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Modern Slavery Statement

Updated 26 September 2019

Introduction

In acknowledgment of Yacuna AG (the "Firm”) responsibilities under the Modern Slavery Act 2015 (the "Act") and its support of the goals set forth in the Act, the Firm has produced the following Modern Slavery Statement (the "Statement") for the years ending 31 December 2021, setting out the Firm's policies and procedures in respect of modern-day slavery.

Business

The Firm is based in Switzerland. The Firm provides research and development services to certain affiliate entities.

Supply Chain

Due to the nature of the Firm's business, the overall risk for the facilitation of modern slavery and human trafficking in our business or amongst our suppliers is low. The Firm's supply chain primarily includes exchanges, trading venues, brokers, market data providers, and industry professionals, who are themselves heavily regulated. The Firm also utilizes other miscellaneous suppliers such as cleaners, caterers and maintenance workers on a customer basis to maintain facilities and meet company needs.

Due Diligence Process and Policies Concerning Modern Slavery

The Firm strongly condemns the use of slavery and human trafficking in any circumstance.

As part of the Firm's employee onboarding process, new employees are made aware of this Statement as well as the Firm's Open-Door Policy, Whistleblowing Policy, and Code of Business Conduct and Ethics (the "Policies"). The Policies actively encourage employees to speak freely with management about any questions or concerns they may have concerning their role, the Firm's conduct, or a supplier. All Firm employees can easily access the Policies in the Employee Handbook, which is located on the Firm's intranet.

As part of the Firm's due diligence process, the Firm has established a new Supplier Code of Conduct (the "Code"). Both existing and new suppliers will be required to acknowledge the Code as a condition to entering or continuing any contractual relationship with the Firm.

Looking Ahead

The Firm remains committed to maintaining strong policies and procedures to identify and prevent modern slavery and human trafficking in its business and supply chains as well as will continue to review and enhance these policies and procedures over the course of the financial year.

Approval

This Statement has been reviewed and approved by the Firm's board of directors for the 2020-2021 year.

For and on behalf of the board of directors of Yacuna AG

President of the board of directors

26 September 2019