Modern Slavery 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 LLP (“ECM LLP”), Elan Capital Management (London) Ltd (“ECM London”) and Elan Capital Management (Technologies) Limited (“ECM Tech”) (together, the “Elan Group”) for the last financial year ending 31 March.
OVERVIEW
The Elan Group 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
ECM London, following a change in legal status from ECM LLP, 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 and ECM LLP are both authorised and regulated by the Financial Conduct Authority in the UK. All three entities have their principal places of business in London. As of 2 December 2024, ECM London is the investment manager of Elan Master Fund Ltd. (the “Fund”). ECM LLP is in the process of being wound down however due to the look back requirements of the Act, it is this entity (as well as ECM Tech) to which this statement currently relates. ECM Tech is a wholly owned subsidiary of ECM London.
SUPPLY CHAINS AND DUE DILIGENCE
As a financial services business, we consider the risk of slavery or human trafficking existing within our business or supply chain to be low. Our supply chains, as a predominately office-based business, are relatively simple and include stationery, cleaning, refurbishment and maintenance suppliers. Where deemed appropriate, service providers are required to provide their own modern slavery statement when being onboarded.
The Elan Group employs a highly skilled workforce and conducts due diligence on its service providers and counterparties, on a risk based approach, regarding amongst other things modern slavery and human trafficking. The Elan Group does not accept any modern slavery in its supply chain nor in its business. We consider our risk of exposure to modern slavery to be low, but we are nonetheless committed to adopting appropriate measures to assess exposure at onboarding of service providers and counterparties and continuing to assess these on a regular basis.
POLICIES AND PROCEDURES
The Elan Group 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 the Elan Group’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.
TRAINING
The Elan Group conducts internal training to all staff on modern slavery when staff initially join the Elan Group. 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”) directly.
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 7 January 2025 by the Directors of ECM London.
Approved on 7 January 2025 by the Directors of ECM Tech.
Signed by Duncan Tiplady
Director & COO of ECM London
Director of ECM Tech