MODERN SLAVERY ACT STATEMENT

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps taken by Cotswolds Capital Advisors Limited and its affiliated entities (together, "Cotswolds Capital" or "the firm") to ensure that modern slavery and human trafficking are not taking place within the firm's operations or supply chains. Cotswolds Capital is committed to acting ethically and with integrity in all of its business relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking find no place in any part of the firm's operations or the supply chains through which it sources services.

Cotswolds Capital is the trading name of three affiliated entities. Cotswolds Capital Advisors Limited is registered in England and Wales (Company Registration Number 16873557) with its registered office at 128 City Road, London, EC1V 2NX, United Kingdom. Cotswolds Capital Inc. is registered in the United States of America (EIN 61-2316210) with its registered office at 1430 Broadway, New York, NY 10018, USA. Cotswolds Capital Consulting L.L.C. is registered in the United Arab Emirates (MLN 1562611) with its registered office at Tajer 9051, Downtown, Dubai, United Arab Emirates. The firm operates as a discreet strategic advisory business across London, New York, and Dubai, providing senior-level counsel on complex transactions, capital relationships, negotiation, and independent strategic matters. The firm operates with a small number of senior principals and a limited number of active engagements at any given time.

Given the nature and scale of the firm's operations, Cotswolds Capital's supply chains are limited in scope. The firm does not manufacture goods, does not operate physical production or distribution facilities, and does not engage large numbers of third party contractors or suppliers. The firm's principal third party relationships are with providers of professional services including legal counsel, accountancy and tax advisory, information technology infrastructure and communications, office premises and facilities, and travel and hospitality services. These relationships are principally with established, reputable providers operating within the United Kingdom, the United States, and the United Arab Emirates, jurisdictions with developed legal frameworks governing employment rights and labour standards. The firm does not consider its supply chains to present a high risk of modern slavery or human trafficking given their limited scope, professional nature, and the jurisdictions in which they principally operate. Nevertheless, the firm takes its obligations under applicable law seriously and applies appropriate diligence to its supplier relationships.

Cotswolds Capital is committed to ensuring that its own operations and those of its supply chain reflect the highest standards of ethical conduct. The firm operates with the following principles in relation to modern slavery and human trafficking. The firm does not engage in, support, or knowingly benefit from forced labour, child labour, human trafficking, or any other form of modern slavery in any part of its operations or supply chains. The firm treats all individuals with whom it works, whether as employees, consultants, or contractors, with dignity and respect, and is committed to fair terms of engagement, fair remuneration, and safe working conditions. The firm expects all third party suppliers and service providers with whom it works to share these commitments and to conduct their own operations and supply chains in a manner consistent with the principles set out in this statement.

The firm takes the following steps to identify and address the risk of modern slavery within its operations and supply chains. Where engaging new suppliers or service providers, the firm takes reasonable steps to satisfy itself as to the nature and reputation of those suppliers, including, where appropriate, enquiring as to their own policies on modern slavery and employment standards. The firm engages principally with established, regulated, or professionally accredited service providers, which are themselves subject to applicable employment and regulatory standards in their respective jurisdictions. The firm keeps its supplier relationships under periodic review and would take appropriate action, including terminating a relationship, if credible evidence of modern slavery practices were identified.

Given the size and structure of the firm, formal training programmes of the kind operated by larger institutions are not presently in place. However, the firm's principals are aware of their obligations under the Modern Slavery Act 2015 and related legislation and take personal responsibility for ensuring that the principles set out in this statement are reflected in the firm's operations and supplier relationships. The firm will keep its approach to training under review as the firm's activities and scale develop.

The firm considers the risk of modern slavery occurring within its own operations to be low, given the professional nature of the firm, the limited scale of its workforce, the seniority and qualifications of its principals, and the jurisdictions in which it operates. The firm considers the risk within its supply chains to be similarly low, given the limited scope of those supply chains, the professional and regulated nature of its principal suppliers, and the jurisdictions in which those suppliers principally operate. The firm will keep this risk assessment under review and will take additional steps as may be appropriate if the nature, scale, or geographic scope of its operations or supply chains changes materially.

The firm will assess the effectiveness of its approach to modern slavery through the following indicators. No reports have been received from any employee, consultant, client, or third party raising concerns about modern slavery in any part of the firm's operations or supply chains. All principal supplier relationships are with established, reputable providers in jurisdictions with developed employment law frameworks. All individuals engaged by the firm as employees or consultants are engaged on fair, documented, and agreed terms.

This statement has been approved by the board of Cotswolds Capital Advisors Limited and signed by a director in accordance with section 54(7) of the Modern Slavery Act 2015.

Cotswolds Capital

1st July 2026

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