This statement is published on behalf of Polar Capital Holdings plc, Polar Capital Partners Limited and Polar Capital LLP (together "Polar Capital") and references to "we", "us", "our" or the "firm" are to all three entities. This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 ("the Act") and constitutes Polar Capital's Anti-Slavery and Human Trafficking Statement for the financial year ended 31stMarch 2025.

Polar Capital Holdings plc is the parent company to the Polar Capital Group which provides specialist active investment management to professional and institutional investors through a range of fundamentally research-driven funds diversified by asset class, as well as geographical and sectoral specialisation. Polar Capital is principally located in London and maintains offices in France, Spain, Germany, Denmark, Sweden, Switzerland, China, Singapore, and the USA.

‌Our Supply Chain

We deemour supply chain to be relatively simple as services provided to Polar Capital comprise of professional services and business support.

Our supply chain includes third party suppliers for the following goods and services:

  • Professional services

  • Recruitment

  • Travel

  • IT and telecommunication

  • Marketing and communication

  • General office support services

Polar Capital takes a zero-tolerance approach to slavery and human trafficking. We expect those in our supply chain to comply with our values and the Act. As a means of ongoing monitoring, we periodically require our suppliers to confirm that they continue to operate in compliance with our Anti-Slavery and Human Trafficking Statement.

‌Due diligence and risk assessment

Due diligence is conducted using a risk-based approach, tailored to the nature and risk profile of a supplier.

When evaluating a supplier's modern slavery and human trafficking risk, we consider elements such as its geographic location, the nature of the services it provides and its corporate status. Performing due diligence assists us in better understanding supplier risks and ultimately better managing supply chain risk effectively.

‌Our Policies

Our anti- slavery and human trafficking efforts are underpinned by the following group-wide policies and procedures which improve our ability to prevent, detect, manage and report slavery and human trafficking.

Code of Conduct

Our global code of conduct sets out the principles and values that we hold ourselves to when making decisions. All employees are required to fulfil their obligation to fully comply with all applicable laws, rules and regulations. All employees are required to confirm at least annually that they have read and understood our code of conduct.

Whistleblowing

Our whistleblowing policy encourages all employees to report any suspected concerns regarding unethical behavior and misconduct. Staff are expected to report breaches or suspected breaches. Divided between internal and external, the various whistleblowing reporting lines that a member of staff may use to report concerns are listed within our policy.

‌Employees

We are duly committed to upholding the highest level of human rights for our employees. Polar Capital's policies and procedures are designed to provide staff members with protections in accordance with legislation relating to human rights and employment.

‌Staff Awareness

We provide staff with training regarding the risks surrounding modern slavery and human trafficking, ultimately aiming to help them better understand the scale of the problem and learn to spot the signs.

‌Key Performance Indicators

We have introduced two key performance indicators (KPls) to assist in measuring the effectiveness of our anti-slavery efforts. Staff and key third-party supplier adherence to our Anti-Slavery Policy is monitored annually on a percentage basis.

‌Governance

This Anti-Slavery and Human Trafficking Statement was approved by the Board of Polar Capital and is updated annually.

We reiterate our commitment to the Act.

David Lamb

David Lamb Chair

Polar Capital Holdings Plc

Approved by the Board on 25 September 2025 and signed on its behalf by David Lamb, Chair

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Polar Capital Holdings plc published this content on December 02, 2025, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on December 02, 2025 at 18:53 UTC.