Modern Slavery Act Statement 2023
CITIC Securities International Company LimitedApril 2024

Introduction
This Statement is being published in accordance with Section 54 of the UK Modern Slavery Act 2015 for thefinancial year ending December 2023. It outlines the steps that CITIC Securities International Company Limited andits subsidiaries (“CSI”) has taken during the year to ensure that modern slavery and human trafficking is not taking
place in our supply chain or any part of our business, as well as future plans in this regard. This Statement applies
to CSI’s global operations and supply chains.
CSI is committed to supporting the protection and advancement of human rights in our business and supply chains.
We have a zero tolerance approach to modern slavery and human trafficking in all its forms.
Our Business
CSI is a global brokerage and investment group. Headquartered in Hong Kong, CSI’s global network spans
locations across Asia, Australia, Europe and the United States. Renowned for presenting differentiated investment
ideas, we work closely with asset managers, corporates, governments and family offices to provide financialservices. Through our parent company, CITIC Securities Company Limited, we have unrivalled access to China for
corporate finance, capital markets and investment opportunities. We leverage out-bound capital flows and assist
global investors in navigating China’s capital markets. CSI’s staff of some 2,000 individuals define our culture of
excellence, innovation, integrity, inclusion and celebration.
A robust approach to governance and risk guide our principles and corporate culture. Our governance isreinforced through CSI’s business principles, corporate governance framework, compliance, risk management,
product and technology innovation, client engagement, staff training, diversity and inclusion.
As a financial services provider, CSI predominantly employs professionally qualified and highly skilled staff. As such
we consider the risk of modern slavery and human trafficking within our own business to be low.
Our Approach
CSI’s approach towards the ensuring that modern slavery is not taking place in our business or supply chain isreflected in a number of policies and practices.
Policies
CSI’s Employee Handbook and Employment legislation
The Employee Handbook sets out CSI’s approach towards its staff. CSI is an equal opportunities employer and iscommitted to providing equal opportunities throughout employment including in the recruitment, training anddevelopment of employees. CSI aims to ensure that it will not unlawfully discriminate against job applicants,
employees of the company, workers or contract workers on the grounds of their age, disability, gender
reassignment, marriage or civil partnership, pregnancy or maternity, race (which includes colour, nationality andethnic or national origins), religion or belief, sex or sexual orientation (the protected characteristics).

It is, therefore, CSI’s policy to make every effort to provide a working environment free from harassment,
intimidation and discrimination which the Company considers unacceptable behaviour. All employees are required
to attest to the CSI Code of Conduct on an annual basis.
The Employee Handbook CSI takes account of the specific employment legislation in each of the jurisdictions inwhich it operates and reviews these requirements on an ongoing basis
Code of conduct
The CSI Code of Conduct provides advice and guidance on how we should conduct business, ethically, and inaccordance with all applicable laws and regulations. The Code is not an exhaustive set of rules but rather a set ofguiding principles. All employees are required to attest to the CSI Code of Conduct on an annual basis.
Anti-Money Laundering and Prevention of Terrorist Financing Policy
CSI’s Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) applies to all its staff andrepresentatives and sets out the firm’s policies and procedures to prevent the occurrence of financial crimes andthe movement of money which has derived from the proceeds of any crime. CSI’s policy is to actively preventmoney laundering, tax evasion and terrorist financing and any activity that might facilitate these crimes, whilst
conducting its business in line with all applicable AML/CFT laws and high ethical standards across all jurisdictions,and where possible and practicable obliging client’s confidentiality and data protection.
Anti-Bribery and Corruption Policy
Bribery and corruption are serious crimes which undermine the rule of law, lead to injustice and can adversely
impact economic development. These activities threaten good governance, sustainable development and fairbusiness practice. CSI is committed to ensuring that persons or entities associated with CSI do not attempt toobtain or retain business for CSI in an unlawful manner. In particular, CSI seeks to prevent any person or entity
associated with it from undertaking any conduct that may be construed as giving or offering bribes with a view toobtaining or retaining business or any other advantage for CSI. The objective of this policy is to ensure that CSI
complies with all applicable laws and regulations to protect the reputation of the firm.
Whistleblowing Policy
CSI’s Whistleblowing Policy relates to complaints or reports regarding actual or potential misconduct or wrongdoing involving a violation of laws, regulations, codes of conduct, internal policies or procedures (whether suchviolation has occurred, is occurring or is likely to occur), any attempt to conceal, or deliberate concealment of, anysuch violation, possible fraud, deception, theft, forgery or corruption, actions which are unprofessional,
inappropriate or in conflict with a general understanding of what is right and wrong and any other matter deemed
to be unethical or detrimental to the reputation of CSI.
CSI also has a global Speak-Up hotline providing employees with a mechanism to report concerns regarding
potentially unlawful, improper or questionable conduct, including with regard to vendors or third parties.
Supply Chain and Due Diligence Process
CSI’s supply chain relates to our global financial services business and includes the supply of personnel, and goods
and services to support the services that we in turn provide to our clients and staff. The services provided to us
include, amongst others, cleaning, catering, security and printing services, professional services such asaccountancy, tax, regulatory, insurance and legal advice, and premises and technology (systems, software andhardware equipment, including telecommunications services) and travel services.
CSI’s vendor due diligence process uses a risk based assessment approach encompassing screening reviews ofpublic records including a review of significant litigation and regulatory actions and negative news stories. ThisApril 2024.