Hudson Bay Capital UK LLP
Modern Slavery and Human Trafficking Statement
This statement is made by Hudson Bay Capital UK LLP (“HBC UK LLP”, the “Firm”, “we” or “our”) pursuant to section 54 of the Modern Slavery Act 2015 (the “MSA”) and covers the financial year ended 31 December 2025.
Our business and structure
HBC UK LLP is the UK affiliate of Hudson Bay Capital Management LP, a global investment management firm headquartered in New York that pursues a multi-strategy investment approach (together with its affiliates, “Hudson Bay Capital”). The Firm operates from a single office in London and provides sub-advisory and related services to Hudson Bay Capital. It is authorised and regulated by the Financial Conduct Authority. Our workforce is small, office-based and highly skilled, and our personnel are remunerated above statutory minimums.
Our supply chains
As a services business, we do not manufacture, import or distribute goods and have no physical supply chain in the conventional sense. Our procurement is overwhelmingly made up of services from other financial services and professional firms, including brokerage and execution, market data and technology, legal, audit, accounting and consultancy providers. These counterparties are typically themselves regulated or professionally supervised, engage skilled staff, and operate in the UK or other jurisdictions where the prevalence of modern slavery is low. The exception is a small number of facilities-related services supporting our London office, such as cleaning and catering, which operate in sectors where the risk of labour exploitation is recognised to be higher.
Risk assessment
Taking into account the sector in which we operate, the jurisdictions from which we source, and the profile of our workforce and suppliers, we assess the overall risk of modern slavery and human trafficking in our operations and supply chains as low. Such residual risk as exists is concentrated in the facilities services described above rather than in our core service providers, and our diligence effort is weighted accordingly. Our vendor management function undertakes due diligence on our vendors, and our compliance function separately carries out targeted vendor due diligence each year, selecting vendors by reference to risk.
Policies and due diligence
The Firm maintains a framework of policies and procedures addressing its legal and regulatory obligations, including in relation to anti-money laundering, anti-bribery and corruption, whistleblowing, and the escalation of incidents and issues. Our Employee Handbook sets out our expectations on conduct, equal opportunities, non-harassment and working conditions. We expect our suppliers to comply with all laws applicable to their businesses wherever they operate, and our vendor review process is designed to alert the Firm to potential higher-risk relationships so that they receive closer attention.
We consider the risk of modern slavery or human trafficking arising within our own workforce to be negligible, and nothing has come to our attention to suggest otherwise.
Training and awareness
Personnel with responsibility for procurement and vendor management, both within the Firm and elsewhere in Hudson Bay, have been made aware of the requirements of the MSA, and modern slavery awareness features in the periodic compliance training delivered to our staff. We do not currently deliver training to staff within our supply chains. Our suppliers are predominantly regulated or professional firms that operate their own compliance and training programmes and consequently, we have not judged direct training of supplier staff to be necessary or proportionate.
Effectiveness
We monitor the effectiveness of these arrangements by reference to indicators we consider appropriate to a business of our size and risk profile: whether any instances of, or concerns relating to, modern slavery or human trafficking have been identified or reported, including through our whistleblowing channels; the completion of our scheduled vendor due diligence; and the completion of compliance training by our staff. No such instances or concerns were identified or reported during the financial year, and we will keep these arrangements under periodic review.
Approval
This statement is made pursuant to section 54(1) of the MSA and constitutes the slavery and human trafficking statement of HBC UK LLP for the financial year ended 31 December 2025. It has been approved by the members of HBC UK LLP.
