It continues to be a priority for the Puma Capital Group to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain.

This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Puma Capital Group’s anti-slavery and human trafficking statement for the 2024 financial year.

Group structure

Puma Investment Management Limited and its subsidiaries together the “Puma Capital Group” provide a range of investment and fund management services within the UK to both private and institutional clients. It has its head office in London, and satellite offices in Manchester and Edinburgh. The Group has a 110 plus strong professional team with over £855m of assets under management (as at March 2025).

Our business 

The Puma Capital Group’s business, comprises the following divisions: Puma Investments, which provides a range of alternative investments to retail investors, intermediaries and wealth managers, Puma Growth Partners, which provides scale-up capital to growing British businesses, Puma Property Finance, which provides first charge lending to developers and professional investors, and Puma Public Markets, which manages capital in the public markets for investors.

We are a signatory to the UN Principles for Responsible Investment and are committed to delivering sustainable investment returns in a way that delivers positive environmental, social and economic benefits.

As a B Corp certified company, we are committed to the highest standards of social and environmental performance, accountability and transparency, including a strong commitment to preventing modern slavery and ensuring the protection of human rights across our operations and supply chain.

Our policies on slavery and human trafficking

We have a number of policies in place to implement our commitment to operating responsibly and ethically as a business and investor. We continuously review and update all our policies.

Our Modern Slavery Statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We also have the following policies in place relevant to modern slavery, which we continuously review and update:

• - Supplier Oversight Policy
• - Supplier Code of Conduct
• - Whistleblowing Policy
• - Responsible Procurement Policy
• - Breaches and Operational Incidents Policy
• - Conflicts of Interest Policy
• - Employee Handbook

Business supply chains

The services the Puma Capital Group itself typically receives, in relation to the services it provides, are office based where its supply chain consists largely of other regulated professional services (Chartered Surveyors, Law Firms, Accountancy Firms, Custodians and Banks).

We recognise that office facility service providers, including cleaning services and IT service providers, as well as food suppliers, may carry a higher risk of modern slavery practices. However, we consider the fact that our service providers are UK based, or have UK establishments, reduces Puma Capital Group’s exposure to modern slavery practices in these areas together with our due diligence processes below.

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk, all new suppliers at onboarding are provided with a copy of our Supplier Code of Conduct, that sets out certain minimum standards we expect suppliers to abide by when providing us (or any funds or entities managed or advised by us) with products or services. These standards cover workforce, data protection, environmental responsibility and bribery and corruption. As part of the onboarding process, suppliers are required to complete a supplier due diligence questionnaire and confirm they have read, understood and agree to be bound by our Supplier Code of Conduct. In addition, suppliers are required to confirm whether they comply with, or are exempt from, the Modern Slavery Act 2015, and, where applicable, to provide a copy of their Modern Slavery Statements.

Our Supplier Monitoring Group (comprising representatives from Compliance, Legal, Finance, IT and Operations along with Head of Impact) oversees all new and existing suppliers, to identify, assess and monitor potential risk areas in our supply chains, mitigate the risk of slavery and human trafficking occurring in our supply chains and protect whistle blowers. This includes requiring our tier 1 and tier 2 suppliers on a periodic basis, to re-complete the detailed due diligence form. Other checks include, but are not limited to, reviewing financial statements, adverse media checks and in some cases conducting site visits where appropriate.

Suppliers outside our tier 1 and tier 2, of smaller contract value, are reviewed annually and monitored by the employee relationship.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, the Puma Capital Group provides employees and management with training on a range of compliance matters including Modern Slavery, particularly in relation to mitigating risks within supply chains.

Staff Wellbeing

We are committed to fostering a safe, supportive and respectful environmental for all our employees. We encourage a culture of openness where staff are empowered to raise any concerns regarding unethical or unsafe practices, with a clear pathway for doing so through our Whistleblowing Policy. In addition, we provide access to Employee Assistance Programs and external support services, ensuring that all our people have the necessary resources for both professional and personal wellbeing. Our commitment to staff wellbeing is integral to maintaining a workplace that is free from exploitation, abuse and modern slavery.  

For an on behalf of the Board 

David Kaye 

Group Chief Executive Officer

31 December 2024