DocuSign Envelope ID: C0293111-C4AD-4714-8FC6-D68E76BF6B42

WELLINGTON MANAGEMENT INTERNATIONAL LTDSLAVERY & HUMAN TRAFFICKING STATEMENT 2022....................................................................................................................................................................................................................................................

INTRODUCTION
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (“the Act”) and constitutes
Wellington Management International Ltd’s (“WMIL”) Slavery and Human Trafficking Statement (“Statement”) for
the financial year 1 January 2022 to 31 December 2022 (“financial year 2022”). Under the Act, commercialorganisations that supply goods or services, carry on business in the UK and meet the annual turnover threshold ofat least £36m from the provision of goods and services must publish an annual slavery and human trafficking
statement.
The Act prompts us to review our business and supply chain to identify where the highest risk of encounteringmodern slavery exists. Our review for the financial year 2022, found that no changes to policy nor approach arerequired to ensure that WMIL continues to meet its obligations under the Act.

OUR BUSINESS AND STRUCTURE
Wellington Management is engaged exclusively in investment management. We serve as a trusted adviser andstrategic partner to investors in more than 60 countries worldwide. We offer capabilities that span nearly all
segments of the global capital markets. Our investment solutions, which are tailored to the unique return and risk
objectives of institutional clients, draw upon our robust body of proprietary research and collaborative culture. We
encourage independent thought and healthy debate. As a private partnership, we believe our ownership structure
fosters a long-term view that aligns our perspectives with those of our clients. WMIL is a subsidiary of Wellington
Management Group LLP.

OUR APPROACH TO THE ACT
We are committed through our corporate sustainability strategy (WellSustain) to incorporate socially andenvironmentally sustainable behaviour into our business activities. We do this through sound governance andengagement with our employees, our community, and our environment. We take our obligations related to theprevention of slavery and human trafficking seriously. We are committed to taking appropriate steps to ensure therequirements of the Act are met within our business and supply chain.

RISKS OF MODERN SLAVERY PRACTICES IN OPERATIONS AND SUPPLY CHAIN
As a professional financial services organisation, WMIL considers its overall risk of modern slavery within its
business operations in the United Kingdom to be relatively low given the nature of the business undertaken and theskillset required. However, WMIL recognises that it can be exposed to the risk of modern slavery indirectly throughits supply chain and investments.

SUPPLY CHAIN & PROCUREMENT PROCESSThe nature of our business along with the high standards we have for ourselves and that we expect from our suppliers
is reflected in our overall assessment that the risk of slavery and human trafficking in our supply chain is low.
As an investment manager, we have a relatively simple supply chain built around supporting our investment
management practice. The external vendors we procure goods and services from primarily fall into four broad
categories:•

Professional & Employee Related Services: firms that provide legal, tax, audit, and accountancy advice;external investment research providers; external training and recruiting consultants; as well as employee
insurance and benefit providers.

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Workplace Services: the services that support the running of our day-to-day business (e.g., cleaning,catering, office equipment maintenance services and property management)
Technology & Data Services: the systems, software and hardware purchased to provide the technology
infrastructure required to undertake our business; also includes market data services.
Travel Services: as a global organisation serving clients in more than 60 different countries, we engage anumber of travel service providers. Wellington Management has a centralized procurement function
responsible for global vendor management. Within that function, there is a Third-Party Risk Management(TPRM) team. TPRM is responsible for initiating the due diligence review process for new and existing
suppliers that we deem to be high risk.

SUPPLIER ADHERENCE TO OUR VALUES
Where applicable, a modern slavery clause will be included in our contractual agreements. WMIL may also request
a supplier provide information regarding the necessary actions it has taken to prevent or remediate modern slavery
in its business or supply chain. We may also request an annual certification to confirm appropriate provisions are inplace. Third party service providers are systematically identified and reviewed for potential modern slavery risks atonboarding based on risk factors such as the third party’s industry and country of operation. Should any supplierbe found to use modern slavery in any part of their supply chain and/or their business, it will result in remediation
discussions and ultimately could result in contract termination.
Over this reporting period, we have made progress in implementing actions to assist in addressing the modernslavery risks associated with our supply chain. These include reviewing and, where necessary, updating due diligenceprocedures and reviewing our suppliers’ statements specifically related to Modern Slavery Information. We also
conducted focused training for members of the procurement and third party risk team.

OUR BUSINESS POLICIES AND PRACTICESIn addition to our procurement process, WMIL has internal policies that support our efforts to reduce the risk ofslavery and human trafficking within our business. These policies include:• Code of Ethics• Safe Work Environment Policy• Equal Employment Opportunity, Discrimination & Harassment Policy• Global Escalation of Concerns Policy and associated hotline• Statement of policy on the prevention of corrupt practices• Health & Safety Policy (UK)• Reference Checking
Our Global Escalation of Concerns Policy is intended to ensure that every Wellington employee knows about and hasaccess to effective avenues to voice any concerns regarding wrongdoing or misconduct at the firm. This policy is
supported by our third-party “Concerns Hotline,” which enables employees to raise concerns on an anonymous orattributed basis via phone, internet, email, or mail. In addition to reinforcing the importance of voicing concerns, thepolicy also makes clear that the firm will not tolerate any form of retaliation against an employee who acts to voice
concerns. In addition, we provide mandatory training on anti-money laundering and anti-bribery and corruption to
all new employees, and annual training to all employees across WMIL. We will continue to utilise our corporate
sustainability strategy, procurement procedures, and employment policies to raise awareness of the Act withemployees and suppliers to help mitigate the risks of slavery and human trafficking in our business.

INVESTMENT MANAGEMENT
ESG is a broad term that refers to one or multiple Environmental, Social and/or Governance issue(s). At Wellington,
we consider ESG as one set of factors among many that should be weighed appropriately to inform investment
decision making. ESG research at Wellington is centralised and available to all portfolio managers and investment
teams. Across Wellington globally, investment teams may incorporate ESG research into decision making asappropriate and consistent with their investment approach. Ongoing interactions between the centralised....................................................................................................................................................................................................................................................
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Sustainable Investment Team and portfolio managers related to company engagement, proxy voting, and portfolio
reviews are all opportunities for portfolio managers to monitor ESG issues and trends.
In 2022, we continued to broaden our research on supply chains and labour rights, with the goal of better assessing
risks and promoting the adoption of modern-slavery risk-management best practices in our investee companies.
These efforts included improving our data platforms and related insights and expanding the use of due diligence
tools, including a proprietary engagement survey. Across Wellington globally, our investment teams may use
collected survey results, as well as research conducted by our ESG analysts within their sector ESG materiality
frameworks, to assess the quality of investee company awareness and diligence in managing labour risk.
We also strengthened our engagement capabilities on labour rights and modern slavery in 2022. As part of ourintegration efforts with regards to these topics, our research teams closely collaborate with portfolio managers andclient account teams to engage with external stakeholders such as issuers and data providers in cases where webelieve engagement may help mitigate risk of slavery and human trafficking to the portfolio.
This statement was approved by the Board of Wellington Management International Ltd on 22 May, 2023.

Signed: ___________________________
Name: Edward J. Steinborn
Title: Director....................................................................................................................................................................................................................................................
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