The company only works towards identifying risks in its supply chain and not on compliance checks of the supply chain.

pg. 24

“Bridgewater has long maintained a due diligence program designed to identify risks associated with our third-party vendors. This review process is carried out by a dedicated team of security, legal, and procurement professionals who use systematized processes to understand and address the risks posed by vendors. Depending on the nature of the engagement, review components may include questionnaires, open-source information searches, independent company assessments, and litigation and sanctions screening, among others.

In 2020, we began explicitly screening for risks of modern slavery and human trafficking. Our aim was twofold: minimize the risk of engaging vendors that cause, contribute to, or are directly linked to modern slavery practices, and communicate, at the outset of our vendor relationships, that combating modern slavery is important to Bridgewater. Specifically, we modified the questionnaire used to screen potential new vendors to identify (i) if the company has any policies, procedures, or statements regarding anti-modern slavery practices and (ii) if there have been any concerns, reports, or investigations of modern slavery risks or incidents relating to the business or its suppliers. At the end of 2020, we expanded from screening a subset of potential new vendors to screening all potential new vendors for modern slavery risks and have found a willingness among vendors to comply with this additional screening process.

In April 2022, we implemented a Procure-to-Pay tool that facilitates the systematization of our modern slavery screening for vendors. This tool is designed to seamlessly enable the collection, storage, and reporting on vendor data, including the results of our modern slavery diligence questions. Any potential new vendor is required to respond to our modern slavery diligence questions in order to complete the onboarding process; the automation of this process eliminates the possibility of a vendor being onboarded without having completed the modern slavery screening.”