CELF Advisors LLP
Modern Slavery Act Statement
Introduction
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Modern SlaveryAct”). It sets out the steps that we, CELF Advisors LLP ("CELF"), have taken to seek to ensure that modern
slavery and human trafficking are not taking place in our business and supply chains during the mostrecently ended financial year.
Organisation’s Structure
CELF is a UK-based affiliate of The Carlyle Group Inc. (“Carlyle”), one of the largest and most diversified
multi-product global alternative asset management firms in the world, offering specialised investment funds
and other investment vehicles that invest across a range of industries, geographies, asset classes andinvestment strategies. Carlyle operates its business through CELF and other Carlyle-affiliated investment
advisers. CELF’s principal place of business is in London and it is authorised and regulated by the Financial
Conduct Authority (FCA) in the UK. CELF provides collateral management services to European structured
credit funds and also provides sub-advisory services in respect of certain other Carlyle-advised funds.
Supply Chain
As an investment advisory firm, we have relatively limited supply chains. Consequently, our assessment of
the risk of modern slavery and human trafficking is based on the nature of our industry and the limited
extent of our supply chains. In connection with our business activities, we engage external parties to provide
support services such as office cleaning and IT development suppliers. We also outsource some ancillaryfunctions relating to our business to professional service firms, such as law firms and accountancy firms.
As per Carlyle’s Procurement Policy, all written contracts include terms to ensure compliance with applicableanti-corruption and anti-bribery laws. Certain business partners are also required to certify that they are incompliance with the minimum standards of anti-corruption and anti-bribery set forth in these contracts.
Carlyle uses the SAP Ariba system globally for the processing of all purchase orders and invoices. This system
supports the performance of appropriate due diligence to be on any new suppliers.
Measures to Address Modern Slavery and Human Trafficking
Global Measures
In connection with our affiliation with Carlyle, we are subject to a number of global measures designed toaddress the social and governance risks related to Carlyle’s business as a global investment firm, including,for example, the risk of suppliers or business partners engaging in illegal or improper conduct. For example,
such measures include the following policies and procedures:

CELF Advisors LLP, Registered in England and Wales, Partnership Number OC357078, Registered Office: 1 St James’s Market, London SW1Y 4AH
CELF Advisors LLP is authorised and regulated by the Financial Conduct Authority•••the Carlyle Code of Conduct, which provides Carlyle personnel with guidelines for proper businessconduct;
the Carlyle Policy on Compliance with Anti-Corruption and Anti-Bribery Laws, which provides
Carlyle personnel with guidelines for compliance with applicable anticorruption laws; andthe Carlyle Whistleblower Policy, which outlines ways in which individuals can report illegal orunethical behaviour.

Further, managing environmental, social and corporate governance (ESG) issues is integral to how Carlyle
invests and conducts its business. Among other things in support of these efforts, on an annual basis,Carlyle prepares an ESG Review, which discusses the firm’s ESG responsibilities and activities. A copy of thisreport can be accessed at the following link: https://www.carlyle.com/sustainability.
Carlyle has developed a systematic approach to ESG due diligence on investments, which is led by theSustainability team. Generally, all global private equity and global credit deals are required to include anESG assessment. This seeks to ensure that significant ESG issues are identified and mitigated at an earlystage, reducing any risk of labour or human rights issues where applicable within Carlyle portfolio
companies. Please see our ESG policy for more details https://www.carlyle.com/sites/default/files/CarlyleESG-Policy.pdf.
Additionally, Carlyle places great emphasis on diversity and inclusion (DEI). The Carlyle DEI Council, whichis comprised of senior global leaders, meets at least three times a year to review and refine the firmwide
DEI Strategy. Additionally, Carlyle’s DEI Leadership Network is a coalition of Carlyle’s portfolio company
CEOs who share resources, insights, and learnings to advance diversity, equity and inclusion within theirrespective companies.
CELF-Specific Measures
Further, we have adopted a Modern Slavery and Human Trafficking Policy (the "MSA Policy"), which seeks
to identify and manage modern slavery-related risks in our business and supply chains. In adopting thispolicy, we seek to accomplish the below overarching objectives:• Continuing to develop systems to (a) identify, assess and monitor potential higher risk areas in our
supply chains, (b) mitigate the risk of slavery and human trafficking occurring in our supply chainsthrough enhanced contract term controls (as applicable and wherever possible), (c) train ouremployees as to these risks and the need to manage them and (d) protect whistleblowers.
• Where possible, building long-standing relationships with our key suppliers and ensuring that
expectations of business behaviour are clear and consistent.
Implementation
Our Legal & Compliance, Human Resources, Corporate Accounting and Office Services teams work together
to implement the objectives considered in this statement and consider ongoing enhancements to theprocesses and controls in place.
EffectivenessWe will continue to monitor our compliance with this statement and our policies, in the following ways:

CELF Advisors LLP, Registered in England and Wales, Partnership Number OC357078, Registered Office: 1 St James’s Market, London SW1Y 4AH
CELF Advisors LLP is authorised and regulated by the Financial Conduct Authority

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training on modern slavery (see below);ongoing implementation of the MSA Policy;
maintenance of systems for supply chain identification, including modern slavery enquiries andcontrols within Carlyle’s vendor management and procurement policies; andongoing review of existing and new supply chains.

Training and Communication
As necessary, training with respect to the MSA Policy is being provided to educate relevant employees on
the importance of implementing and enforcing effective systems in an effort to ensure slavery and humantrafficking is not taking place in our supply chain.
Further, training on anti-corruption and anti-Bribery is provided to all Carlyle employees globally on anannual basis.
Ongoing Monitoring
If issues are identified in relation to modern slavery, these will be dealt with by the Legal & ComplianceTeam or as otherwise specified by applicable Carlyle policies and procedures.
This statement is reviewed annually. In accordance with section 54 of the MSA, CELF Advisors LLP have
prepared this Statement for their most recent financial year (ending 31st December 2023).
The CELF board approved this most recent statement. It has been signed by a designated member and asigned copy is available upon request.

CELF Advisors LLP, Registered in England and Wales, Partnership Number OC357078, Registered Office: 1 St James’s Market, London SW1Y 4AH
CELF Advisors LLP is authorised and regulated by the Financial Conduct Authority