Modern Slavery Act

Pursuant to section 54(1) of the Modern Slavery Act 2015 (the (“Act”), this statement  for  financial year ended 31 December 2023, made by Roscommon Analytics UK Limited, on behalf of itself, Beaufort Commodities LLP and Prizm Capital LLP (together ‘Roscommon UK’, “we”, “us” or “our”) outlining the steps we have taken during the financial year to understand the potential modern slavery risks related to our business, and to ensure that slavery and human trafficking is not taking place in our operations and supply chains.

Our Structure and Business

Roscommon Analytics UK Limited is a wholly-owned subsidiary undertaking of Roscommon Analytics LLC, a limited liability company incorporated in the state of Delaware. Roscommon Analytics LLC uses technology and analytics to generate profits in the energy commodity markets and operates as investment manager to the Roscommon Funds. Roscommon Analytics UK Limited, along with affiliates, Beaufort Commodities LLP and Prizm Capital LLP, provide investment management services to generate profits in the energy commodity markets, focused on the European natural gas market. Roscommon Analytics LLC has a global presence, with offices in New York, Houston, London, Berlin, Stockholm, Zug and Brisbane.

Risk Assessment and Management

Roscommon UK have a zero-tolerance approach to modern slavery, and respect for human rights is fundamental to our organisation and principles.  We are committed to and take seriously our responsibility to help protect, preserve and promote acting ethically and with integrity in all our business dealings and relationships to ensure that modern slavery, forced labour and human trafficking is not taking place anywhere in our own business or any of our supply chains. All our employees and our business relationships, suppliers and contractors have a responsibility to prevent, detect and report modern slavery in any part of our business or supply chains.

We believe that the sector and locations in which we operate represent a relatively low risk of modern slavery and human trafficking.

Policies and Procedures

Roscommon UK has Employee Handbooks and various policies in place that reflect our commitment to acting ethically and within the law. Our employees are expected to review, attest and adhere to such policies, which govern the business and are reviewed and, if necessary, restated annually and we implement the same approach with our employment practices and onboarding of new hires.

Roscommon UK takes great care when implementing relationships with suppliers, contractors and other vendors, and where necessary, endeavour to include appropriate provisions within our contractual arrangements with such service providers that ensures they are and remain fully compliant with applicable laws and regulations, which includes the Act. We have an expectation that all our business partners take appropriate steps to reduce modern slavery and human trafficking within their supply chains as well as maintaining all licenses, permits and consents which may be required for their business.

Roscommon UK will continue to explore initiatives to promote responsible business practices in our operations and supply chains. We recognise that our clients and employees expect Roscommon UK to be aware and proactive in this area and so we will continue to monitor our risks and procedures to ensure ongoing compliance.

This Modern Slavery Act Statement has been approved by the Board of Directors of Roscommon Analytics UK Limited and signed by designated person on 14/12/2023.

Name: Kevin M. Kelley

Title: Director/CEO

Roscommon UK Analytics UK Limited