Modern Slavery Statement.

Introduction from the CEO

We are taking steps to combat slavery and human trafficking, and we are committed to improving our practices in achieving this.

Organisation’s Structure

Thesis Unit Trust Management Limited and its subsidiary undertaking, TUTMAN LLP and its associated company, Tutman Fund Solutions Limited (together “TUTMAN”) are authorised fund managers in the UK. Each is authorised and regulated by the Financial Conduct Authority. We are a part of the Thesis group, and our ultimate parent company is PSC Theo Topco Limited, a company incorporated in Guernsey. Thesis Unit Trust Management Limited has its head office in Chichester and, as at 30 April 2026, had 25 employees. Tutman Fund Solutions Limited has its head office in Glasgow and, had 83 employees as at 30 April 2026. Thesis Holdings Limited, a company incorporated in Jersey, is the immediate parent company of Thesis Unit Trust Management Limited and, since 30 June 2025, Tutman Fund Solutions Limited. Thesis Holdings Limited and Thesis Unit Trust Management Limited are the members of TUTMAN LLP.

Thesis Unit Trust Management Limited had a global annual turnover of over £196m as at 30 April 2026. Tutman Fund Solutions Limited had a global annual turnover over £53m as at 30 April 2026.

Our Business and Supply Chain

Whilst all our business is conducted in the UK from our offices in Chichester, West Sussex and in Glasgow and our suppliers are principally UK-based, we do have some suppliers (for example, of IT equipment, such as laptops to the Thesis group) and service providers (for example fund administrators and investment managers) who perform their work for us in other parts of the world. Tutman has not, during the 2025/2026 financial year, caried out an assessment of parts of its supply chain at risk as it has relied on due diligence responses from delegates and has not carried out any site visits or third party audits, relying on information publicly available from suppliers of IT equipment.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Human-Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due Diligence Processes for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk we have in place systems to:

Review supplier contracts to check they contain a clause obliging the supplier to comply with applicable law.
Identify and assess potential risk areas in our supply chains.
Mitigate the risk of slavery and human trafficking occurring in our supply chains.
Monitor potential risk areas in our supply chains.
Protect whistle blowers, encouraging a culture of openness and reporting of any suspected wrongdoing.

Supplier Adherence to our Values

We have zero tolerance to slavery and human trafficking. To ensure those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme. This consists of:

Ongoing due diligence of delegates on a regular basis as part of a risk-based monitoring programme.
As part of our monitoring programme assurance/evidence is sought that suppliers have appropriate polices/procedures in place.
We have identified those suppliers who provide some services in locations other than the UK.

The Group Environmental, Social and Governance Committee is responsible for modern slavery compliance matters. The Committee includes representatives from our Legal, Compliance, HR and Third Party Delegate Oversight teams.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff both on induction and as part of their ongoing development. Completion of a test by new staff members after attending training, tailored to TUTMAN, provided by the Head of Legal is tracked. External training is also provided to all Thesis staff within a two year period since the previous training in the form of a CISI training module and test. We also check whether our delegates provide training to their staff, especially where there are operations overseas.

Our Effectiveness in Combating Slavery and Human Trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains, which are considered appropriate:

Use of an international background screening service to check eligibility of employees to work in the UK;
Communication and personal contact with the next link in the supply chain and their understanding of, and compliance with, our expectations; and
Monitoring any incidents or allegations across our supply chains which conflict with our values by having slavery and human trafficking as an agenda item at regular service reviews.

Assessment of Effectiveness

The effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains is assessed annually by the Group Environmental, Social and Governance Committee, prior to submitting this statement for board approval. During the financial year, we improved our due diligence process carried out on our delegates in line with the statutory guidance issued by the Home Office in March 2025.

This statement, approved by the Thesis Unit Trust Management Limited board of directors on 27 August 2026, is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes TUTMAN’s slavery and human trafficking statement for the financial year ending 2026. It was approved by the Tutman Fund Solutions Limited board of directors on 3 September 2026.

David Tyerman, CEO
Thesis Unit Trust Management Limited

Dated 21 September 2026