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“Baillie Gifford operates a zero-tolerance approach to modern slavery and human trafficking. For those in our supply chain and contractors that we deem to be higher risk, we seek to oblige these Suppliers to comply with our policies as set out in this statement and our Supplier Code of Conduct. We have sent our Supplier Code of Conduct to all existing key Suppliers. We have also taken steps to ensure that our Supplier Code of Conduct, including our expected standards of behaviour, are acknowledged by these Suppliers.”

“This statement is supported by our ESG Principles and Guidelines and our Anti-Bribery and Corruption (including Anti-Modern Slavery) Policy and Supplier Code of Conduct which is overseen by the Anti-Financial Crime Group which reviews our approach to combating modern slavery and human trafficking.”

The inclusion of MS clause in the supplier contract is not explicit.

“Depending on the risk rating that we assign to a Supplier, the following due diligence measures are considered:

— Include appropriate modern slavery clauses in contractual terms where necessary with the assistance of our commercial contract checklist;”