This statement is issued by CCAM, in compliance with section 54 of the Modern Slavery Act 2015 (the “Act”). This statement constitutes CCAMs’ Modern Slavery and human trafficking transparency statement for the financial year ended 31 December 2021 and sets out the CCAM’s approach to the prevention of slavery, servitude, forced or compulsory labour (together, “Modern Slavery”) within the relevant organisation and its supply chains.

CCAM’s business

CCAM is a specialist Asian and Japanese fund management group, focused on managing capacity constrained, performance focussed funds.

As CCAM is a regulated investment management entity and given the nature of the services procured from suppliers, CCAM believes the risk of Modern Slavery arising within its businesses, or within the businesses of its suppliers, to be limited.

Supply chains

CCAM’s supply chains include:

  • Third party distribution companies and platforms that enter into arrangements to distribute or promote CCAM’s investment funds and investment strategies;
  • Third party outsourcing and professional services companies that provide a range of professional services to CCAM, including IT services, legal advice, audit and payroll services, office cleaning, office equipment and supplies and services required to support staff in CCAM’s offices; and
  • Third party providers of private healthcare, employee benefits and other associated services required to support CCAMs’ staff.

Policy on Slavery and Human Trafficking

CCAM is committed to ensuring that its supply chains are free of any slavery and/or human trafficking and will not knowingly support or do business with any supplier who is involved in such activities. CCAM expects their employees, contractors and suppliers to prevent acts of modern slavery and human trafficking from occurring within both their businesses and supply chains. CCAM has corporate policies in place under which employees are encouraged to report concerns of non-compliance with FCA rules or statutory obligations, including those under the Act, to Compliance. Any concerns raised in respect of the Act will be escalated to senior management for review and investigation.

Due diligence processes

In any procurement process appropriate due diligence is conducted to assess the extent of CCAM’s exposure to the risk of slavery. This may include measures such as:

  • incorporation of questions in procurement documents/initial due diligence covering the service provider’s or supplier’s working practices; and
  • placing a contractual obligation on the service provider or supplier to comply with all applicable laws which, where relevant, would include compliance with the Act.

The above measures are applied proportionately in accordance with CCAM’s assessment of the level of risk associated with the particular supplier. Consideration is given to the nature of products or services and the locations from which those products are made, or services provided.

Responsible Investing

The risks of modern slavery and human trafficking are considered as part of CCAM’s bottom-up investment process, alongside financial and strategic issues, as part of CCAM’s assessment and engagement with companies.

The Portfolio Manager is responsible for engagement on ESG matters, including modern slavery, and monitoring is carried out via investment reviews. Where CCAM might have specific concerns or where it deems it necessary to protect its clients’ interests, it will consider escalating its concerns to senior management or seriously consider disposing of its position.


All staff with responsibility for procurement from third party suppliers will receive appropriate training on their obligations under the Act and how best to meet those obligations. In addition, the Compliance Department can provide on-going advice and support to such staff, as required.

Approval procedure

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 was ratified by the Partners of Coupland Cardiff Asset Management LLP on 27 January 2022.


Richard Cardiff