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Appian Capital Advisory – Modern Slavery Statement

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INTRODUCTION

Appian Capital Advisory LLP (“Appian“) is the sub-advisor to Appian Capital Advisory Limited, the investment advisor to Appian Natural Resources Fund II LP, Appian Natural Resources Fund III LP, Appian Credit Strategies I LP and Appian EM Fund LP and other related co-investment and continuation vehicles, which are private equity funds investing in mining and mining-related companies, assets and management teams across select geographies and commodities.

Appian is committed to the prevention of forced labour and has a zero-tolerance policy for human trafficking and slavery in all its forms. This statement confirms Appian’s commitment to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking are not taking place within Appian’s own business or, so far as reasonably practicable, within the supply chains of businesses with which Appian has a relationship.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Appian’s Modern Slavery and Human Trafficking Statement for the financial year ended 31 December 2025. It has been approved by the Members of Appian Capital Advisory LLP in accordance with section 54(6)(b) of the Modern Slavery Act 2015. This statement will be submitted to the UK Government’s Modern Slavery Statement Registry, in line with Home Office guidance.

Given the nature of Appian’s activities — investing in mining and resources companies, many of which operate in jurisdictions with elevated human rights risk profiles — Appian recognises that its sector carries inherent exposure to modern slavery risks both in its own operations and through portfolio company supply chains. This statement sets out the steps taken to identify, assess and mitigate those risks.

ORGANIZATIONAL STRUCTURE AND SUPPLY CHAINS

Appian is an international fund management enterprise with offices in London (UK), New York (USA), and Dubai and Abu Dhabi (UAE). Our primary areas of focus are private equity and private credit investing in metals, mining and infrastructure across select geographies and commodities, with over US$5 billion of assets under management.

Appian’s own direct supply chain is relatively limited, comprising principally professional services (legal, accounting, tax and audit), IT infrastructure and office services providers. We assess these suppliers as presenting a lower intrinsic risk of modern slavery exposure, given their professional nature and geographic footprint predominantly in developed market jurisdictions. Notwithstanding this, all new suppliers are subject to Appian’s standard onboarding due diligence, which includes modern slavery risk assessment.

Appian’s principal modern slavery risk exposure arises through the operations and supply chains of its portfolio companies, many of which operate in the mining sector across emerging markets in Africa, South America, Southeast Asia and elsewhere. Appian considers this sector-level and geographic risk in its investment due diligence and ongoing portfolio monitoring processes (see Section below).

POLICIES ON SLAVERY AND HUMAN TRAFFICKING

Appian operates the following policies relevant to the prevention of slavery and human trafficking:

Human Rights Policy

Appian respects the human rights of all those working for or with Appian, and of people in the communities in which Appian and its portfolio companies operate. Appian is committed to ensuring no modern slavery occurs within its operations or supply chains, including no human trafficking, forced or involuntary labour, and no child labour. Appian will not exploit anyone and will not knowingly do business with organisations or individuals that do not meet equivalent human rights standards.

Appian’s Human Rights Policy is aligned with the UN Guiding Principles on Business and Human Rights (“UNGPs”) and the IFC Performance Standards, which are incorporated as requirements in Appian’s investment documentation with portfolio companies.

Recruitment Policy

Appian is an equal opportunities employer and is committed to a non-discriminatory and respectful working environment. Appian operates a robust recruitment policy, including appropriate background checks covering criminal record screening (including for bribery, corruption and human trafficking offences), right-to-work verification, and identity confirmation. The policy helps safeguard against human trafficking and forced labour in Appian’s own workforce.

Appian does not use zero-hours contracts or engage labour through intermediaries in ways that could obscure the employment relationship or create vulnerability to exploitation.

Whistleblowing Policy

Appian operates a whistleblowing policy so that all employees can raise concerns about, among other matters: breaches of FCA rules; behaviour harmful to Appian’s reputation or financial well-being; breaches of Appian’s policies; any kind of harassment or misconduct; and suspected cases of modern slavery or human trafficking. Concerns can be raised confidentially through Appian’s designated whistleblowing channel, and Appian’s policy prohibits any retaliation against individuals who raise concerns in good faith. The Senior Manager responsible for whistleblowing under the SM&CR is Mathias J. Iranzo Conde.

Code of Business Conduct

Appian’s Code of Business Conduct encompasses the following policies relevant to modern slavery prevention:

  • Anti-money laundering and counter terrorist financing policy;
  • Equal opportunities and diversity policy;
  • Gifts, benefits and anti-bribery policy;
  • Whistleblowing policy;
  • Kidnapping, ransom and extortion policy; and
  • Environmental, social and governance (ESG) investment policy (including human rights requirements for portfolio companies).
DUE DILIGENCE AND SUPPLY CHAIN RISK MANAGEMENT

Appian has integrated modern slavery and human rights risk assessment into both its pre-investment due diligence and ongoing portfolio monitoring processes. Specifically:

  1. Pre-investment: All new investments are subject to an ESG due diligence process that includes assessment of modern slavery risk factors, including labour practices, use of contract or migrant labour, community relations and supply chain traceability. High-risk findings are escalated to the Investment Committee and may form conditions to investment.
  2. Investment documentation: Appian’s standard investment agreements require portfolio companies to comply with applicable laws (including modern slavery and forced labour legislation) and, where relevant, to adopt the IFC Performance Standards as an operational benchmark.
  3. Ongoing monitoring: Portfolio companies are subject to annual ESG reporting and periodic site visits. Modern slavery indicators form part of Appian’s ESG monitoring framework. Material concerns identified through monitoring are escalated to the relevant portfolio company management team and reported to the Appian Investment Committee.
  4. Supplier onboarding: Appian requires new suppliers and service providers to confirm compliance with applicable modern slavery legislation as part of the onboarding process. Contracts with material suppliers include appropriate representations and termination rights in the event of non-compliance.

Our suppliers, contractors and agents are expected to act in a socially responsible and ethical manner. Suppliers are selected and retained only if their policies and practices are consistent with Appian’s standards. Where a supplier is unable to demonstrate adequate standards, Appian will work with them to improve, or will seek an alternative supplier.

TRAINING AND AWARENESS

All new staff undergo an induction programme that includes briefing on Appian’s key policies and procedures, including those relating to modern slavery and human trafficking. All existing staff are subject to mandatory annual compliance training, which includes modules on anti-money laundering, countering bribery and corruption, market abuse and modern slavery awareness.

Appian will review its training programme annually to ensure it remains fit for purpose and reflects emerging risks and regulatory guidance. Completion rates for mandatory training are monitored and reported to the Compliance Officer.

Where Appian staff are involved in investment transactions or portfolio oversight in higher-risk jurisdictions, targeted training on relevant modern slavery and human rights risks is provided to the relevant deal team members.

MEASURING EFFECTIVENESS

Appian monitors the effectiveness of its approach to preventing modern slavery through a combination of qualitative and quantitative indicators, which are reviewed at least annually. These include the completion of mandatory staff training; the operation of Appian’s whistleblowing arrangements, including any modern slavery concerns raised and their outcomes; the integration of modern slavery considerations within investment due diligence and ongoing portfolio monitoring; portfolio company reporting on labour practices and human rights; and the outcomes of supplier onboarding reviews.

Appian will continue to develop and refine its approach as the programme matures, and any gaps or areas for improvement identified through this review process will be addressed in the following year’s programme.

APPROVAL AND SIGNATURE

This statement was approved by the Members of Appian Capital Advisory LLP on 09 July 2026 and is signed on their behalf by Michael W. Scherb, for and on behalf of ACAL Capital Advisory Ltd, a designated member of Appian Capital Advisory LLP, in accordance with section 54(6)(b) of the Modern Slavery Act 2015.

Michael W. Scherb
Founder and Chief Executive Officer

For and on behalf of ACAL Capital Advisory Ltd, Designated Member of Appian Capital Advisory LLP
Date: 09 July 2026

 

Page last updated: 13 July 2026