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"We have a set of policies and standards guided by international principles and all applicable laws and regulation. In 2020 we published our Group Human Rights Statement, defining the Group’s commitment to human rights, including modern slavery. The Statement includes the policies, processes and measures we have in place to assess and manage modern slavery risks across our business, such as:

Ȃ An employment verification process for all employees, including right to work checks prior to joining.

Ȃ Screening of suppliers using our proprietary modern slavery risk framework and a due diligence process to understand and evaluate their human rights management, including training, reporting and remedial plans. We will automatically exclude any organisation if it or its associated individuals have been convicted of slavery, servitude, forced or compulsory labour, child labour or an offence in human trafficking. Our Supplier Code of Conduct outlines our expectations of suppliers and their sub-contractors in regards to modern slavery or human trafficking.

Ȃ The Group Whistleblowing Policy (available on request) sets out the internal procedure for reporting and investigating concerns without fear of reprisals or detrimental treatment. We have also extended access to our independently operated Whistleblowing hotline to any external party.

Ȃ We only provide financial services to clients who meet our Group standards including our Group Financial Crime Risk Appetite Statement.

Ȃ We monitor supply chain standards and workforce metrics across all sectors and companies through our proprietary research tool, CONTEXT, as well as human rights policies for higher risk sectors."