Anti-Slavery & Ethical Standards

Statement on Modern Slavery and Ethical Conduct

SINNLA CS FUNDS Limited is committed to conducting its business in an ethical, responsible and lawful manner.

While Singapore does not impose a statutory reporting obligation equivalent to the UK Modern Slavery Act 2015, the Company maintains a zero-tolerance approach to forced labour, human trafficking and exploitative employment practices.

Our Business Structure

SINNLA CS FUNDS Limited operates as an investment-focused entity. The nature of its activities means that it does not maintain complex operational supply chains.

The Company primarily engages regulated financial and professional service providers, including but not limited to:

• banks and custodians

• fund administrators

• technology and data providers

• accounting firms

• legal advisors

• corporate service providers

These counterparties are generally established in regulated jurisdictions.

Risk Assessment

Given the structure of the Company’s operations, the risk of modern slavery within its direct business activities is considered low.

Nevertheless, SINNLA CS FUNDS Limited takes a proportionate, risk-based approach to:

• counterparty due diligence

• onboarding processes

• governance and compliance oversight

Where appropriate, ESG and reputational considerations may be included in due diligence processes.

Employment & Workplace Standards

SINNLA CS FUNDS Limited is committed to maintaining fair and lawful employment practices. Where applicable, internal policies address:

• equal opportunity principles

• anti-discrimination standards

• lawful right-to-work verification

• professional conduct expectations

• mechanisms for raising concerns

Employees and associated personnel are encouraged to report any concerns regarding unethical practices through appropriate internal channels.

Ongoing Commitment

The Company remains committed to continuously reviewing its governance framework and ethical standards to ensure that its policies remain proportionate, effective and aligned with international best practice.

This statement reflects the Company’s position for the financial year ending 31 December 2025 and has been reviewed and approved by the Board of Directors of SINNLA CS FUNDS Limited.

Approved by:
Christian Bodenbinder
Director
SINNLA CS FUNDS Limited

Date: January 2026