Modern Slavery Act Transparency Statement
Introduction
This statement is made by Viking Global Investors Europe LLP (the “Firm” or “Viking”) pursuant to Section 54(1) of the Modern Slavery Act 2015 (the “MSA”) in respect of the financial year ending 31 December 2024.
The Firm acknowledges the importance of compliance with the MSA and its purpose to stop slavery, servitude and forced or compulsory labour, and human trafficking. The Firm is committed to conducting its business with integrity and without modern slavery in either the business or its supply chains and to being transparent in its approach, consistent with the Firm’s obligations under the MSA.
Business and Organisational Structure
The Firm is a limited liability partnership incorporated in accordance with the laws of England and Wales and is authorised and regulated by the Financial Conduct Authority (“FCA”) and is subject to the requirements of the FCA Rules.
The Firm is a UK authorised investment manager and provides sub-advisory and trade execution services in the UK, to Viking Global Investors LP (“VGI”) and its group entities in the U.S. The Firm’s clients are VGI and/or its affiliates, which act as investment adviser to various private funds.
Policies
The Firm has an anti-slavery and human trafficking policy (the “Policy”) to support the Firm in ensuring there is no modern slavery in its business and supply chains. Employees are required to review and attest to the Policy upon joining the Firm and on an approximately annual basis thereafter and are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of the Firm’s business or supply chains of any supplier tier at the earliest possible stage, including through the use of the whistleblowing channels available to employees. The Firm may discipline its employees and/or terminate its relationship with individuals and organisations working on its behalf if they breach the Policy.
The Firm’s Chief Compliance Officer has primary and day-to-day responsibility for implementing the Policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
We believe our Code of Ethics (the “Code”) and employment policies and procedures are fair, transparent and implement positive working practices for all of our colleagues. The Code is in place to embed the principles of trust, honesty, objectivity, fairness and respect for oneself and others. All staff of the Firm must read, understand and comply with the Code, policies and procedures that are applicable to them. These are kept under review and enhancements are made where appropriate. The Firm and its wider group are committed to implementing and enforcing systems and controls to safeguard against modern slavery, human trafficking and harmful working practices.
Due Diligence, Risk Assessment and Management
After having reviewed the requirements of the MSA, the Firm considers that its business, supply chain and countries in which the Firm and its affiliates operate are at low risk of involving instances of modern slavery or human trafficking. The goods and services the Firm purchases to allow the delivery of its asset management services are limited to areas such as professional services, real estate, facility management, office equipment, software and catering in the UK. The Firm will continue to assess the risks associated with its supply chains and expand the scope of our focus, as necessary.
Nonetheless, the Firm is committed to taking appropriate steps designated to ensure there is no modern slavery in its supply chains or in any part of its business. The Firm expects its suppliers to comply will all applicable laws and regulations in conducting their businesses.
In order to ensure that staff have a comprehensive understanding of the Firm’s culture and values, as well as the Policy and the risk the Firm’s business faces from modern slavery in its supply chains, the Firm provides annual training to individuals who work for the Firm, and this also forms part of the induction process for all individuals who work for the Firm.
Ongoing Commitment
The effectiveness of the steps taken to ensure there is no slavery or human trafficking in the business or supply chains outlined above will be kept under periodic review. The Firm will seek to raise awareness and educate all staff about modern slavery and the importance of its eradication generally.
The Firm will periodically review and, as appropriate, update this statement.