PIMCO Europe Ltd– Modern Slavery Statement for 2023
Introduction
PIMCO Europe Ltd (the “Company”) wholeheartedly supports the Modern Slavery Act 2015, which aims to drive out allforms of modern day slavery and human trafficking from business practices. The Company has zero tolerance towards
human rights violations and is committed to the highest standards of ethical and sustainable business practice, both inour own business and in our supply chains. This statement is made by the Company, as required by section 54 of theModern Slavery Act, in respect of the financial year ended 31 December 2022.
Organisation, Risks and Policy
The Company is part of the PIMCO group, one of the world’s premier fixed income investment managers. The Company
provides a range of investment products and services primarily to clients within the EMEA region. PIMCO considers
human capital risk as part of its integration of ESG across client portfolios. In 2017, PIMCO became a signatory to theUN Global Compact (https://www.unglobalcompact.org/participation/report/cop/create-and-submit/active/439234) as acommitment to advancing the principles of human rights, labour, environment and anti-corruption within its sphere ofinfluence. PIMCO also partners with organizations such as Business in the Community to leverage best practices related
to human rights and corporate citizenship. Furthermore, PIMCO maintains a dialogue with external stakeholder groups
seeking to improve the analysis of human capital risks including UN Principles of Responsible Investment andInternational Sustainability Standards Board. PIMCO’s Statement on Human Rights is available [here] and reiterates
PIMCO’s commitment to respecting human rights as outlined in the International Bill of Human Rights and theInternational Labor Organization’s (ILO) core conventions in line with the United Nations Guiding Principles on Businessand Human Rights (UNGP)The Company has considered its direct exposure towards all forms of slavery, human trafficking or child labour and, inparticular, its employment practices which it believes eliminate any risk of these occurring in the Company’s ownbusiness. As is generally the case with financial services firms, the Company is required to be authorized, is subject toregulatory supervision and operates in a heavily regulated environment. The Company undertakes comprehensive preemployment checks in relation to all potential employees that are required to be satisfied prior to employment. Inaddition, the work carried out typically requires staff with a higher education or other professional qualifications who, inorder to perform their roles, are often subject to individual regulatory authorisation and continuing professional trainingrequirements.
It is noted that, being in a professional services industry, the Company’s procurement activities are also limited.
Accordingly, the Company’s exposure to supply chain risks is also considered limited. However, the Company has
undertaken a risk-based assessment of its suppliers and has determined due diligence based on the level of risk
associated with each service provision.
Due Diligence
As part of the Company’s commitment to full compliance with the Modern Slavery Act, the Company seeks to ensurethat it knows who is providing it with goods and services at all times. The Company has previously communicated its
policy of zero tolerance in writing to its existing suppliers and it does the same for all new suppliers. The Company also
has controls in place to ensure that legal and regulatory requirements, including the Modern Slavery Act, are considered
prior to any supplier agreement being finalized. The Company has standard contractual provisions on modern slavery
that are included wherever appropriate.
The Company’s material outsourcing relationships are with other financial services firms which, for similar reasons, are
low risk from a modern slavery perspective. Notwithstanding, the Company has obtained Modern Slavery Act statementsof compliance from all such suppliers rated as posing a material or higher risk. The Company also conducts routine
periodic due diligence over its material outsourcing relationships and other vendors and includes modern slavery checksas part of these processes.
The Company has reviewed service providers involved in the provision of office facilities, cleaning, and other products
and services for its offices. This includes the procurement of electronic equipment. The Company has obtained Modern
Slavery Act statements of compliance from all such existing suppliers rated as posing a material or higher risk, androutinely obtains compliance statements from all such new suppliers.
The Company has considered its product distribution channels and, whilst considered low risk for the reasons given,has circulated updated terms to each of its sub-distribution partners to cover the Modern Slavery Act. In addition, theCompany has updated its distribution agreement template to explicitly cover the Modern Slavery Act going forward.
Training
All staff involved with procurement and all other relevant staff have been trained on ethical procurement which addresses
key supply chain issues, including human rights and the risk of modern slavery, in supply chains. Training is repeatedannually to ensure that relevant employees understand the latest detection and mitigation methods.

Effectiveness
The Company does not believe any incidents as outlined by the Modern Slavery Act have ever occurred within theCompany nor is it aware of any such incidents within its supply chain. However, the Company continues to look at how
it can further mitigate the risk of modern slavery in its supply chain and is ready to take appropriate action promptly toaddress any concerns that may arise. This includes ensuring that all of its suppliers, existing and new, that pose amaterial or higher risk have provided statements of compliance; that contractual terms with any such new suppliers
satisfy modern slavery requirements; that all relevant staff receive training appropriate to their needs; and that any
material issues arising from implementation of this policy are effectively escalated should the need arise. At the sametime, the Company is reinforcing its contribution to combatting modern slavery globally through its integration of ESG
across client portfolios.
Conclusion
This statement is made pursuant to section 54 of the Modern Slavery Act 2015. As required by the Act, it has been
approved by the Board of Directors of the Company on 15 May 2024, and it has been published on the Company’s
website, with a prominent link to it on the Company’s homepage, and on the UK government’s Modern Slavery
Statement Registry.
Signed on 15 May 2024 on behalf of the Board:

Craig Dawson
Chief Executive Officer and Director, PIMCO Europe Ltd2