These terms and conditions, together with any and all other documents referred to herein, set out the terms of use under which you may use this website, http://www.acquarius.gi (“our site”).  Please read these terms and conditions carefully and ensure that you understand them.  Your agreement to comply with and be bound by these terms and conditions is deemed to occur upon your first use of our site.  If you do not agree to comply with and be bound by these terms and conditions, you must stop using our site immediately.

  1. Definitions and Interpretation:
  • In these terms and conditions, unless the context otherwise requires, the following expressions have the following meanings:

content” means any and all text, images, audio, video, scripts, code, software, databases and any other form of information capable of being stored on a computer that appears on, or forms part of, our site; and
we/us/our” means Acquarius Trust Group a company registered in Gibraltar under number 12071 whose registered office is at Suite 2, Icom house, 1/5 Irish Town, Gibraltar GX11 1AA (“the service provider”).

  1. Information About Us

    Our site, http://www.acquarius.gi is owned and operated by us.

  2. Access To Our Site

    • Access to our site is free of charge.
    • It is your responsibility to make any and all arrangements necessary in order to access our site.
    • Access to our site is provided “as is” and on an “as available” basis.  We may alter, suspend or discontinue our site (or any part of it) at any time and without notice.  We will not be liable to you in any way if our site (or any part of it) is unavailable at any time and for any period.
  3. Intellectual Property Rights

    • All content included on our site and the copyright and other intellectual property rights subsisting in that content, unless specifically labelled otherwise, belongs to or has been licensed by us.  All content is protected by applicable united kingdom and international intellectual property laws and treaties.
    • Subject to sub-clause[s] 4.3 [and 4.6] you may not reproduce, copy, distribute, sell, rent, sub-licence, store, or in any other manner re-use content from our site unless given express written permission to do so by us.
    • You may:
      • Access, view and use our site in a web browser (including any web browsing capability built into other types of software or app);
      • Download our site (or any part of it) for caching;
      • Print [one copy of any] page[s] from our site;
      • Download extracts from pages on our site; and
      • Save pages from our site for later and/or offline viewing.
    • Our status as the owner and author of the content on our site (or that of identified licensors, as appropriate) must always be acknowledged.
    • You may not use any content saved or downloaded from our site for commercial purposes without first obtaining a licence from us (or our licensors, as appropriate) to do so.  [this does not prohibit the normal access, viewing and use of our site for general information purposes whether by business users or consumers.]
    • [Nothing in these terms and conditions limits or excludes the provisions of chapter iii of the copyrights, designs and patents act 1988 ‘acts permitted in relation to copyright works’, covering in particular the making of temporary copies; research and private study; the making of copies for text and data analysis for non-commercial research; criticism, review, quotation and news reporting; caricature, parody or pastiche; and the incidental inclusion of copyright material.]
  4. Links To Our Site

    • You may link to our site provided that:
      • You do so in a fair and legal manner;
      • You do not do so in a manner that suggests any form of association, endorsement or approval on our part where none exists;
      • You do not use any logos or trade marks displayed on our site without our express written permission; and
      • You do not do so in a way that is calculated to damage our reputation or to take unfair advantage of it.
    • You may link to any page of our site.
    • Framing or embedding of our site on other websites is not permitted without our express written permission.  Please contact us at info@acquarius.gi for further information.
    • You may not link to our site from any other site the main content of which contains material that:
      • Is sexually explicit;
      • Is obscene, deliberately offensive, hateful or otherwise inflammatory;
      • Promotes violence;
      • Promotes or assists in any form of unlawful activity;
      • Discriminates against, or is in any way defamatory of, any person, group or class of persons, race, sex, religion, nationality, disability, sexual orientation, or age;
      • Is intended or is otherwise likely to threaten, harass, annoy, alarm, inconvenience, upset, or embarrass another person;
      • Is calculated or is otherwise likely to deceive another person;
      • Is intended or is otherwise likely to infringe (or to threaten to infringe) another person’s privacy;
      • Misleadingly impersonates any person or otherwise misrepresents the identity or affiliation of a particular person in a way that is calculated to deceive (obvious parodies are not included in this definition provided that they do not fall within any of the other provisions of this sub-clause 5.4);
      • Implies any form of affiliation with us where none exists;
      • Infringes, or assists in the infringement of, the intellectual property rights (including, but not limited to, copyright, trade marks and database rights) of any other party; or
      • Is made in breach of any legal duty owed to a third party including, but not limited to, contractual duties and duties of confidence.
      • The content restrictions in sub-clause 5.4 do not apply to content submitted to sites by other users provided that the primary purpose of the site accords with the provisions of sub-clause 5.4.  You are not, for example, prohibited from posting links on general-purpose social networking sites merely because another user may post such content.  You are, however, prohibited from posting links on websites which focus on or encourage the submission of such content from users.
  5. Links To Other Sites Links to other sites may be included on our site.  Unless expressly stated, these sites are not under our control.  We neither assume nor accept responsibility or liability for the content of third party sites.  The inclusion of a link to another site on our site is for information only and does not imply any endorsement of the sites themselves or of those in control of them.
  1. Disclaimers

    • Nothing on our site constitutes advice on which you should rely.  It is provided for general information purposes only.
    • Insofar as is permitted by law, we make no representation, warranty, or guarantee that our site will meet your requirements, that it will not infringe the rights of third parties, that it will be compatible with all software and hardware, or that it will be secure.
    • We make reasonable efforts to ensure that the content on our site is complete, accurate, and up-to-date.  We do not, however, make any representations, warranties or guarantees (whether express or implied) that the content is complete, accurate, or up-to-date.
  2. Our Liability

    • To the fullest extent permissible by law, we accept no liability to any user for any loss or damage, whether foreseeable or otherwise, in contract, tort (including negligence), for breach of statutory duty, or otherwise, arising out of or in connection with the use of (or inability to use) our site or the use of or reliance upon any content included on our site.
    • To the fullest extent permissible by law, we exclude all representations, warranties, and guarantees (whether express or implied) that may apply to our site or any content included on our site.
    • [Our site is intended for non-commercial use only.]  If you are a business user, we accept no liability for loss of profits, sales, business or revenue; loss of business opportunity, goodwill or reputation; loss of anticipated savings; business interruption; or for any indirect or consequential loss or damage.
    • We exercise all reasonable skill and care to ensure that our site is free from viruses and other malware.  We accept no liability for any loss or damage resulting from a virus or other malware, a distributed denial of service attack, or other harmful material or event that may adversely affect your hardware, software, data or other material that occurs as a result of your use of our site (including the downloading of any content from it) or any other site referred to on our site.
    • We neither assume nor accept responsibility or liability arising out of any disruption or non-availability of our site resulting from external causes including, but not limited to, ISP equipment failure, host equipment failure, communications network failure, natural events, acts of war, or legal restrictions and censorship.
    • Nothing in these terms and conditions excludes or restricts our liability for fraud or fraudulent misrepresentation, for death or personal injury resulting from negligence, or for any other forms of liability which cannot be excluded or restricted by law.  For full details of consumers’ legal rights, including those relating to digital content, please contact your local citizens’ advice bureau or trading standards office.
  3. Viruses, Malware and Security

    • We exercise all reasonable skill and care to ensure that our site is secure and free from viruses and other malware.
    • You are responsible for protecting your hardware, software, data and other material from viruses, malware, and other internet security risks.
    • You must not deliberately introduce viruses or other malware, or any other material which is malicious or technologically harmful either to or via our site.
    • You must not attempt to gain unauthorised access to any part of our site, the server on which our site is stored, or any other server, computer, or database connected to our site.
    • You must not attack our site by means of a denial of service attack, a distributed denial of service attack, or by any other means.
    • By breaching the provisions of sub-clauses 9.3 to 9.5 you may be committing a criminal offence under the computer misuse act 1990.  Any and all such breaches will be reported to the relevant law enforcement authorities and we will cooperate fully with those authorities by disclosing your identity to them.  Your right to use our site will cease immediately in the event of such a breach.
  4. Acceptable Usage Policy

    • You may only use our site in a manner that is lawful.  Specifically:
      • You must ensure that you comply fully with any and all local, national or international laws and/or regulations;
      • You must not use our site in any way, or for any purpose, that is unlawful or fraudulent;
      • You must not use our site to knowingly send, upload, or in any other way transmit data that contains any form of virus or other malware, or any other code designed to adversely affect computer hardware, software, or data of any kind; and
      • You must not use our site in any way, or for any purpose, that is intended to harm any person or persons in any way.
    • We reserve the right to suspend or terminate your access to our site if you materially breach the provisions of this clause 10 or any of the other provisions of these terms and conditions.  Specifically, we may take one or more of the following actions:
      • Suspend, whether temporarily or permanently, your right to access our site;
      • Issue you with a written warning;
      • Take legal proceedings against you for reimbursement of any and all relevant costs on an indemnity basis resulting from your breach;
      • Take further legal action against you as appropriate;
      • Disclose such information to law enforcement authorities as required or as we deem reasonably necessary; and/or
      • Any other actions which we deem reasonably appropriate (and lawful).
    • We hereby exclude any and all liability arising out of any actions (including, but not limited to those set out above) that we may take in response to breaches of these terms and conditions.
  5. Privacy and Cookies

    Use of our site is also governed by our cookie and privacy policies, available from http://www.acquarius.gi/cookies and http://www.acquarius.gi/privacy  these policies are incorporated into these terms and conditions by this reference.

  1. Changes To These Terms and Conditions

    • We may alter these terms and conditions at any time.  [if we do so, details of the changes will be highlighted at the top of this page.]  Any such changes will become binding on you upon your first use of our site after the changes have been implemented.  You are therefore advised to check this page from time to time.
    • In the event of any conflict between the current version of these terms and conditions and any previous version(s), the provisions current and in effect shall prevail unless it is expressly stated otherwise.
  2. Contacting Us

To contact us, please email us at info@acquarius.gi.

  1. Communications From Us

    • If we have your contact details, we may from time to time send you important notices by email.  Such notices may relate to matters including, but not limited to, service changes and changes to these terms and conditions.
    • We will never send you marketing emails of any kind without your express consent.  If you do give such consent, you may opt out at any time.  Any and all marketing emails sent by us include an unsubscribe link.  If you opt out of receiving emails from us at any time, it may take up to 72hrs business days for us to comply with your request.  During that time, you may continue to receive emails from us.
    • For questions or complaints about communications from us (including, but not limited to marketing emails), please contact us at info@acquarius.gi
  2. Data Protection

    • Any and all personal information that we may collect will be collected, used and held in accordance with the provisions of the data protection act 1998 and your rights and our obligations under that act.
    • We may use your personal information to:
      • Reply to any communications you send to us;
      • Send you important notices, as detailed in clause 14;
    • We will not pass on your personal information to any third parties.
  3. Law and Jurisdiction

    • These terms and conditions, and the relationship between you and us (whether contractual or otherwise) shall be governed by, and construed in accordance with, English law.
    • If you are a consumer, any disputes concerning these terms and conditions, the relationship between you and us, or any matters arising therefrom or associated therewith (whether contractual or otherwise) shall be subject to the jurisdiction of the courts of Gibraltar, as determined by your residency.
    • If you are a business, any disputes concerning these terms and conditions, the relationship between you and us, or any matters arising therefrom or associated therewith (whether contractual or otherwise) shall be subject to the exclusive jurisdiction of the courts of Gibraltar.

 Client Account Terms & Conditions

  1. Client Account Money & Client Account Operations:

    • If client monies are to be held by Acquarius Trust Company Limited (or associated licensed companies) (‘Acquarius’), they will be held on a client account.
    • A “client account” is an account kept at a bank or building society for holding client money in accordance with the requirements of the Code of Conduct: Businesses Handling Client Monies. The Code of Conduct stipulates that:
    • The client account(s) of:
      • A sole trader must be in the name under which that person is known, whether that is their own name or the business’ name;
      • A partnership must be in the name under which the partnership is known;
      • An incorporated business must be in the company name, as registered at Companies House; and the name of the account must include the word “client” in full (an abbreviation is not acceptable).
      • A trust must be in the name registered at Companies House but with reference to the name assigned to the trust as per the trust deed, or alternatively the most recent deed of amendment changing the name assigned to the trust.
    • A client account must be a bank account or a building society account in Gibraltar.
    • There are two types of client account:
      • A “separate designated client account” which is an account for money relating to a single client, and which includes in its title a reference to the identity of the client; and
      • A “general client account” which is any other client account.
    • Monies held in a client account must readily be made available if requested, unless the client otherwise instructed at setup.
    • Monies held in a client account will only receive interest on the amount held when the monies in account exceed GBP 100,000 (One hundred thousand pounds sterling).
    • Client accounts are reconciled regularly and at least monthly to bank statements and clearly identify different client monies. Monies not reconciled will be investigated in a timely manner and efforts made to return money where it is no longer necessary to hold a deposit.
  2. Use Of A Client Account:

    • Client money are paid without delay into a client account and will be held in a client account.
    • Only client money may be paid into or held in a client account, except:
      • An amount paid in by Acquarius required to open or maintain the account; or
      • An advance from the business to fund a payment on behalf of a client in excess of funds held for that client such sum becoming client money upon payment into the account.
    • Client money will be returned to the client promptly, as soon as there is no longer any proper reason to retain those funds. Any payments received into the client account after distribution to the client will be paid to the client promptly.
    • A client will be informed verbally and confirmed by way of email, or similar, of the amount of any monies retained prior to the termination of the client account, and the reason for that retention.
    • A client will be informed at least annually of the amount of client money held for as long as the monies are held.
    • Banking facilities will not be provided through a client account.
    • Payments into, and transfers or withdrawals from a client account, must be in respect of instructions provided by the client relating to a provided invoice, or in relation to distribution to the underlying client.
  3. Withholding Monies From Client Account:

    • Blank agreements, nor any other types of agreement, cannot, and will not be used to hold client money outside a client account.
    • Upon request, part of a receipt of monies into a client account can be retained only if the entire payment is first placed in the client account before transferring the relevant part out and dealing with it in accordance with the client’s instructions.
    • Written instructions received from clients regarding client monies shall be kept for a minimum of six years.
  4. Receipt & Transfer Of Costs

    • When monies are received into the client account as payment or part payment of Acquarius invoices, or similar, the composition of the amount received will be determined without delay, and dealt with accordingly; and
      • If the sum comprises Acquarius invoices only, it will be transferred to the office account;
      • If the sum comprises only client monies, the entire sum must be placed in the client account; or
      • If the sum includes both invoices monies and client money, Chapter 7 will be followed.
    • If Acquarius invoices are to be paid from monies held in a client account, initially an invoice must be sent to and received by the client. The invoice should only include actions and duties performed by Acquarius or as cover for fees paid by Acquarius on behalf of the client that are included on the invoice to be paid from the client account.
    • Payments made out of a client account must be specific sums relating to invoices that have been provided to Acquarius prior to payment, and which can be covered by the amount held for the particular client. Round sum withdrawals on account of invoiced amounts are a breach of the Code For Business Handling Client Monies, unless such rounding (up) is made so as to ensure that any bank charges incurred by the receiver at the receiving bank are covered by the payment.
    • A payment for an Acquarius invoice with an agreed fee shall be paid into the office account. An “agreed fee” is one that is fixed and is evidenced in writing and has been accepted by the client.
  5. Disbursements:

    • Monies received for payment of Acquarius invoices is office money.
    • Monies received for holding in respect of the client is client money.
    • Monies received for other invoiced fees which have been incurred but not as yet paid is office money.
    • Monies received for future disbursements, ie. anticipated but not yet incurred, is a payment on account and is therefore client money.
  6. Receipt Of Mixed Payments:

    • A “mixed payment” is one which includes client money as well as office money.
    • A mixed payment must either:
      • Be split between a client account and office account as appropriate; or
      • Be placed without delay in a client account.
    • If the entire payment is placed in a client account, all office monies should be transferred out of the client account within 21 days of receipt.
  7. Withdrawals From A Client Account:

    • Client money may only be withdrawn from a client account when it is:
      • Properly required for a payment to or on behalf of the client;
      • Properly required for payment of a disbursement on behalf of the client;
      • Properly required in full or partial reimbursement of expenses paid on behalf of the client by Acquarius;
      • Transferred to another client account following agreement by the client;
      • Distributed to the client based on instructions provided by the client; or
      • Money which has been paid into the account in breach of the Code For Business Handling Client Monies (e.g. money paid into the wrong separate designated client account).
    • Office monies may only be withdrawn from a client account when it is:
      • Monies properly paid into the account to open or maintain it;
      • Properly required for payment of Acquarius invoices;
      • Part of a mixed payment placed in a client account under Chapter 6; or
      • Monies which have been paid into a client account in breach of the Code For Business Handling Client Monies.
    • Monies withdrawn in relation to a particular client from a general client account will not exceed the money held on behalf of that client.
    • Money held for a client in a separate designated client account will not be used for payments for another client account, unless both client accounts relate to the same client and the client specifically authorises the payment from the other client account.
    • Policies and procedures governing withdrawals from client accounts are in place, and transfers will be by way of a transfer to the office account when in relation to Acquarius invoices. The withdrawal will not be made in cash.
  8. Dealing With Complaints & The Office Of Fair Trading:

    • Every reasonable effort will be made to reach a speedy solution in the event of a dispute with a client regarding any client account issue. Should the need arise then a client’s formally appointed representative will be dealt with in the same way.
    • A complaints procedure is maintained and operated in an appropriate manner in accordance with regulations in Gibraltar.
    • All verbal and written complaints are logged. All complaints will be acknowledged in email / writing within 14 calendar days of receipt, and investigation of the issue of the complaint promptly undertaken. Where possible, a senior member of staff not directly involved in the transaction will lead the investigation.
    • If the client remains dissatisfied, the client will be told how their complaint may be pursued further either within your business, or externally should the need arise. Following the conclusion of the investigation, a written statement of the final view, which includes any offers made to the client (where relevant), will be sent to the client. This letter should also explain to the complainant how and where to refer the complaint externally should that be necessary.

Modern Slavery Statement

Modern Slavery:

Modern Slavery is an international crime affecting an estimated 40.3 million individuals around the world. This global issue transcends age, gender and ethnicities; it is estimated that 1 in 4 victims of Modern Slavery are children and that 3 quarters are women or girls. The term “Modern Slavery” refers to the offences of Human Trafficking, slavery, servitude, and forced or compulsory labour. This can then be considered under five headings:

•  The sexual exploitation of adults;
•  The trafficking of adults into conditions of labour exploitation;
•  The trafficking of adults into conditions of criminal exploitation;
•  The trafficking of minors into conditions of sexual, criminal or labour exploitation;
•  Other forms of exploitation.

“Human Trafficking” is a global crime that trades in people and exploits them for profit. “Human Trafficking” is defined in the UN Trafficking in Persons Protocol, which supplements the United Nations Convention against Transnational Organised Crime, as “the recruitment, transport, transfer, harbouring or receipt of a person by such means as threat or use of force or other forms of coercion, abduction, fraud or deception for the purpose of exploitation”. Although Human Trafficking often involves an international cross-border element, it is also possible to be a victim of Modern Slavery within your own country. There are several broad categories of exploitation linked to Human Trafficking, including sexual exploitation, forced labour, domestic servitude, organ harvesting, child related crimes, forced marriage and illegal adoption.

Modern Slavery includes victims who have been brought from overseas and vulnerable people in the UK, Isle of Man, Gibraltar and in Ireland who are forced to work illegally against their will. This is across many different sectors such as agriculture, hospitality (catering, etc.), construction, car wash services, retail and manufacturing (though COVID related restrictions may have seen some re-distribution to food supply chains and warehousing).

Estimates of the number of victims of Modern Slavery in the UK, Isle of Man, Gibraltar and Republic of Ireland have markedly increased in recent years. The 2018 Global Slavery Index estimated approx. 136,000 such individuals in the UK, with approx. 8,000 in the Republic of Ireland. The UK National Crime Agency (NCA) annual National Strategic Assessments of Serious and Organised Crime indicate significantly increasing numbers of Modern Slavery related cases referred through relevant reporting/referral mechanisms, and numbers of associated police investigations, each year. It has been estimated that globally Modern Slavery generates as much as $150 billion (£116 billion) in profits every year with more than a third of these profits generated in developed countries, including the UK, Isle of Man, Gibraltar and the Republic of Ireland.

The (UK) National Crime Agency (NCA) identified in their Indicators of Modern Slavery and Human Trafficking in the Accountancy Sector guidance what they consider the key areas where they deems there to be greater risk and visibility of Modern Slavery and Human Trafficking. This NCA guidance is included available at the above link.

Our Structure:

Acquarius Trust Company Limited (‘Acquarius’) is regulated by the Gibraltar Financial Services Commission. It also has strong connections to the Association of Trust & Company Managers (ATCOM) and the Gibraltar Association of Compliance Officers (GACO), as well as links with the Legal Services Regulatory Authority (LSRA), the Gibraltar Finance Centre (GFC), and Gibraltar Regulatory Authority (GRA). Acquarius employs 15 people in Gibraltar operating from offices in Icom House in Irish Town in Gibraltar.

Further details on the structure of Acquarius are available in our website at https://www.Acquarius.gi/

Our Policy:

The policy of Acquarius is to conduct all of our business in an honest and ethical manner, and to comply with all applicable legislation. We strive to ensure that neither Modern Slavery nor Human Trafficking supports our supply chain or our businesses; this objective is implicit in our policies and procedures. We aim for a zero-tolerance approach to violations of anti-slavery and Human Trafficking laws.

If breaches of these laws are found within our supply chain, we will look to support organisations in their efforts to comply with the applicable legislation. Acquarius will review the continuation of business with individuals and organisations found to be involved in slavery, Human Trafficking, forced or child labour and retains the right to cease business with such individuals and organisations on this basis.

Acquarius is committed to acting professionally and with integrity in all its business dealings and relationships worldwide.

In this context, Acquarius has created a dedicated Anti-Slavery and Human Trafficking Policy, and will review this policy and its operation in practice, at least on an annual basis.

Reporting Knowledge or Suspicion of Slavery or Human Trafficking:

All employees and partners within the firm have a statutory obligation to report knowledge or suspicion of slavery or Human Trafficking. Any genuine suspicion or knowledge of slavery or Human Trafficking is to be immediately reported to the relevant Engagement Partner and to the Head of Risk, who will decide what further action, if any, is deemed necessary. If the issue reported also relates to knowledge or suspicion of money laundering, terrorist financing, or proliferation financing then a further report is to be submitted to the Money Laundering Reporting Officer (MLRO). In addition, the Acquarius Whistleblowing Policy provides for alternative avenues for reporting, including in respect of suspicion or knowledge of slavery or Human Trafficking. Partners and employees who raise concerns of slavery or Human Trafficking in good faith may do so without fear of discrimination or reprisal.

These provisions do not replace any legal reporting or disclosure requirements. Where statutory reporting requirements and procedures exist, these must be fully complied with. During the financial year ended 30/09/2022 the Compliance Team of Acquarius did not receive any reports related to knowledge or suspicion of slavery or Human Trafficking.


Acquarius’s client acceptance and ongoing monitoring procedures include detailed risk assessments of each client from an anti-money laundering, counter-terrorist financing, counter-proliferation financing and wider risk perspective. These include a review for potential publicly available indications of previous or current involvement with criminality, including Modern Slavery and Human Trafficking.
Acquarius has included appropriate anti-slavery and Human Trafficking provisions into our terms of business with clients.

Employment Procedures:

Acquarius has procedures in place pertaining to our employment practices. Robust recruitment processes in line with Gibraltar employment law, including “right to work” document checks, contracts of employment, and checks to ensure all employees are above minimum working age, whilst always considering market-related pay and reward, which is reviewed annually and in line with local figures.

Supply Chain/ Procurement:

We recognise that our firm is exposed to a greater slavery and Human Trafficking risk when dealing with suppliers of products and services, particularly those who have operations and suppliers in other territories. However, Acquarius considers that we, and the majority of our suppliers, are not in industries with a high risk of modern day slavery. In addition, our supply chains are primarily confined to countries with a relatively lower risk of modern day slavery and Human Trafficking.

From a risk management perspective, we have identified areas we need to develop in conjunction with our supply chain, and a risk-based approach is under development. This approach is to include identifying and reviewing suppliers and vendors that fall within industries and/or countries that can carry higher risk, including in respect of modern day slavery and Human Trafficking. Acquarius has developed measures to assist in the review and management of these areas of risk, including an enhanced supplier and vendor take-on review and ongoing monitoring process, which is handled by our Compliance Team.


We want to help our employees, partners, clients and suppliers to understand more about these issues and understand how to report any suspicions they may have related to Modern Slavery and Human Trafficking.

The topic of Modern Slavery, and our associated Anti-Slavery and Human Trafficking Policy, continues to be flagged in the induction training undertaken by new staff members starting with Acquarius. We flag each update of this Statement and of the associated Anti-Slavery and Human Trafficking Policy to all staff members, and we continue to consider on an ongoing basis ways to further enhance awareness on the issues of slavery and Human Trafficking and of Acquarius’s Anti-Slavery and Human Trafficking Policy among relevant employees and partners.

Looking Forward:

Acquarius will continue to develop and implement the measures mentioned above in respect of our supply chain. Our approach to Modern Slavery and Human Trafficking risk will continue to evolve and we will continue to mitigate these risks through the provisions mentioned above during 2023 and beyond. Acquarius shall take responsibility for this statement and its objectives, and this statement will be reviewed and updated as appropriate.