"NBEL’s supply chain primarily consists of sophisticated financial and professional service providers which support its

investment management activities, such as large global institutional banks, financial market utilities and data providers.

Consequently, NBEL believes that there is a low risk of modern slavery or human trafficking within its operations or

supply chain. However, robust due diligence and ongoing oversight of third party outsourced functions are key Neuberger

Berman control processes. NBEL is committed to acting ethically with integrity and transparency in its business and

supply chain dealings, and to maintaining effective systems and controls, inclusive of policies and procedures, to

safeguard against any potential occurrence of modern slavery or human trafficking."

Does not mention if the effectiveness of actions taken are measured