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"Risk Assessment, Management and Steps Taken

Service Providers and Suppliers

Russell Investments expects its service providers and suppliers to have similar standards of integrity and fair treatment in the manner they treat their employees. Nonetheless, it considers the risk of modern slavery and human trafficking within its supply chain to be low given the nature of its business.

Russell Investments still takes certain steps to further reduce the risk of any such behaviour:

- Any third-party investment management is subject to a due diligence processes prior to the commencement of any business relationship with Russell Investments and there is a robust governance arrangement around the process of selecting third-party investment managers. Thereafter, on an ongoing basis the arrangement is subject to periodic risk management checks taking into account compliance with laws and regulations. Any investment manager will also be asked to contractually agree to complying with relevant regulatory requirements and applicable laws.

- Where it identifies higher risk service providers, Russell Investments now seeks to include contractual provisions to require compliance with relevant laws and regulations including the Act."