HARGREAVES LANSDOWN ASSET MANAGEMENT LIMITED

Policies described

Freedom of workers to terminate employment Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents Provides access to remedy, compensation and justice for victims of modern slavery

Training described

Your whole organisation Your suppliers

Worker engagement and working conditions

Your suppliers Workers within your organisation

Social audits

Audit conducted by your staff

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app

Other monitoring

Due Diligence for new suppliers, a Supplier Code of Conduct, and the incorporation of Anti-Slavery and Human Trafficking avoidance measures, requirements and standards in our legal agreements.

Demonstrated progress

Ensure colleagues with procurement responsibilities understand the risks of modern slavery and human trafficking in our supply chains. Colleagues are expected to report suspicious activity, however small, and this is acted upon through our ‘Speak Up’ whistleblowing policy. Colleagues undertake annual mandatory whistleblowing training.

Reported risks and mitigations

• Risk: IT Service Providers with a UK base form a large part of our supply base and consist of software providers, hosting services, support and maintenance for our internal IT infrastructure.
• Area: Within your supply chains
• Tier: Tier 1 suppliers
• Group: Other vulnerable groups
• Location: United Kingdom
• Mitigation: We continuously review our procurement and supply chain practices, adding greater transparency and oversight. We are using a new Vendor Management System to ensure that we onboard and manage our third parties efficiently as well as ensuring we work to comply with all current regulations and practices as part of our ongoing procurement strategy.
• Risk: Fund groups are subject to a requirement to comply with the Modern Slavery Act 2015.
• Tier: Don't know
• Mitigation: Continue to monitor and track our supply chain
• Risk: Approximately, 80% of our direct suppliers are based in the UK, which makes it simpler for us to take preventive or remedial steps than if they were based overseas.