SCHRODER INVESTMENT MANAGEMENT NORTH AMERICA LIMITED

Policies described

Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits child labour Prohibits discrimination Provides access to remedy, compensation and justice for victims of modern slavery

Training described

Your whole organisation

Worker engagement and working conditions

Your suppliers Civil society organisations Workers within your organisation

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app Through trade unions or other worker representative groups

Other monitoring

Internal employee surveys and forums.

Demonstrated progress

We measure and report on a number of KPIs including: number of instances of modern slavery reported, number of human rights-related engagements across our clients' investment portfolios, completion rate from modern slavery e-learning and number of modern slavery engagements with suppliers. Over time we will enhance our measurement of assessing the effectiveness of our approach and progress with smarter metrics.

Reported risks and mitigations

• Risk: A risk that we could invest in companies or assets involved in modern slavery.
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Group: Migrants
• Mitigation: To assist with sustainability analysis within sectors, regions and companies, we use CONTEXT™, a proprietary model that is accessible to investment teams. We have developed a framework for analysing a company’s human rights due diligence efforts across 5 areas of human rights due diligence. Our engagement strategy aims to identify companies with the most material risks of human rights abuses and work with them to address their approaches to human rights and encourage them to implement the UNGPs.
• Risk: A risk that our employees could be exploited.
• Area: Within your own operations
• Mitigation: We manage the risk of modern slavery within our workforce by making sure all new hires possess the legal right to work in their respective countries and that their fundamental rights as workers are protected. We conduct pre-employment checks, including right-to-work checks. We require outsourced companies to carry out employment checks and follow the standards set out in our Supplier Code of Conduct. We encourage our suppliers and their subcontractors to provide training on worker welfare.
• Risk: A risk that we could purchase goods and services from companies involved in modern slavery.
• Mitigation: We screen and monitor supplier risk, escalating any issues to relevant subject matter experts for investigation. This screening is carried out before onboarding a new supplier and is subsequently monitored on an ongoing basis. We carried out targeted enhanced due diligence on suppliers assessed as highest risk, based on their total risk scores. This included reviewing responses to our business transparency questionnaire and assessing suppliers using a third-party risk analytics database.