This statement is made by Ingenious Capital Management Holdings Limited and its subsidiaries (“Ingenious”) pursuant to section 54 of the UK Modern Slavery Act 2015. Ingenious recognises its responsibilities under the Modern Slavery Act to take a robust approach to slavery and human trafficking.


Modern slavery is a violation of human rights and takes different forms such as servitude, slavery, forced and compulsory labour and human trafficking. Modern slavery entails the deprivation of a person’s liberty by another for the purposes of exploiting them for personal or commercial gain.

As a firm we are committed to preventing slavery and human trafficking in our own business and our corporate activities and to ensuring that our supply chains are free from slavery and human trafficking.

The organisation

Ingenious is an investment group which specialises in the media, infrastructure, real estate and education sectors. We act as a bridge between finance and business by identifying, funding and managing compelling investment opportunities. We raise capital to fund these opportunities from a range of partners including high net worth individuals, institutions, corporates, family offices and other financial institutions.

A risk-based assessment of our supply chain indicates that the risk of slavery and the risk of human trafficking is low. Given the nature of our business, we believe our exposure to modern slavery or human trafficking to be limited, however compliance measures are in place to monitor this frequently within our own business and our supply chains. We have put in place a robust process for the consideration, approval and monitoring of our outsourcing arrangements in order to exercise due skill, care and diligence when entering into, managing or terminating any outsourcing arrangement. We also conduct appropriate due diligence on any person we accept money from or invest money with. In line with internal risk management processes Ingenious will continue to assess, monitor and manage risks on an ongoing basis.

Ingenious encourages the use of its Whistleblowing policy for our employees, customers and partners to report any concerns including those of slavery and/or human trafficking and all concerns are investigated thoroughly. Ingenious uses only specified and reputable recruitment agencies to source employees and verifies the practices of any new agency before accepting workers from that agency.

Ingenious ensures its employees are trained on an ongoing basis with regards to regulatory and personal responsibilities.

Ingenious will refrain from entering into business and/or will discontinue current business with any organisation that is found to be in breach of the Modern Slavery Act 2015. There have been no reported instances of slavery or human trafficking within our supply chains during the preceding twelve months.