MSA Transparency Statement

Viking Global Investors Europe LLP

Modern Slavery Act Transparency Statement


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 ended 31
December 2021.

The Firm is a limited liability partnership incorporated in accordance with the laws of England and
Wales. The Firm is committed to conducting its investment advisory business in accordance with
the highest legal and ethical standards, and in compliance with all applicable laws, rules, regulations
and guidance.

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

After having reviewed the requirements of the MSA, the Firm considers that its business and supply
chain are at low risk of involving instances of modern slavery. Nonetheless, the Firm is committed
to taking appropriate steps designated to ensure there is no modern slavery in its supply chain or
in any part of its business. The Firm expects its suppliers to comply will all applicable laws and
regulations in conducting their businesses.

Business and Organisational Structure

The Firm is a UK authorised investment manager and provides sub-advisory and trade execution
services to Viking Global Investors LP (“VGI”) and its group entities. The Firm’s clients are VGI
and/or its affiliates, which act as investment adviser to various private funds. The Firm is authorised
and regulated by the Financial Conduct Authority (“FCA”) and is subject to the requirements of the
FCA Rules.

Steps the Firm has taken to address the MSA for the financial year ended 31 December 2021

  • Supply Chain Review: As a financial services business, the Firm is operated by a highly skilled
    workforce and has a limited supply chain. We consider the risk of slavery or human trafficking
    existing within our business or supply chain to be low. The goods and services we purchase to
    allow the delivery of our asset management services are limited to areas such as professional
    services, real estate, facility management, office equipment, software and catering in the UK.
  • Employment Practices, Culture & Values: 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. Regular training is provided to all staff around the
    Firm’s culture and values. The Group is committed to implementing and enforcing systems and
    controls to safeguard against modern slavery, human trafficking and harmful working practices.
  • Anti-slavery and human trafficking policy: The Firm has recently introduced an anti-slavery and
    human trafficking policy into its 2022 Europe Policy Manual. The Firm’s Chief Compliance Officer
    has primary and day-to-day responsibility for implementing this 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. Employees 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. The Firm may discipline its
    employees and/or terminate its relationship with individuals and organizations working on its behalf
    if they breach the policy.

Training on the Firm’s anti-slavery and human trafficking policy, and on the risk to the Firm’s business
faces from modern slavery in its supply chains form part of the induction process for all individuals
who work for the Firm, and regular training will be provided as necessary.

The effectiveness of the steps taken to ensure there is no slavery or human trafficking in the
business or supply chain 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.

This statement has been approved by the Firm’s Operating Practices Committee and signed on its
behalf by the Firm’s Chief Compliance Officer on March 29, 2022.