ALPHA REAL CAPITAL LLP

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 Human resources Executive-level staff Procurement staff

Worker engagement and working conditions

Your suppliers Workers within your organisation Workers within your supply chain Businesses in your industry or sector

Grievance mechanisms

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

Other monitoring

Supply chain due diligence questionnaire is used with supply chains. We liaise with tenants of the properties in our funds to ensure their operations and working conditions are appropriate.

Demonstrated progress

Implemented a supplier DDQ when onboarding supplier & during investment process for transactions. Conducting Risk Assessments and screening of tenants against internal compliance policies and modern slavery/human trafficking laws. Maintain open communication with them to be aware of their working practices. We will shortly publish our supply chain code of conduct policy to share with supply chains and suppliers. We train our staff upon joining & annually on modern slavery risks & prevention.

Reported risks and mitigations

• Risk: Modern Slavery & Human Trafficking risks in our supply chains e.g. renewable energy (solar panels/energy), infrastructure, forestry & self storage areas.
• Area: Within your supply chains
• Tier: Tier 1 suppliers Tier 2 suppliers Tier 3 suppliers and below
• Group: Women Migrants Refugees
• Location: China United Kingdom
• Mitigation: Supply chains to provide their modern slavery statements & must confirm they are in compliance with their company's statements - this is part of our investment process for transactions and due diligence requirements when onboarding suppliers/supply chains. We assess suppliers & employee code of conduct policies. We then evaluate the risk factors in the suppliers and geographies. Have ESG scorecards and ESG Committee that considers these risks.
• Risk: Modern Slavery & Human Trafficking risks in our fund's properties, mainly the tenants that occupy them, e.g. nursing homes, nurseries etc.
• Area: Within properties of our Funds that invest in properties. This would relate to tenants and landlords. The properties our funds own may be rented to nurseries, nursing homes, assited living
• Location: United Kingdom
• Mitigation: Our investment process actively considers modern slavery & human trafficking risks among other ESG Factors. Our ESG Scorecard analysis incorporates modern slavery considerations. We engage with investee companies, supply chains, landlords & tenants of our Fund e.g. nursing homes. We have conversations with them on their recruitment practices, employee code of conduct, working hours, eligibility of their workforce to work in the UK, to ensure working conditions satisfies the standards we expect.
• Risk: Modern Slavery & Human Trafficking risks in our direct suppliers for our firm, such as cleaning or IT staff.
• Tier: Tier 1 suppliers Tier 2 suppliers
• Mitigation: We select suppliers based on their reputation in the industry, modern slavery statements & ethical practices. We have implemented mitigations through our supplier DDQ, questioning their practices, including health & safety practices, recruitment practices & employee code of conduct policies. We evaluate the risk factors in the suppliers and geographies based on this information. We are a member of the UN Global Compact. For high risk suppliers, we escalate to a relevant committee for evaluation.