It only states what should be considered for risk assessment and does not mention how risk assessment is carried out.

Pg. 4

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

• Business Criticality - includes an assessment of the materiality of Blue Bay's annual spend with the service provider, availability of alternatives/substitutes and the level of difficulty of sourcing these alternatives/substitutes;

• Applicability to the Act - looks at whether the supplier/vendor will be subject to the UK Modern Slavery Act 2015 and/or to the Commonwealth Modern Slavery Act 2018 of Australia; and

• 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.”