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 Regit Topco Limited, a company incorporated in Jersey.  Thesis Unit Trust Management Limited has its head office in Chichester and, as at 30 April 2025, had 24 employees. Tutman Fund Solutions Limited has its head office in Glasgow and, as at 31 December 2024, had 76 employees.  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 £188m as at 30 April 2025.  Tutman Fund Solutions Limited had a global annual turnover over £47m as at 31 December 2024.

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.

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 consists of representatives from our Legal, Compliance, HR and TUTMAN 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. Following the acquisition of Tutman Fund Solutions Limited, all staff members will be invited to attended training, tailored to TUTMAN, provided by the Head of Legal and to complete a test.  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 business partners provide training to their staff, suppliers and service providers.

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:

  • 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.

Further Steps

The effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains is kept under annual review.  We are improving 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 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 2025.  It has also been approved by the Tutman Fund Solutions Limited board of directors as an interim statement following the acquisition.

 

David Tyerman, CEO                                                  Neil Coxhead, CEO

Thesis Unit Trust Management Limited                     Tutman Fund Solutions Limited

Signed 29 September 2025                                       Signed 30 September 2025