pg. 1-2

"Our current approach to assessing the risk of modern slavery and human trafficking

Due Diligence: We operate supply chains predominantly comprising of business and professional services organisations and have minimal contact with the countries and sectors that are generally considered to have a risk of modern slavery and human trafficking.

However, we take a risk-based approach to addressing matters of modern slavery and human trafficking within our supply chain, whereby we conduct due diligence on all new suppliers during the on-boarding process and at regular intervals with existing suppliers. This forms part of our wider due diligence assessment which includes a review of our suppliers’ other policies and standards.

As part of our approach to due diligence around modern slavery, we also review the prospective organisation’s modern slavery statement. Where one exists, we check that the statement and underlying policies are as rigorous as the Act requires. For suppliers who do not publish a statement, we make use of a questionnaire to ensure that their approach to identifying and mitigating the risks of modern slavery again meets the same standards as those required by the Act. This approach ensures a consistent and rigorous approach to modern slavery across our supply chains."

pg. 2-3

"Environmental, Social and Governance (ESG)

The Group is committed to the principles of good stewardship and responsible investment, as outlined in our Stewardship Policy and 2020 Annual Stewardship Report. We integrate ESG factors into our investment decision-making and ownership practices and this forms a core aspect of how we exercise our stewardship responsibilities on behalf of clients, in order to meet their investment objectives. Jupiter recently announced that we will align our business with the UN Global Compact Principles. Fund managers retain responsibility for integrating ESG within their investment strategies. We monitor our portfolios for potential UN Global Compact violations, such as modern slavery and child labour in company supply chains. This process makes use of third party ESG data, with assistance from the Governance and Sustainability (G&S) Team and oversight from the CIO Office.

To further strengthen our commitment to responsible investment, we became an investor member of the Workforce Disclosure Initiative (‘WDI’) in November 2020. This initiative mobilises investors to ensure companies disclose comparable and comprehensive data on their workforce practices. Members of the G&S Team and investment personnel participated in a workshop on modern slavery convened by WDI in 2020.

Furthermore, in February 2021 we joined the ShareAction Good Work Investor Coalition which brings together institutional investors to collaboratively engage on workforce issues, including the Living Wage, diversity and inclusion and insecure working practices."