attempts to

encourage others to do so), against someone who in good faith reports a breach of

this Policy or applicable anti-slavery laws or regulations to us; or

(E) knowingly files a false report of a breach of this Policy or applicable anti-slavery laws

or regulations.

Disciplinary and other action is dependent on the nature and severity of the violation, up to

and including termination of employment or the business relationship with TCS.

9. What about our MSA statement?

9.1 Where the turnover of us and our subsidiaries (if any) is or exceeds £36 million in total

annually, we will publish a MSA statement in accordance with s54, MSA. Even where the

turnover is below this level, our policy is still to publish a MSA statement annually.

Dated: September 29, 2020

From time to time this Policy may be revised.