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Modern Slavery Act

This statement is published on behalf of Maples and Calder, Maples Fiduciary Services (UK) Limited and Maples and Calder Services Europe Limited (the "UK entities") with reference to section 54(1) of the Modern Slavery Act 2015 (the "Act") (the "Statement"). The Statement covers the financial year to 30 November 2016.

The Statement was approved by the Global Management Committee of the Maples Group on 27 March 2017.

The Maples Group includes Maples and Calder, an integrated international law firm advising clients around the world on the laws of the British Virgin Islands, Cayman Islands and Ireland.  In each jurisdiction in which Maples and Calder has a presence, a separate undertaking or entity called Maples and Calder has been established including Maples and Calder in London, an unlimited liability company registered in England and Wales (Company No. 03369233).  The Maples Group also includes MaplesFS (including Maples Fiduciary Services and Maples Fund Services) an independent provider of specialised fiduciary, fund administration, entity formation and management and trust and private client services.  In the UK, Maples Fiduciary Services (UK) Limited is a private limited company (Company No. 09422850). The Maples Group has also established Maples and Calder Services Europe Limited in the UK (a private limited company with Company No. 07052645) to provide certain support services to other entities within the Maples Group.  At present, the UK operations of the UK entities do not meet the criteria to require a statement under the Act. Notwithstanding this, the UK entities regard the Act and its objectives as a necessary measure to counter slavery and human trafficking and are therefore pleased to publish the steps that are being taken in this Statement.

We acquire goods and services from suppliers in the UK and elsewhere to support the services we provide to our clients and the Maples Group generally.  We have committed to support the objectives of the Act not just within the UK but on a global, group wide basis.  The Maples Group is opposed to slavery and human trafficking and has policies and procedures in place, including in relation to anti-money laundering, countering terrorist financing and anti-bribery and anti-corruption, which prohibit the facilitation of criminal enterprises.  Although as a professional services provider we believe the risk of slavery or human trafficking existing within our business to be low, we are taking steps to ensure we identify any links to, or risks of, being connected with slavery or human trafficking.

During this first year of reporting, efforts have been focussed on identifying and implementing a suitable due diligence framework so that third party supply chain practices can be examined and audited going forward. During the next reporting period to 30 November 2017 we will conduct due diligence on our contractors and suppliers to ensure that we know who we are working with, and the source of goods and services we acquire.  This due diligence will include more detailed consideration given to suppliers who may be located in, or have connections to, countries with a higher risk of slavery and human trafficking. At each contract renewal we will proactively ensure that our suppliers share our commitment to the fight against slavery and human trafficking and have their own policies and procedures in place to support the objectives of the Act.  We are committed to best practice in this regard and ensuring that slavery and human trafficking do not exist in our supply chains.  In the event that we do identify any links between a supplier and slavery and/or human trafficking we will insist on that supplier taking remedial steps or we will terminate the relationship.

The Maples Group trains staff on induction and annually on various policies and procedures we have in place to prohibit the facilitation of criminal enterprise and we are taking steps to introduce a mandatory module in relation to the Act to help our people identify risk factors and indicators or "red flags" of possible slavery and human trafficking.  Internally, our core values include people and teamwork to achieve the best results for our clients - you can find more details about our values, commitments to diversity and equality, and corporate social responsibility and community projects at https://www.maplesandcalder.com/about-us/.

Alasdair Robertson

Global Managing Partner, Maples and Calder

Chairman, MaplesFS

Date:  27 March 2017