pg. 3

"Criteria 3: Addressing modern slavery risks in operations and supply chains

Modern slavery risks in operations

Argo’s operations involve the internal management of a portfolio of predominantly ASX-listed, Australian shares. We recognise that it is possible that investee companies may have elements of modern slavery in their operations and/or supply chains.

To ensure that this risk is minimised Argo has a stringent investment process. Argo’s investment process includes the integration of non-financial factors such as Environmental, Social and Governance (ESG) issues into its assessments. Potential and future growth implications arising from ESG issues are factored into Argo’s forecasts of an investee company’s long-term valuation. In particular, Argo’s ESG Investment Statement3 sets out the social considerations that the investment team considers in its qualitative assessment of a company and these include modern slavery risks. The majority of Argo’s investee companies are large ASX listed companies with rigorous corporate governance practices. Many are also likely to qualify as reporting entities themselves under the Act.

Argo actively engages with the management of investee companies regarding any perceived ESG risks or concerns, but as a passive investor we have limited ability to control the actions of investee companies. We note that Argo is not required under the Act to directly monitor or report on the operations and supply chains of its individual investees."

Unclear whether this investment process is done prior to investing. Therefore, I have changed the answer to No.