Appian Capital Advisory LLP – Modern Slavery Statement

INTRODUCTION

Appian Capital Advisory LLP (“Appian”) is the investment advisor to Appian Natural Resources Fund I LP, Appian Natural Resources Fund II LP, Appian Natural Resources Fund III LP and Appian Credit Strategies I LP, which are private equity funds that invest solely in mining or mining related companies, assets and management teams across select geographies and commodities.

Where the context so requires, references in this statement to Appian include references to Appian and its affiliates from time to time. Appian is committed to the prevention of the use of forced labour and has a zero tolerance policy for human trafficking and slavery. This statement confirms Appian’s continued commitment towards implementing and enforcing effective systems to ensure that slavery and human trafficking, in all its forms, are not taking place within the Appian business.

ORGANIZATIONAL STRUCTURE

Appian is an international fund management enterprise comprising of nine offices around the world located in London (main office), New York, Toronto, Perth, Dubai, Belo Horizonte, Johannesburg, Montreal and Lima. Our primary areas of focus are private equity and private credit investing in mining and mining related companies and assets across select geographies and commodities. With over US$3.6 billion of assets under management, Appian is uniquely positioned as the premier operating value investor in the metals, mining and infrastructure sector with an investment model that offers downside risk protection while maintaining upside optionality and generating long-term value investment through the cycle.

Appian’s policies on slavery and human trafficking

Appian operates the following policies which are relevant to the prevention of slavery and human trafficking in its operations:

1. Respecting human rights
   Appian respects the human rights of all those working for or with Appian, and of the people in the communities in which Appian operates.  Appian are committed to ensuring no modern slavery happens within their operations or supply chains, including no human trafficking, forced or involuntary labour and no child labour.  Appian will not exploit anyone and will not do business with companies, organizations, or individuals that Appian believes are not working in accordance with the same human rights standards as they do.  In all aspects of our business, personnel are expected to abide by our policies and applicable laws relating to modern slavery and human trafficking.
2. Recruitment policy
   Appian are an equal opportunities employer and are committed to creating and ensuring a non-discriminatory and respectful working environment for all our staff. Appian operate a robust recruitment policy, including, without limitation, proper background checks to ensure that the potential personnel has not been convicted of any bribery or corruption cases nationally or internationally. The recruitment policy helps safeguard against human trafficking or individuals being forced to work against their will.
3. Whistleblowing
   Appian also operates a whistleblowing policy so that all employees, regardless of length of service, know that they can raise reportable concerns related to breach of FCA rules, anything that would be the subject matter of a protected disclosure, behaviour that harms or is likely to harm the reputation or financial well-being of Appian or breach one of Appian’s policies and procedures, including any kind of harassment, misconduct and suspected cases of modern slavery.
4. Code of business conduct
   Appian operate the following codes of conduct policies to ensure compliance with our commitment to ensuring that slavery and human trafficking is not taking place within the Appian business.
   • Anti-money laundering and counter terrorist financing policy
   • Cash movements policy
   • Equal opportunities & diversity policy
   • Gifts, benefits and anti-bribery policy
   • Whistleblowing policy
   • Kidnapping, ransom and extortion policy

SUPPLIERS

We acknowledge that the risks associated with modern slavery reach beyond Appian’s direct supply chain to include those within the supply chains of the companies we invest in. We remain committed to integrating modern slavery considerations into both our pre-investment and post-investment procedures, offering guidance to the management teams of our portfolio companies as needed.

Our suppliers, contractors, and agents are expected to act in a socially responsible and ethical manner. A potential supplier is selected and retained only if their own procedures correspond with Appian’s codes of conduct. Suppliers are required to comply with the laws, rules, and regulations of the countries in which they operate.

TRAINING

All new staff undergo an induction programme when they join Appian. This includes a briefing on all of the key policies, procedures and processes adopted by Appian, which includes modern slavery and trafficking. In addition, all existing members of staff are subject to our annual roll out of compliance tutorials which must be completed by each staff member. These compulsory courses include, among others, tutorials on anti-money laundering and countering terrorist financing, countering bribery & corruption and combating market abuse.

OUR PERFORMANCE INDICATORS

Appian are proud to have a first-class record when it comes to anti-modern slavery and/or human trafficking practices and we continue to take active steps towards ensuring that this is not taking place within our wider supply chain.

APPROVAL AND SIGNATURE

This statement has been approved by the Appian Board of Directors and is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Modern Slavery and Human Trafficking Statement for Appian Capital Advisory LLP and its affiliates.

Winta Jarvis
General Counsel and Chief Compliance Officer