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"As a founding signatory to the UNPRI (United Nations

Principles for Responsible Investment) we recognise

and embrace our duty to act as responsible longterm stewards of our clients’ assets. We integrate

environmental, social and governance (ESG) issues,

including human rights issues and modern slavery,

into our investment analysis and decisions across asset

classes. We use our influence as a large asset manager to

engage with the companies we invest in to drive positive

change in their behaviour. We do this through research

and active ownership, exclusions and driving industry

change.

Below are examples of some of our investment actions

on human rights including modern slavery:

• We support and use the Corporate Human Rights

Benchmark (CHRB), which we helped found in 2013, to

assess companies’ performance on how they embed

human rights, including tackling modern slavery. We

include the CHRB results in our ESG research and voting

policy to ensure we hold companies that scored poorly

accountable at their Annual General Meeting (AGM).

In 2019 we voted against 32 companies and we were

pleased to see that 23 of these have improved. In 2020

we have voted against [97] companies. We also worked

with the Investor Alliance for Human Rights to send an

investor statement to all companies scoring 0 on all

human rights due diligence indicators, representing over

US$4.5 trillion in assets under management.

• To help ensure FTSE350 companies are meeting

minimum requirements within the Modern Slavery

act we supported the Business and Human Rights

Resource Centre and other collaborators such as

Rathbones to identify a list of 38 companies who have

failed to meet the minimum reporting standards of

the Act. We have written to these firms requesting

compliance.

• We are also working with the charity fund manager

CCLA and a group of investors on the “Find it, Fix it,

Prevent it” project which goes beyond minimum

compliance of the law and instead focuses on how

companies are working to tackle modern slavery in

their operations.

• Aviva Investors recognise that some human rights

issues are market failures and therefore need

addressing through government and regulatory

action. We engage with governments and regulators,

particularly in our key markets, to call for and support

policy action to tackle these challenges, such as

through mandatory disclosure and mandatory

human rights due diligence.

"