Modern Slavery Act Transparency Statement

Trinity Street Asset Management LLP (“TSAM”) is committed to preventing modern slavery and human trafficking from occurring within in its business or supply chains. The term ‘modern slavery’ encompasses the criminal offences set out in the Modern Slavery Act 2015 but, more broadly, may include: 

• Forced labour;
• Human trafficking;
• Exploitation of a criminal, financial or sexual nature;
• Domestic servitude; and 
• Forced or early marriage. 

This statement outlines the steps TSAM has taken to ensure modern slavery does not occur in its business or supply chains. 

The Firm, Supply Chains & Risk Assessment

TSAM is a UK-based limited liability partnership whose sole business activity is investment management. TSAM’s financial year ended on 31 March 2024. As a financial services firm regulated in the jurisdictions in which TSAM operates, the risk of modern slavery is deemed to be low because TSAM is based in, and sources its services almost entirely from, countries with a low prevalence of modern slavery and a high government response rate, such as the UK, some other European countries and the United States. TSAM referred to the Global Slavery Index when assessing the prevalence of modern slavery and the government response rate in relevant countries.  

TSAM is committed to conducting appropriate checks where it identifies a potential risk of modern slavery and has obtained confirmation that staff servicing its London office are adequately paid, legally permitted to work in the UK, and that building management are in compliance with the principles of the Modern Slavery Act. 

Recruitment & Staff Terms and Conditions

TSAM has fewer than 30 staff members, all of whom receive adequate compensation, benefits and holiday leave. On occasion, TSAM may not have a direct employment relationship with a small number of workers, such as contractors engaged via a recruitment agency. However, TSAM only works with reputable agencies where such need arises. All staff members, including contractors, are vetted as part of the recruitment process, including their eligibility to work in the UK.

These standards are aligned with, or exceed, standards expected within the investment management industry and, more broadly, the countries in which its staff members are situated.

Policies, Procedures and Due Diligence

TSAM’s policies and procedures demonstrate our commitment to eradicating the risk of modern slavery in our business and supply chain. These include, but are not limited to: 

• Staff Handbook – TSAM expectations of staff members are clearly set out, along with their legal rights and procedures on how to raise grievances internally.
• Whistleblowing Policy - staff members are encouraged to report any suspicion of wrongdoing via the firm’s whistleblowing procedures, which are designed to make it easy for concerns to be raised, without fear of reprisal or victimisation.
• Compliance Manual – sets out TSAM’s expectations of staff members on various topics including bribery & corruption, as well as setting out the regulatory conduct rules to which staff must adhere. 
• Anti-Money Laundering Policy and Procedures – set out the risk factors to consider when onboarding clients, as well as the due diligence measures and ongoing monitoring undertaken. 

Awareness Training

TSAM delivered staff training on modern slavery as part of its annual compliance training. Annually, staff members attest to having read the Compliance Manual, which includes details of what modern slavery encompasses and what actions staff members should take if they suspect they have identified an instance of modern slavery.

Effectiveness of Measures 

TSAM intends to regularly review the effectiveness of the measures implemented to help combat the risk of modern slavery. 

This statement was approved by the members of TSAM and signed on 07 February 2025.