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"BlueBay’s Modern Slavery Act Service Provider Risk Assessment Framework & Results

For the risk assessment, there were three broad sets of criteria considered:

1. Business Criticality – includes an assessment of the materiality of BlueBay’s annual spend with the service provider, availability of alternatives/substitutes and the level of difficulty of sourcing these alternatives/substitutes;

2. Applicability to the Act – looks at whether the supplier/vendor will be subject to the Modern Slavery Act; and

3. Slavery, Human Trafficking and Forced labour – evaluates the nature and characteristics of the service provider’s business activities against 'high risk' industry sectors and business characteristics

Each of the service provider categories was subjected to the above three criteria so as to define an overall ‘Risk' Score’ for each category. A score between 24 and 30 is considered as High risk; a score between 17 and 23 is Medium risk and a score between 10 and 16 is Low risk.

Where a category has scored between 24 and 30 and is ranked as High, a more detailed review of the service provider within that category will be performed to better understand how the service provider organisation addresses the issue of slavery, human trafficking and forced labour within their business context. However, a category ranking of Medium and Low will not be subject to a more detailed assessment. BlueBay will only assess direct relationship and not the suppliers (fourth parties) used by the service providers.

The results of the 2020 assessments of the service provider categories, showed that no category has been ranked as High. The overall findings are as follows:

 BlueBay mainly has exposure to service-based vendors which utilise skilled labour

 The majority of vendors were categorised as 'low' risk, with some being 'medium' risk

 Medium risk service provider categories are: Outsourcers (Service), Outsourcer (Staff), Platforms and a subcategory of Others On further analysis of the sub category of Others – “Building Management / Maintenance Organisations”, we identified that when solely applying the risk criteria No.3 above (Slavery, Human Trafficking and Forced labour), this sub-category poses the highest risk due to the nature and characteristics of the business activity. Actions taken during 2020 and planned actions for 2021:

 The Facilities function maintained a number of direct relationships with service providers within the subcategory of “Building Management / Maintenance Organisations”. In August 2020, a decision was taken to outsource a number of facilities activities to a new service provider and thus consolidating the number of direct relationships held in the “Building Management and Maintenance Organisation” sub-category with the new outsourcer. The modern slavery report for this outsourcer was assessed as part of the on boarding due diligence

 BlueBay aligned its vendor management processes with RBC’s supplier management process and has updated its procedures.

 During 2021, the RBC Supplier Code of Conduct will be rolled out to new service providers and plan will be established to rollout the RBC Supplier Code of Conduct for current service providers on a risk based approach."