Regulatory Disclosures
Our commitment to preventing modern slavery and human trafficking
Effective date: 1 July 2026
1,Our commitment
AG (Australian Gulf) Capital Limited ("we", "us", "our" or the "Firm") has zero tolerance for modern slavery and
human trafficking in any form. We are committed to acting ethically and with integrity in all our business
dealings and relationships, and to implementing and enforcing effective systems and controls to help ensure
that modern slavery is not taking place anywhere in our own business or in our supply chains.
Although we are not required to publish a statement under a specific modern-slavery reporting law, we make
this statement voluntarily to set out the steps we take to identify, prevent and mitigate the risks of modern
slavery, forced labour, servitude, human trafficking and child labour (together, "modern slavery").
2,Our business, structure and operations
We are an alternative asset manager established in the Abu Dhabi Global Market and authorised and regulated
by the Financial Services Regulatory Authority (FSRA) of the ADGM. We operate primarily from Abu Dhabi,
United Arab Emirates, providing our services to professional and institutional clients.
3,Our supply chains
As a financial-services firm, our supply chains are focused on the procurement of professional and business
services rather than physical goods. They typically include providers of technology and data, professional
advisers, fund administration and custody, market data, facilities management, recruitment, travel and office
supplies. We consider the risk of modern slavery within our direct operations and higher-value professional
supply chains to be low, while recognising that risk can arise in lower-tier and outsourced services.
4,Policies
This statement is supported by our broader governance and conduct framework, which may include our code
of conduct, ethics and anti-bribery and corruption policies, whistleblowing policy, recruitment and human-
resources policies, and procurement and third-party due-diligence procedures. Together these are designed to
promote ethical conduct and to make clear that we expect the same standards from those we do business
with.
5,Due diligence and risk assessment
We seek to manage modern-slavery risk through our onboarding and procurement processes. Depending on
the nature and risk profile of a relationship, our measures may include:
• assessing new and existing suppliers and counterparties, with enhanced scrutiny for higher-risk sectors
and jurisdictions;
• incorporating expectations regarding ethical conduct and legal compliance into our contractual
arrangements where appropriate;
AG (Australian Gulf) Capital Limited
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• following fair and lawful recruitment practices, including verifying the identity and right to work of our
personnel and paying at least applicable minimum wages; and
• providing channels through which concerns can be raised confidentially.
6. Assessing effectiveness
We keep our approach under review and, where appropriate, use indicators such as the completion of due
diligence on higher-risk suppliers, staff completion of relevant training, and the number and nature of concerns
raised, to assess the effectiveness of our measures and to identify improvements.
7. Training and awareness
We seek to ensure that relevant personnel understand the risks of modern slavery and know how to identify
and report concerns, through induction and periodic awareness activities proportionate to their roles.
8. Raising concerns
Anyone who suspects that modern slavery is occurring in our operations or supply chains is encouraged to
report it through our whistleblowing arrangements or by contacting us at info@ausgulf.com. Concerns may be
raised confidentially, and we do not tolerate retaliation against anyone who raises a concern in good faith.
9. Approval
This statement has been approved by the Board of Directors (or governing body) of AG (Australian Gulf) Capital
Limited and will be reviewed and, where necessary, updated on a periodic basis.
