Modern Slavery Act

This statement is published pursuant to Section 54(1) of the Modern Slavery Act 2015 by Sarnia Asset Management (“Sarnia”) and covers the period from our incorporation on 11 February 2020.

Sarnia is committed to the highest standards of professionalism, ethical behaviour and integrity in everything we do. We take our responsibilities to our clients, the people who work in our business, our suppliers and the communities in which we do business seriously.

The Profile Of Our Business

The Company was founded in February 2020 and is a Guernsey domiciled non-cellular company and has been established to act as an investment management company. It is regulated by the Guernsey Financial Services Commission (“GFSC”) to carry out restricted activities with respect to Category 1 and Category 2 controlled investments, i.e. the structuring, establishing, managing and administering of investment funds.

Sarnia does not have operating or administrative subsidiaries outside of the Bailiwick of Guernsey. It does have employees, freelancers, and advisors in the UK as well as the EU (primarily: Germany). It will market its funds to a number of jurisdictions, initially focusing on the UK, the EU, the US, and Switzerland.

None of the jurisdictions in which we operate have a poor record on modern slavery and human trafficking. We are committed to monitoring developments in the jurisdictions in which we operate through sources such as the Global Slavery Index. Our employees are required to comply with professional and ethical codes of conduct.

As a fund management company, we operate in a professional services environment with a relatively low risk of modern slavery occurring. We do not rely on extensive or complex supply chains for the purposes of our business.

Policies

Notwithstanding the low risk of modern slavery in our business sector, we are committed to ensuring that we do not permit practices such as modern slavery or human trafficking within our business or in our supply chain.

We have robust recruitment processes which seek to that ensure appropriate checks on new recruits are carried out before the relevant staff member commences employment.

In working for Sarnia, our staff are protected by our policies which are intended to reflect and uphold our commitment to a high standard of ethics and integrity in our business. Our policies are regularly reviewed to ensure that they are and remain comprehensive.

We provide all of our staff with relevant training on our policies and procedures to prevent money laundering, to counter the financing of terrorism and to ensure that our services are not exploited by those wishing to conduct other criminal enterprises.

Clients & Suppliers

Before taking on a new client, we conduct due diligence checks. We are constantly reviewing our due diligence processes to ensure that any issues relating to money laundering or other criminal enterprises (including modern slavery or human trafficking) are identified.

In relation to our supply chain, we deal only with reputable suppliers of goods and services. We continue to review our approach to the engagement (and renewal) of suppliers in order to identify any supply chain risks and take any actions necessary with suppliers to ensure that such risks are mitigated.

Governance

As Sarnia expands to operate across multiple jurisdictions – if only by way of accepting investors from abroad – we are concerned to ensure that modern slavery issues are considered at both a local and global level within our business and supply chain with robust and consistent measures put in place to address any identified risks.

Swen Lorenz
Chief Executive Officer
Sarnia Asset Management
25 August 2021