HANDELSBANKEN WEALTH & 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 the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents

Training described

Your whole organisation Your front line staff Human resources Executive-level staff Procurement staff

Grievance mechanisms

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

Demonstrated progress

Every year we outline how we have made progress against our commitments in the year previous and we set new goals for the year ahead. We also track a number of key KPI's to measure each year

Reported risks and mitigations

• Risk: We focus on 3 areas in our statement Firstly those colleagues working in our own operations, those based either in our Head office locations or our branch network
• Area: Within your own operations
• Group: Women
• Location: United Kingdom
• Mitigation: Further expand on our modern slavery training, beyond the mandatory training, so that colleagues can recognise and respond to modern slavery risks. Enhance the information our branch colleagues have available to support their conversations with customers about modern slavery and the Real Living Wage. Explore further KPIs, including customer engagement. Collaborate with other organisations, industry groups and government agencies to share best practice and improve efforts to combat modern slavery
• Risk: secondly we focus on workers in our supply chains and in particular high risk sector categories of suppliers such as Construction, cleaning and Facilities Management
• Area: Within your supply chains
• Tier: Tier 1 suppliers
• Group: Women Migrants Refugees Children
• Mitigation: Conduct and annual review of our Supply Chain ESG strategy Continue the Bank's onboarding plans to EcoVadis including our subsidiary Continue onboarding new suppliers to Hellios FSQS for due diligence Enhance our Supplier Code of Conduct Carry out a Risk assessment on our subsidiary's supply base Continue to build capability and knowledge Explore opportunities to streamline our supply base Develop a new set of targeted assessment questions for cleaning suppliers
• Risk: Thirdly we focus on risks working with our Customers of the Bank and help our colleagues to spot the signs of victims or perpetrators of the crimes
• Area: Within our Customer base
• Group: Women Migrants Refugees Children Other vulnerable groups
• Mitigation: Establish a small working group of Branch colleagues to support customer focused initiatives Provide enhanced information to Branch colleagues on modern slavery when onboarding customers Further enhance our indicators for vulnerable customers Support branch colleagues with deeper dive webinars on the red flags of modern slavery Work with Business customers to support their sustainability goals