SCOTTISH WIDOWS ACTIVE MANAGEMENT FUND

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 Your front line staff Procurement staff Your suppliers

Worker engagement and working conditions

Your suppliers Trade unions or worker representative groups Civil society organisations Professional auditors Workers within your organisation Workers within your supply chain Central or local government Law enforcement, such as police, GLAA and other local labour market inspectorates Businesses in your industry or sector

Social audits

Third party audit arranged by your organisation Third party audit arranged by your supplier Unannounced audit

Grievance mechanisms

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

Actions addressing ILO indicators

Supporting investigations by relevant authorities

Demonstrated progress

• Delivery of bespoke human rights and modern slavery training and insight sharing with the Group Executive Committee and Group Board as part of the 2025 Board Training programme. • To support the design of an escalation process to report modern slavery, and in collaboration with Unseen UK, we facilitated workshops with colleagues from across the Group. We retained our Tier 2 rank in the annual CCLA modern slavery benchmark

Reported risks and mitigations

• Risk: High risk suppliers linked to sector risk in the UK i.e construction
• Area: Within your supply chains
• Tier: Tier 2 suppliers Tier 3 suppliers and below
• Group: Other vulnerable groups
• Location: United Kingdom
• Mitigation: Through collaboration with Unseen UK we carried out worker wellbeing visits across construction sites, where offices are being developed for the Group. These visits were designed to support our shared commitment to safe and inclusive environments for operatives. Interviews conducted by Unseen UK followed a structured framework aligned with International Labour Organization (ILO) indicators and the Ethical Trading Initiative (ETI) Base Code, ensuring a robust and recognised approach.
• Risk: Lending risk
• Area: Within your own operations
• Group: Migrants
• Mitigation: We enhanced our ESG risk assessment within the credit risk process by adopting a more targeted, risk-based methodology for Commercial Banking clients with direct lending relationships. This approach recognises that ESG factors, including human rights and modern slavery risks can translate into material credit, regulatory, and financial risks for our clients and therefore impact the Group.
• Risk: Modern slavery as an economic crime
• Group: Migrants Refugees Children
• Mitigation: The Group takes a proactive role in identifying potential perpetrators and the Group’s Financial intelligence Unit (GFIU) unit has made human trafficking and modern slavery a primary area of focus. The GFIU seeks to better understand the threat to the Group to make accurate and insightful assessments that inform our risk-based approach and response.