Modern Slavery Act Statement

Privilege Project Finance Ltd anti-slavery and human trafficking statement for the financial year ended 31 December 2019

Company overview

Privilege Finance Services Limited (PFS) took over the management functions of the business from

Privilege Project Finance Ltd (PPF) one the 1^st April 2019.

PFS employs 25 staff and operates in the UK.

PFS is a management services company providing services for the Privilege groups of companies that in turn are financial services providers, with a limited supply chains which predominantly focus on procuring professional and technology services, with most of its suppliers based in the UK and the EU.

Policy and principles

PFS is committed to complying with its obligations under the Modern Slavery Act and other relevant legislation relating to the detection and prevention of modern slavery and human trafficking. In particular, PFS is committed to implementing and enforcing effective systems and controls that seek to ensure that modern slavery is not taking place anywhere in its business or in its supply chains and identify and manage any incidents which do arise.

Consistent with its obligations under the Modern Slavery Act, PFS is committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chains. PFS expects the same standards from its contractors, suppliers and other business partners.

Actions taken in financial year ended 31 December 2019

During the financial year ended 31 December 2019, PFS took the following steps with the intention of ensuring that slavery and human trafficking does not take place in its business or supply chains:

1. Modern Slavery Policy
   Implementation of the policy and roll out across established suppliers
2. Standard Contractual Documentation
   New updated contractual provisions requiring suppliers to comply with the Modern Slavery Act are in place. All SPV boards that have Privilege directors are made aware of their obligations and those directors are provided with a copy of the policy
3. Risk Assessments
   This is complete. Establishing the origin of funds for final risk assessments

Next Steps

The policies and procedures will be reviewed during the 2020 financial year and will further enhance the transparency of supply chains and enable a more effective risk-based approach to third party management. This development will ensure that PFS is better able to identify and then effectively mitigate the risks of modern slavery across its supplier landscape.

Approval

This statement is made with respect to the financial year ended 31 December 2019 in accordance with section 54(1) of the Modern Slavery Act 2015. This statement covers PFS and has been approved by the Board of Directors. The statement will be reviewed and updated (if necessary) annually to reflect PFS’s ongoing commitment to ensuring that its business and supply chains are free from slavery and human trafficking. The statement is signed by a director of PFS.