Nodem Limited Modern Slavery and Human Trafficking Statement

Introduction

Nodem Limited (“Nodem”, “we”) submits this statement under section 54 of the Modern Slavery Act 2015 (the “Act”). It sets out the approach that we have taken towards modern slavery since our founding in April 2024. ‘Modern slavery’ under the Act may refer to slavery, servitude, forced or compulsory labour and human trafficking. Nodem is committed to conducting its business without modern slavery and to taking appropriate and reasonable measures to minimise the risk of modern slavery occurring within its business and its supply chains.

Nodem’s structure, business, and supply chains

Nodem is a venture capital firm based in London, UK, investing in early-stage technology companies. Nodem is committed to ensuring that human rights abuses do not exist in any way in our business or supply chains.

Nodem manages venture capital investments and is undergoing an authorisation process with the Financial Conduct Authority as an alternative investment fund manager. Nodem is headquartered in London and has a small team that is expected to grow in 2025.

Nodem is committed to holding itself and its suppliers to high standards of business conduct and integrity and to being free from any slavery and human trafficking. Due to the nature of our business and operations, Nodem is at low risk of exposure to these issues, and our supply chain is not complex.

Risk assessment

As a provider of financial services, a large proportion of Nodem’s suppliers are considered to be low-risk professional services providers. For example, suppliers and vendors are engaged mainly for data delivery, software / hardware products and office supplies while our outsourced service providers are primarily utilised for fund administration services. Professional services are also used by Nodem, such as those provided by legal firms and accountants. Facilities management (cleaning and security), courier services and catering are potential areas of higher risk, although the current modern slavery risk is assessed as low. Despite the low risk, we seek to carefully manage the residual risk and any high risks emerging from new suppliers and/or vendors.

We are an investment manager for funds that invest in early and growth stage technology-focused businesses. As such, the risk of modern slavery within our portfolio company portfolio is generally considered to be low, however, further information on pre-investment due diligence is provided in the section ‘Investment Process’.

Training

Where relevant to their line of business and function, employees receive training on policies and procedures that pertain to products and services we provide to our clients. This includes training on the firm’s Anti-Bribery and Corruption, AML and KYC policies and practices. All newly hired employees will undergo training, and current employees will be assigned training on an ongoing basis.

Investment process

Our approach to sustainable action in the investment process is set out in fund documents and marketing material, which can be provided upon request.

For the companies in which we invest, we carry out legal, financial, commercial, and ESG due diligence before investment, including consideration of the nature of activities undertaken and the engagement of personnel directly or through the supply chain.

Approval procedures

This statement was approved by Nodem’s directors and Managing Partner.

Alex Branton

Managing Partner and Compliance Officer