Modern Slavery Policy

Modern Slavery and Human Trafficking Policy Statement 2026

This statement is made by Validus Risk Management Limited and its subsidiaries (together referred to as “Validus”) pursuant to section 54 of the Modern Slavery Act 2015 (the “Statement”). Validus is committed to conducting business in an ethical and honest manner, and to implementing and enforcing systems that ensure slavery and/or human trafficking are prevented. The Statement was approved by the Board of Directors of Validus for the financial year ending December 2025 and will continue to apply until amended. The Board of Directors of Validus will review it at least once a year.

Introduction from the Board

Validus operates in the financial services sector as a provider of independent market risk advisory firm specialising in the management of currency, interest rate and commodity price risk. It is authorised by the Financial Conduct Authority (the “FCA”) as a MIFIDPRU investment services firm (FRN: 555972).

Validus considers its legal and corporate responsibilities of great importance in relation to its investors, its partners, its employees, and the wider community. Validus acknowledges that modern slavery and human trafficking are punishable by up to life imprisonment.

Validus faces a low risk of involvement in slavery or human trafficking in the territories that the firm is active in. However, Validus is focused on maintaining its zero-tolerance approach to these issues.

Policies

Validus operates a number of internal policies and procedures which are relevant for mitigating the risk of modern slavery and human trafficking occurring in its business or any of its supply chains. In particular, the following policies contribute towards mitigating the risk of modern slavery and human trafficking:

1. Recruitment Validus follows a robust recruitment policy, including conducting eligibility to work checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. Only specified, reputable recruitment agencies are used to source labour and any new agency is verified before they are used.
2. Whistleblowing Policy. This ensures all employees are aware that they can raise concerns about how colleagues are being treated, or practices within the organisation without fear of Our employees are encouraged to report any breaches of policies or any other concerns that have come to their attention.
3. Know Your Client / Know Your Supplier. Validus conducts risk-based due diligence on clients and suppliers to verify identity, ownership and business integrity, with enhanced checks for higher-risk No engagement proceeds until due diligence is completed and approved by Compliance.
4. Risk Management Policy. Validus applies risk assessment policies and procedures that are proportionate to their size, structure and location

Due Diligence Processes and Training

The following due diligence procedures to review our supply chains and prospective clients apply:

1. Supply Chains. As part of the financial services sector, Validus recognises that it has a responsibility to take a robust approach to modern slavery and human trafficking. Validus is committed to improving its practices to combat modern slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from modern slavery and human trafficking. Given the nature of our suppliers, who are either financially regulated themselves or supply financially regulated firms, the majority of suppliers and business is conducted from locations which are considered to be at low risk of engaging in modern slavery, forced labour or human trafficking. Our supply chains are generally short and direct, particularly as our services cannot be resold and are on a direct basis with clients.
2. Client Due Diligence. All clients undergo either a simplified or enhanced due diligence process whereby they are screened for evidence of criminal activity, adverse media and sanction lists. As part of this due diligence process, Validus assesses if the client presents risks from a modern slavery and human trafficking perspective.
3. Training. Validus provides a mandatory online training course on modern slavery and human trafficking to all staff members across the firm alongside wider training on financial crime, bribery, corruption, data protection and other related topics. Each financial year, employees receive e-learning modules followed by examination on the module material provided.