pg. 2

"To assess the modern slavery risks in our Investment Portfolios, we relied on the analysis and data in the Global Slavery Index (“GSI”) published by the Walk Free Foundation (most recently in 2018) and the Global Estimates of Modern Slavery (“GEMS”) report released by the International Labour Organisation and the Walk Free Foundation in 2017. The GSI provides a country by country ranking across three dimensions of modern slavery risk: the number of people in modern slavery, the actions governments are taking to respond, and the factors that make people vulnerable. The GEMS indicate the main industries at risk of forced labour (such as mining, manufacture, agriculture/forestries/fishing, construction, healthcare services, IT services and software).

Based on the country rankings in the GSI, we reviewed the Investment Portfolios by undertaking a thematic risk assessment to identify potential exposures to countries stated in that report to have elevated modern slavery risks. Our analysis found that certain of the Investment Portfolios invest in companies which are located in or exposed to countries which are believed by GSI to be at a higher risk for modern slavery (in geographies such as Asia, South America, the Middle East and South Africa)."

I have changed the answer to No because the above evidence refers to assessing risk within their investment portfolio rather than a process of identifying risk prior to investment. Page 4 describes Responsible investment but also seems to refer to existing investee companies and how they engage with them to address modern slavery risks.