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"Investment portfolio

In the investment portfolio we seek to identify modern slavery risks as part of our responsible investment approach by integrating Environmental, Social and Governance (ESG) factors in the investment process. This includes analysing material social or ‘S’ factors including supply chain, labour and modern slavery risks. We assess modern slavery risks prior to investing in an asset and on an ongoing basis throughout the ownership phase for our most material assets.

As part of our ‘S’ factor assessments, we take into consideration the geographic location of the investment, industry exposure and the nature of the business’ workforce to identify potential risks. These elements have been informed by guiding frameworks such as the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, The Global Slavery Index, and UN Guiding Principles on Business and Human Rights. Based on these factors and further information gathered in due diligence, we identify key modern slavery and labour risks for the investment which informs the asset class teams’ decision to invest in the asset or external managers’ decision to invest in the asset."

Explicitly states assessing risk prior to investing.