Last updated August 2026
Objective
This statement comprises the Slavery and Human Trafficking statement of Capel Asset Management (the Company) for the financial year ending 31 March 2025. Capel Asset Management is required to make this statement pursuant to section 54(1) of the Modern Slavery Act 2015 (MSA). The Statement was approved by the Board in March 2025.
The Business
Capel Asset Management provides a range of investment management services within the UK to both private and institutional clients. Given the nature of its operations, Capel Asset Management is at very low risk of exposure to Slavery and Human Trafficking issues. However, the Company continues to take its responsibilities seriously and has sought ways to champion better work and working lives and to raise awareness of the issues of Modern Slavery and Human Trafficking.
Supply Chains
Capel Asset Management does not act as a producer, manufacturer, or retailer of any physical goods and, as a financial services provider, it has a relatively straightforward supply chain compared to other sectors.
Policies in relation to Slavery and Human Trafficking
Capel Asset Management recognises the role it shares with its suppliers in tackling the growing issues of Modern Slavery. The Company is committed to a high level of ethical trading within its business, for clients, and within the supply chain that it uses. The Staff Handbook states the Company has a zero tolerance to Slavery and Human Trafficking and places a duty on all staff to report any potential infringement arising either internally or externally.
Key policies include:
• Conduct Policy
• Whistleblowing Policy
• Conflicts of Interest Policy
• Employee Policies
Capel Asset Management has also committed to paying its staff not less than the current London or National Living Wage (depending on location).
Due Diligence Processes
Although Slavery and Human Trafficking concerns are of a low risk to the business, Capel
Asset Management has introduced an approach to ensure ongoing monitoring of suppliers. Suppliers are assessed and reviewed when contracts are reviewed, renewed, or established.
For and on behalf of the Board
Russell Edward Catley
This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Capel Asset Management’s anti-slavery and human trafficking statement for the 2026-2027 financial year.