Modern Slavery Statement

Introduction

This statement has been prepared by GSA Capital Partners LLP on its behalf and on behalf of GSA Capital Services Limited, Green Park Research Limited and GSA Member Limited ("GSA") in accordance with section 54 of the Modern Slavery Act 2015 ("the Act"). It sets out the steps GSA took during the financial year ending 31st March 2024 to detect and prevent modern slavery within its organisation.

Organisation Structure

GSA Capital Partners LLP is an FCA registered Alternative Investment Fund Manager, founded in 2005 and currently employing approximately 160 staff globally. GSA operates in the financial services sector and manages a number of absolute return investment strategies focused on systematic trading across liquid markets globally. GSA is principally located in London and New York.

Risk Assessment

GSA's supply chain primarily consists of intangible goods and services such as financial trading and clearing services via electronic platforms, supplied to GSA by regulated trading counterparties, exchanges, software providers and data vendors.

GSA's clients are all professional institutions and day-to-day business transactions do not, for the most part, include any physical buying or selling of goods.

GSA's staff are largely highly skilled, well paid individuals who are hired on a long-term contractual basis, and for whom GSA faces significant competition in the marketplace. All staff hired are subject to comprehensive background checks which are intended to highlight any problematic issues that may require further investigation.

Given these factors, GSA considers its business and employees to be at low risk from modern slavery. However, it acknowledges the potential for the risk of modern slavery within certain elements of its supply chain for ancillary services required by the firm, such as providers of routine cleaning, catering and security services, where work is outsourced to third parties who might deploy lower skilled workers to provide GSA with the required services.

Policy in relation to slavery and human trafficking

GSA will not tolerate modern slavery within its organisation and endeavours to avoid doing any business with any entity that participates in modern slavery. It assesses its suppliers and counterparties for any signs of such practices, considering the geographic location of the supplier, their reputation and the nature of the services provided. GSA would take action if it became aware that there had been a breach of the Act by GSA or any of its suppliers.

Training

GSA has made relevant staff aware of GSA's position on modern slavery. All staff are required to read the GSA Compliance Manual which references GSA's Modern Slavery Statement, its contents and highlights where GSA's Modern Slavery Statement can be found.

GSA staff are required to undertake online training, which aims to educate them on their role in detecting and deterring third parties from using the financial system to further modern slavery schemes. The training explains and tests GSA staff on how to identify modern slavery red flags and has, as some of its learning objectives, the ability to identify the links between financial crimes such as money laundering and human trafficking, understanding the importance of counterparty due diligence and knowing how to identify suspicious behaviour.

Tim Kuschill

General Counsel