SCHRODER ADMINISTRATION 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

Worker engagement and working conditions

Your suppliers Workers within your organisation

Grievance mechanisms

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

Other monitoring

We engage with our employees through a variety of channels including our regional and global Employee Forums. Our GEF is chaired by the Senior Independent Director and meets regularly.

Demonstrated progress

Key Performance Indicators that summarise some of our activities and progress for 2022 can be found on page 21 of our Modern Slavery Statement 2022. We have also included comparison metrics to 2021 and 2020, as we believe it is important to show our continued effort and progress. We recognise that it’s difficult to quantify outcomes and impacts of an approach to tackle modern slavery. Over time we will enhance our measurement of assessing the effectiveness of our approach and progress.

Reported risks and mitigations

• Risk: As an active investment manager, we recognise that we are linked to potential adverse modern slavery risks through our clients’ investment portfolios.
• Area: Within our value chain - the investments we manage
• Group: Women Migrants Refugees Children
• Mitigation: We integrate modern slavery risks into our fundamental analysis of companies and actively engage with them to promote and respect human rights. We have an internal tool, used to support investment analysis, that includes several performance measures and questions related to human rights and modern slavery topics. We developed a bottom-up framework for analysing a company's human rights due diligence efforts. We continue to actively engage with companies an vote on human rights practices.
• Risk: We recognised that there is a risk risk that modern slavery could take place within our direct workforce.
• Area: Within your own operations
• Group: Women Migrants Refugees
• Mitigation: We are committed to respecting the ILO’s Declaration on Fundamental Principles and Rights at Work and to providing equal employment opportunities and combatting all forms of discrimination. We continuously manage the risk of modern slavery in our workforce by making sure that the people we hire have the right to work in the relevant country and that their basic rights as workers are protected. We commit to providing fair wages and benefits and a secure working environment for our people.
• Risk: We recognise the risk that we could purchase goods and services from companies involved in modern slavery.
• Area: Within your supply chains
• Tier: Tier 1 suppliers
• Mitigation: We expect all our suppliers to operate in a responsible, open and transparent way, fully compliant with all applicable laws and regulations, and our Supplier Code of Conduct. We take a risk-based approach to the sourcing, onboarding and monitoring of our own supply chain and apply enhanced due diligence to those deemed to be higher risk regarding modern slavery exposure. Fundamental to our supply chain oversight is performing both initial and ongoing supplier criticality assessments.