UK MODERNSLAVERY ACTSTATEMENT
2023

About us
Introduction of Russell Investments reporting entity
This Modern Slavery Statement (Statement) is made on behalf of the following Russell Investments
reporting entities:•

Russell Investments Limited (RIL)•

Russell Investments Implementation Services Limited (RIISL) and•

Russell Investments Systems Limited (collectively, Russell Investments, we or our). This
Statement sets out the steps taken by Russell Investments during the financial year ending 31
December 2023 to seek to identify and prevent modern slavery and human trafficking in ourbusiness and supply chains in accordance with the UK Modern Slavery Act 2015 (the Act).

The term Modern Slavery is defined in the UK as the recruitment, movement, harbouring or receiving of aperson through the use of force, coercion, abuse of vulnerability, deception or other means for the purposeof exploitation1. The Act criminalises Modern Slavery, making it an offence to hold a person in a position ofslavery, servitude and/or forced and compulsory labour and / or facilitating their travel with the intention of
exploiting them soon after. It also seeks to increase transparency to the public on the actions organisations
are taking to address risks of slavery and human trafficking in their businesses and supply chains.

Organisational structure
About Russell Investments
We are members of the Russell Investments group of companies (the Russell Investments Group). The
Russell Investments Group is a global investment solutions provider focused on helping investors achieve
their investment goals, bringing together its capabilities in strategic advice, manager research andimplementation. Our London office opened in 1979 and was the first non-US office to open in the Russell
Investments Group, beginning with a team of 60 people. Today, we have over 200 local associates andpartner with a wide range of professional clients to offer innovative investment solutions. Headquartered in
Seattle, Washington, the Russell Investments Group operates multi-nationally and is dedicated to improving
people’s financial security, leveraging an over 85-year client-centric heritage grounded in investment
innovation.

Operations
Russell Investments provides investment solutions to professional clients with a focus on the UK,
Switzerland and the Middle-East and our operations include:1•

providing portfolio management and investment advisory services;•

acting as the investment manager of funds within the Russell Investments Group; and•acting as the distributor of funds within the Russell Investments Group.

Modern Slavery and Public Health Research and Analysis published 7 December 2017 by Public Health England.

Russell Investments / UK Modern Slavery Act Statement/2Our beliefs
Core values
The Russell Investments Group has a Global Code of Conduct which is a set of principles demonstrating ourcore values summarised below:

We behave with non-negotiable integrity.

We value our people and are dedicated to fostering a meritocracy. Our pillars areinclusivity, humanity, fairness, hard work, creativity, teamwork, fun and humility.

We play to win by exceeding client expectations and executing with a sense ofurgency and purpose.

We are passionate investors who embrace intellectual curiosity and rigor.

These values, which are aligned with our purpose, emphasise putting our clients’ interests first while
nurturing a high integrity to ensure that trust with our clients and associates is never broken. Full details of
our corporate values can be found here.
In accordance with our core values, Russell Investments supports the UK Government’s objectives toeradicate modern slavery and human trafficking. We comply with the Act and recognise the risk of Modern
Slavery in business supply chains noting in particular the higher risk for global supply chains. We strive toensure that our systems and processes are fit for purpose in combating the risk of Modern Slavery activity
within our supply chain. In a global context, the Russell Investments Group continues to grow its
engagement in an internationally consistent, top-down approach to ESG issues, including Modern Slavery
risk.

Governance framework
Russell Investments employs a robust governance framework which fosters a culture of non-negotiable
integrity and reduces the risk that we cause or contribute to modern slavery.
All associates at Russell Investments are required to certify that they will comply with the terms of the
Global Code of Conduct and are obliged to promptly report any suspected violations of the Code byanother associate, contractor, or vendor.
Russell Investments operates a Whistleblowing Policy which applies to all employees, officers,
consultants, contractors, interns and agency workers. The policy provides associates with guidance as to
how to report suspected wrongdoing and the investigation process. To further encourage a culture of
speaking out, associates of Russell Investments can report any actual or suspected instances of unethical or
illegal conduct on a fully anonymous and confidential basis via an Ethics hotline which operates 24 hours aday.
Russell Investments operate a series of Anti-Bribery and AML policies and processes designed tosafeguard against financial crime and to reduce the risk of exposure to third parties with poor systems andcontrols in place relating to ethical behaviour.
Russell Investments promotes a Diversity and Equal Opportunities Policy for all associates andemployment applicants. All associates are required to comply with this policy when dealing with otherassociates and other individuals working within Russell Investments including temporary staff or agency

Russell Investments / UK Modern Slavery Act Statement/3

staff, consultants, job applicants, clients, suppliers, customers and contacts of Russell Investments, andanyone else with whom they come into contact during the course of their employment.
Russell Investments operates an Anti-Bullying and Harassment Policy which advises on how to deal withincidents of bullying and harassment if they arise. This policy extends to all employment-related activities
regardless of where such conduct occurs and also applies, to the extent possible to complaints by nonassociates i.e. vendors, clients and business partners.

Russell Investments supply chain and associated risks of modern slavery
Russell Investments understands that the assets it manages represent an opportunity and an obligation to
help drive positive outcomes in the areas of sustainability and social change. We strive to use the influence
afforced by the investment choices we make to reduce the risk of Modern Slavery within our global
investment portfolios.
Russell Investments has a range of global and UK supplier relationships. In assessing the risk of Modern
Slavery in our business, we have divided our supply chain into two groups.
•

Businesses that support our investment solutions business including money managers anddistributors (Investment Supply Chain); and•Businesses that support the day to day running of our business including commercial realestate/cleaning/office suppliers and other services needed to support staff in offices, pay-roll
providers and pension fund providers and private health-care providers (Operations Supply
Chain).

Russell Investments considers the risk of Modern Slavery within its supply chain to be low given the natureof its business. Nonetheless, we still take certain steps to further reduce the risk of any such behaviour.

Investment supply chain
The Russell Investments Group has been conducting money manager research in a global capacity for over
50 years and follows a disciplined research process to select and recommend money managers for use
within Russell Investments. Our proprietary manager research process is based on qualitative assessments
supported by quantitative analysis. The aim of our research process is to identify strategies that will
outperform. This assessment includes many facets, including ESG considerations.
Russell Investments uses information from a variety of sources, including third party data providers, as well
as data gathered as part of our investment and operational due diligence processes to help understand therisk of Modern Slavery within Russell Investments’ investment portfolios. Russell Investments analysts in theInvestment Division use a range of ESG data derived from various third party and internal subject matter
experts when researching, analysing, and constructing our global investment portfolios.
On a monthly basis, all Russell Investments equity funds report against their benchmarks. This helps
portfolio managers understand the ESG risks present in their portfolio, including those associated with
Modern Slavery. Modern Slavery risk variables (such as human rights, human capital management andhuman supply chain risk) for each Russell Investments are measured relative to the fund benchmark. The
data from our reports enables us to understand the potential for exposure to Modern Slavery in our equity
portfolios.
Regular engagement with our money managers on measuring and acting on ESG risks is a key aspect ofmanaging and understanding our Modern Slavery risks. As outlined in more detail below, ESG is an areathat Russell Investments’ manager research analysts formally assess for every investment strategy. We
have regular dialogue with the money managers on ESG matters, including Modern Slavery considerations.
In addition, Russell Investments portfolio managers perform a quarterly review of ESG risks in our funds.
Our money managers often have a close understanding of where potential Modern Slavery risks may lie andhow those risks are being addressed on the ground. We draw on this expertise to help us better understandthe Modern Slavery risks in the companies in which we invest and consider the most appropriate action,
including in some cases, direct engagement with investee companies, in partnership with our money
managers.

Russell Investments / UK Modern Slavery Act Statement/4Operations supply chain
The majority of our Operations Supply chain are located in the UK.
We recognise that some of our suppliers may present potentially higher risk where they use contracted
labour or products indirectly sourced from higher risk industry sectors and jurisdictions. We therefore takethe following steps to mitigate those risks in our supply chain:•

Our suppliers who supply materials used for internal fabric works/ consumables are required tocertify that materials have not been sourced, manufactured, or supplied using Modern Slavery andthat the supplier has complied with all applicable laws relating to Modern Slavery.

•

Our suppliers who appoint contractors on our premises must undergo DBS and right to work
checks.

•Any new supplier entering into a contract or tendering for work with Russell Investments must
provide us with details of their policies on Modern Slavery, as well as providing assurances that
they, or anyone within their own supply chain, do not engage in Modern Slavery or any associatedactivity. Where we identify higher risk service providers, we seek to include contractual provisions
to require compliance with relevant laws and regulations including the Act.

Investment process
Initial and ongoing due diligence processes
The Russell Investments Group has a specialised global team that carries out initial due diligence on any
money manager being considered to manage or advise on all Russell Investments products globally. This
includes an assessment of their structure, function and governance, including the following ESG factors:
ESG Commitment – quality of ESG resources (data and people) and alignment with the investment process
ESG Consideration – quality of their insights and assessment of ESG related risks and returns
ESG Implementation – effectiveness of reflecting ESG insights in the portfolio
Active Ownership – evaluation of the transparency, quality, and duration of stewardship activities withinvestee companies on ESG issues
The Russell Investments Group Investment Division assesses each prospective money manager against theabove criteria, and then grades them against their industry peers. Additionally, our quarterly risk
management questionnaires that are completed by all money managers who are appointed to manage
assets by Russell Investments, contain specific Modern Slavery questions. These questions relate to the riskof Modern Slavery within the money manager’s business and supply chain.

Sustainability risks policy and enhanced oversight programme
From the last reporting period, Russell Investments continues to operate in keeping with its Sustainability
Risks Policy. This policy describes how we manage risks relating to sustainability across our global
investment portfolios. Modern Slavery has been defined as one of the risks to be managed in our portfolios,
typically from a ‘Social’ (S) or ‘Governance’ (G) perspective. As part of the continuing implementation of the
Sustainability Risks Policy, Russell Investments has further developed and expanded the global Enhanced
Oversight Program.
The Enhanced Oversight Program requires Russell Investments portfolio managers to assess sustainability
risks in the portfolios they manager as part of their quarterly review process. ESG data provided by different
third parties is used by Russell Investments to help determine the areas of ESG risk contained in theportfolios we manage. If Modern Slavery risks are highlighted as part of this review process, the portfolio
manager will broaden the discussion to research analysts and (likely) the money manager responsible for aparticular security holding in the portfolio. Russell Investments’ portfolio managers are directly accountable
for ESG risks identified as part of the Enhanced Oversight Program. This includes keeping adequate recordsof all discussions and outcomes with relevant money managers.

Russell Investments / UK Modern Slavery Act Statement/5Active ownership and partnering
At Russell Investments, we believe that a strong stewardship program includes pursuing activities which
offer the highest return or risk mitigation opportunities. To this end, Russell Investments’ Active Ownership
Team strategy is focused on material issues under the general categories of ‘Environment,’ ‘Social,’ and‘Governance.’
Within the ‘Social’ category, we have defined “human capital management” which is focused on how
companies attract, develop, and retain employees while providing working conditions favouring greater
employee engagement. We believe that ensuring investee companies exhibit an adequate management of
their human capital can help to prevent trafficking, forced labour, child labour, and other forms of Modern
Slavery.
Additionally, to ensure that companies meet a minimum standard for good governance practices, we check
whether a company has breached global 'norms,' as represented by the UN Global Compact Principles 2. If a
company is identified as being in breach of one of the principles of the UNGC, we will engage with thecompany with the purpose of understanding why a breach has been flagged, promoting improvements ingovernance practices, and ultimately assessing whether the company exhibits good governance.
In 2022, Russell Investments released an internal platform called ENACT which was built to improve thesharing of ESG-related insights. This tool allows us to assess how the companies we are investing in areprogressing managing sustainability risks from their business activities. The name ENACT was drawn fromthe combination of two of our critical responsible investing practices: Enhanced Oversight and Active
Ownership.
ENACT allows investment team members to record and access the ESG-related insights that are gathered
during sub-adviser oversight and from engagement activity. Critically, ENACT maps an issuer’s securities
across funds, enabling coordination between fixed income and equity experts, and it serves as a timeline
and progress marker for our engagement objectives. We believe that setting and tracking explicit
engagement objectives is key to an effective program.

Employees
Russell Investments is committed to ensuring that there is no modern slavery and human trafficking within
our business and that the rights of our workers are protected. We consider that all associates have the rightto work in an environment: (i) that is free of any form of harassment, bullying and discrimination; (ii) which
promotes dignity and respect; and (iii) where associates feel able to raise any concerns relating to bullying or
harassment, should they arise, and do so without fear of reprisal. Furthermore, we ensure that all our
employees have a right to work in the UK (or, where based in one of our branches, have a right to work inthat relevant jurisdiction).
We are committed to respecting and promoting equality and diversity in the workplace and aim to ensurethat associates treat each other with respect and dignity in the workplace, leading to an environment freefrom discrimination and to reduce the risk that our employees could be exploited.
To support these commitments, we have operating procedures, practices and programmes including but notlimited to:•an Employee Assistance Programme which provides anonymous services for associates on
workplace issues.

•a Complaints procedure for any associate who believes they have experienced or are experiencing
any form of discrimination, harassment or victimisation.

•an orientation process for new associates designed to embed and communicate Russell
Investments’ core values.

Established in 1999, the UN Global Compact (‘UNGC’) is a voluntary framework that has Ten Principles built around human rights, labour
standards, the environment, and anticorruption. These principles promote the integration of sustainable business practices and challenge
companies to become more open and transparent about their strategies, policies and procedures pertinent to sustainability issues.
2

Russell Investments / UK Modern Slavery Act Statement/6Training
Russell Investments provides training to its associates on Anti-Bribery, Anti-Money Laundering and the FCA
Conduct Rules. This training is mandatory. Where an associate does not complete mandatory training by thedue date (in the absence of mitigating circumstances), this is recorded as a conduct violation and reported to
the Russell Investments board of directors.
Russell Investments provides a training programme, Promoting Equality and Diversity to team leaders,managers and supervisors on raising awareness and how to develop a culture that encourages diversity andequal opportunities in the workplace.
This statement has been approved by the relevant boards of directors of Russell Investments on 11
March 2024 and has been drafted in accordance with section 54(2) of the Act.

David Rae, Director
Russell Investments Limited
Russell Investments Implementation Services Limited
Russell Investments Systems Limited

Russell Investments / UK Modern Slavery Act Statement/7

QUESTIONS?
Call Russell Investments at 020 7024 6000
or visit russellinvestments.com

FOR PROFESSIONAL USE ONLY
Unless otherwise specified, Russell Investments is the source of all data. All information contained in this material is current at the time ofissue and, to the best of our knowledge, accurate. Any opinion expressed is that of Russell Investments, is not a statement of fact, issubject to change and does not constitute investment advice. The value of investments and the income from them can fall as well as riseand is not guaranteed. You may not get back the amount originally invested.
In the UK this marketing document has been issued by Russell Investments Limited. Company No. 02086230. Registered in England andWales with registered office at: Rex House, 10 Regent Street, London SW1Y 4PE. Telephone +44 (0)20 7024 6000. In the EU thismarketing document has been issued by Russell Investments Ireland Limited. Company No. 213659.
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this marketing document has been issued by Russell Investments Limited a Dubai International Financial Centre company which isregulated by the Dubai Financial Services Authority at: Office 4, Level 1, Gate Village Building 3, DIFC, PO Box 506591, Dubai UAE.
Telephone +971 4 578 7097.This material should only be marketed towards Professional Clients as defined by the DFSA.
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