J O HAMBRO CAPITAL 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 the use of worker-paid recruitment fees Prohibits compulsory overtime 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

Worker engagement and working conditions

Your suppliers Trade unions or worker representative groups Workers within your organisation Businesses in your industry or sector

Grievance mechanisms

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

Other monitoring

We did a vigorous review of our supply chain concentrating on a number of key areas in order to identify any issues in relation to modern slavery.

Demonstrated progress

Our outsourcing oversight function, in conjunction with our HR and Operations teams monitor how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chain and report any concerns to senior management for remedial action. We will continue to monitor the effectiveness of the steps we have taken to prevent slavery or human trafficking in our supply chain and will review the Modern Slavery Act statements made by our suppliers

Reported risks and mitigations

• Risk: 1. Vulnerable Populations: Low skilled, temporary jobs, migrant workers or minorities.
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers
• Group: Women Migrants Refugees Children
• Mitigation: We have circa 1360 suppliers globally. The material suppliers are typically listed and regulated financial services entities who employ skilled, permanent workers. Many of these operate within jurisdictions with regulatory responsibilities to report on their exposure to modern slavery, and to have in place appropriate risk management practices. We have developed a risk assessment framework and rated all of our suppliers and we will continue to carry out deeper analyses.
• Risk: High and medium risk geographies: Lack of regulation or enforcement agencies, poor track records on corruption and human rights, prevalence of criminal organisations.
• Area: Our investments
• Mitigation: In line with common practice, we referred to the top 50 highest risk countries as identified in the latest Global Slavery Index (2018). After completing an initial assessment on our Australian investment strategies, which represents 46.67% of our total assets under management, we can confirm that as at 30 September 2020, we did not hold any investments in entities incorporated or listed, nor held debt offered by government or semigovernment issues, in these 50 countries.
• Risk: Business models structured around high-risk practices: Complex and long supply chains w/ several intermediaries along the chain, oligopolistic industries, labour intensive industries, short lead times
• Area: Within your own operations
• Mitigation: We see risks in our operations as inherently low. We are a global professional services business, and our statutory responsibilities and employment policies help to manage such people related risks. We see risks in our operations as inherently, and do not have subsidiaries or offices based in countries that we inherently consider to be high risk in terms of modern slavery practices. We operate in a highly regulated environment and are compliant with requirements for managing modern slavery risk