Modern Slavery Statement

Introduction

This statement is made in relation to Argonaut Capital Partners LLP (‘Argonaut’), pursuant to section 54(I) of the Modern Slavery Act 2015 (the ‘Act’) for the financial year ending 31 December 2023.

The purpose of this statement is to set out the steps that Argonaut has taken and continues to take to ensure that modern slavery or human trafficking does not take place in our business or our supply chain. 

Argonaut is committed to acting ethically and with integrity.

Our Business and Supply Chain 

Founded in 2005, Argonaut is a UK based group whose sole business activity is investment management. It pursues a fundamental investment strategy across a variety of jurisdictions globally with a core focus on Europe, including UK equities. Argonaut is authorised and regulated in the UK by the Financial Conduct Authority (FRN: 433809).

Argonaut does not tolerate modern slavery or human trafficking and takes a risk-based approach to its supply chain, including making inquiries where it is considered necessary to do so. The nature of Argonaut’s business means that it does not have complex supply chains and does not procure material services from suppliers located in high-risk countries. Argonaut sources the majority of its services from the UK and other low risk countries such as Ireland and the US where modern slavery is not prevalent. Argonaut’s suppliers are predominantly regulated financial and professional services companies, including banks, data service providers, technology providers, accountants and law firms. Argonaut also engages suppliers of equipment, maintenance and support services for its office location. 

Argonaut believes that it undertakes appropriate due diligence in relation to new suppliers and expects its suppliers and their supply chains to comply with all relevant legislation and regulation in the countries in which they operate. Argonaut has an escalation policy that allows employees to report issues and concerns without reprisals for doing so. The firms policies are periodically reviewed and, where necessary, updated to ensure its continuing commitment to the Act.

Training and Awareness

Argonaut’s Staff Compliance Manual and Code of Ethics require staff to act with integrity and abide by the firm’s policies and procedures (including, but not limited to policies relating to, Whistleblowing, AML and Anti-Bribery). All Argonaut staff are required to attest to this on a regular basis and are provided with appropriate ongoing training to ensure they are aware of their obligations to comply with the firms policies and procedures, including with respect to the risk of modern slavery. 

This statement will be reviewed annually and updated as required.