The Modern Slavery Act 2015


The Modern Slavery Act 2015 (the “Act”) seeks to address the role of businesses in preventing
modern slavery from occurring in their supply chains and organisations. This statement
constitutes the slavery and human trafficking statement required by Section 54 of the Act, for
the financial year ending 31 March 2024 for Sona Asset Management (UK) LLP and its Group
companies (together “Sona”).

Sona is committed to addressing the requirements placed on it by the Act. Sona applies
policies and processes on a group-wide basis irrespective of where our companies, people,
clients and supply chain providers are located.

Organisational Structure

Sona Asset Management (UK) LLP is a limited liability partnership incorporated in England and
Wales and regulated in the United Kingdom by the Financial Conduct Authority (FRN: 814191)
(“FCA”). Sona’s sole business is investment management.

Supply Chains

Sona has a zero-tolerance policy to slavery and human trafficking and will not knowingly
support and/or do business with any suppliers who are involved in slavery.

Sona’s direct supply chains includes, for example, trading partners and administrators (banks
and trading counterparties); suppliers of office supplies (e.g. printing supplies, groceries);
professional services (e.g. legal and financial advice); data and research providers; and IT
software and services. We undergo rigorous supplier due diligence on all suppliers.

Our Approach to the Act

To fulfil our obligations under the Act, Sona may:

  • Undertake due diligence on our supply chains to assess the nature and extent of its
    exposure to the risk of slavery.
  • Communicate to potential key suppliers that Sona has a zero-tolerance policy with
    regards to slavery.
  • Collaborate with industry peers, regulatory bodies, law enforcement agencies, and
    non-governmental organizations to share best practices, resources, and intelligence to combat
    modern slavery effectively.

We expect our suppliers to comply with all applicable laws and regulations in the conduct of
their business, but in addition believe that our suppliers should meet appropriate standards
with respect to labour practices and treatments.

We are satisfied that there is no evidence of any act of modern slavery or human trafficking in
our business and supply chains involving our employees.

Policies, Awareness and Training

Sona maintains several policies which are relevant to the detection and protection of Modern
Slavery in order to create a fair working environment and mitigate the risk of modern slavery.
These include the Employee Handbook, Whistleblowing Policy, Compliance Manual and AML
and Bribery Assessment.

Sona employees receive annual training on a verity of topics, but not limited to, money
laundering and terrorist financing, whistleblowing, corruption, bribery. These topics are also
included in the new joiner training to remind them of their obligations to comply with the
Sona’s policies and procedures, including modern slavery.


Sona remains steadfast in our commitment to eradicating modern slavery and human
trafficking. We understand that this goal necessitates ongoing vigilance, collaboration, and
concerted action from all stakeholders. Through our unwavering efforts and partnerships, we
strive to create an environment where human rights are upheld, and exploitation is eliminated.

Iain Colquhoun, CFO
10 May 2024