Modern slavery, human trafficking, forced labour, and child labour have no place in the Group's business or in the supply chains and counterparties through which the Group operates. We take steps appropriate to the scale of our operations to identify, prevent, and report any such activity.
The footprint of the Group.
| Legal form | BVI segregated portfolio company. Issued capital USD 10,000,000. Sole shareholder. |
| Operations | Investment-fund operations conducted from the British Virgin Islands. The first segregated portfolio capitalises a Class A reinsurance platform in the Turks & Caicos Islands. |
| Personnel | Two Directors. Service providers engaged on a contracted basis through written engagement letters. |
| Supply chain | Limited and visible. Comprises BVI Registered Agent, Authorised Representative, Auditor, Fund Administrator, Banker / Escrow Bank, BVI Legal Counsel, TCI Insurance Manager, TCI Auditor, Actuarial Consultant, TCI Legal Counsel, Reinsurance Brokers, screening providers, and IT / cloud-hosting providers. Each is named in the Operating Infrastructure page. |
Where the risk could arise.
The Group has assessed its operations and supply chain to identify modern-slavery and human-trafficking risk. The assessment finds that risk is low in the Group's direct operations and in its supply chain, on the basis that: (i) all service providers are regulated professionals (lawyers, auditors, banks, fund administrators, insurance managers, brokers); (ii) all engagements are governed by written engagement letters with confidentiality and conduct obligations; (iii) the underlying investment is a regulated reinsurance platform whose ceding-company counterparties are themselves licensed insurers; and (iv) personnel are limited in number and personally known to the Board.
The Group does not operate in or capitalise sectors at higher inherent risk of modern slavery — extractive industries with informal workforces, garment supply chains, fishing operations in protected zones, agricultural seasonal labour, or sectors where forced or trafficked labour is documented as systemic.
What we do, in proportion.
| Investor onboarding | AML / KYC includes source-of-funds and source-of-wealth verification. Funds derived from human trafficking or modern slavery are by definition unlawful and would be flagged by the EDD framework. |
| Service-provider onboarding | Engagement letters include a representation that the provider does not employ forced or trafficked labour and complies with all applicable labour laws in its jurisdiction. |
| Underwriting screens | The Responsible Investment Statement excludes, at Target level, reinsurance counterparties whose underlying activity is wildlife trafficking, illegal logging, or fishing in protected zones — sectors which carry elevated modern-slavery risk in addition to environmental and sanctions risk. |
| Sanctions screening | OFAC, UN, EU, UK HMT and BVI local lists, including any designations relating to human-trafficking activity. |
| Whistleblowing | The independent whistleblowing channel can receive any report of suspected modern slavery or human trafficking, anonymously, with non-retaliation guaranteed. |
| Training | Director and personnel training includes an annual module on financial-crime typologies, including human-trafficking indicators. |
Approved by the Board.
This Statement is approved annually by the Board of Amberstone Capital Group SPC Ltd. The next review will take place at the Q1 governance cycle of [next year].
Signed for and on behalf of the Board:
Odaana Magumba · Principal Director · [Date]