Modern Slavery StatementWellington
Management Australia Pty Ltd ABN 19 167 091 090
As an additional measure, we reviewed a subset of the suppliers paid by WMA in calendar year 2021, focusing on
Financial Year Reporting Period: 1 January 2021 to 31 December 2021
those suppliers with spend of greater than US$25,000 to ensure where appropriate, such suppliers arecommitted to adhering to the Modern Slavery Act CASH_TBA_OFFSETINTRODUCTION
This document is a Modern Slavery Statement (Statement) issued by Wellington Management Australia Pty Ltd(WMA) in accordance with the Modern Slavery Act 2018 (Cth) (Act) and has been approved by the Board of WMA as
its principal governing body.
This Statement outlines our commitment and steps taken in identifying and addressing modern slavery risks within
our business and supply chain to address the requirements of the Act. Our review for the financial year 2021 foundthat no changes to policy nor approach are required to ensure that WMA continues to meet its obligations under theAct.

STRUCTURE, OPERATIONS AND SUPPLY CHAIN OF THE REPORTING ENTITYSTRUCTUREWMA, a proprietary limited company organised in Australia (ABN 19 167 091 090), conducts business development
and client support services in Australia and New Zealand. The office opened in January 1997 and WMA holds anAustralian Financial Services Licence (no. 462912). WMA does not own or control other entities.
WMA is 100% owned by Wellington Management Global Holdings, Ltd., a Bermuda-domiciled holding company. Theultimate parent company of the Wellington Management organisation is Wellington Management Group LLP, aMassachusetts private limited liability partnership owned by 195 partners, all fully active in the business of the firm andwhich has operations in North America, Europe and Asia Pacific regions. Approximately 900 investment professionals
are employed across the Wellington Management Group (Wellington Management).
Sydney, Australia(30 employees)

Address

Wellington Management Australia Pty
Ltd

Level 17
126 Phillip Street
Sydney NSW 2000
Australia
Telephone: +612-8233-6400

All employee data is as of 31 December 2021
OPERATIONS AND SUPPLY CHAIN
WMA is engaged exclusively in investment management and serves as a trusted adviser and strategic partner toprofessional investors and wholesale clients.
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 and employee related services: such as legal, tax, audit/accountancy advice; external training
and recruiting providers; employee insurance and benefit providers
Workplace services: services which support the running of our day-to-day business (e.g., cleaning, catering,
office equipment maintenance services and property management)
Technology and data services: systems, software and hardware purchased to provide the technology
infrastructure required to undertake our business; market data services
Travel services: as a global organisation serving clients in many different countries, our staff undertake global
travel; as such, we engage with a number of travel service providers

Note that historically the firm has engaged in a significant amount of travel. However, like many aspects of ourbusiness, we continually re-evaluate the benefits and costs associated with areas of significant business activity.
Travel is one such area that has been impacted by the implications of COVID-19. As such, travel may prove to be a less
impactful element of our procurement expenditures in the future as we adapt the manner in which we conduct ourbusiness to current and future considerations.

RISKS OF MODERN SLAVERY PRACTICES IN OPERATIONS AND SUPPLY CHAIN
Modern slavery has been defined by the Act to include eight types of serious exploitation:






Trafficking in persons
Slavery
Servitude
Forced labour
Forced marriage
Debt bondage
The worst forms of child labour
Deceptive recruiting for labour services

INVESTMENT MANAGEMENT
As a professional financial services organisation, WMA considers the risk of modern slavery within its Australianbusiness operations to be low. However, we recognise that there may also be modern slavery risks through its
investment management activity. In order to assess a company, we believe there are multiple factors we shouldconsider.

Sector/industry exposure risk: Certain sectors and industries may have high modern slavery risks becauseof their characteristics, products and processes. Indicators of this type of risk include the use of unskilled,temporary or seasonal labour, use of short-term contracts and outsourcing, use of foreign workers or
temporary or unskilled labour to carry out functions which are not immediately visible (i.e., at night), security
and cleaning.
Geographic risk: Certain countries may have higher risk of modern slavery, including due to poor governance,
weak rule of law, conflict, migration flows and socio-economic factors.
Entity risks: Certain entities may have exposure to modern slavery risks because of poor governancestructures, a record of treating workers poorly or a track record of human rights violations.

Our clients are invested in a variety of investment strategies, including both commingled funds and separate accounts,
with broad global and regional supply chains. As such, the underlying companies in which we invest span many
sectors/industries, countries and entities, some of which have increased exposure to modern slavery risks. We
acknowledge that the risks of modern slavery may be heightened in some of our investee companies’ supply chainsand operations as a result of the geographical location of some suppliers and areas of operation.

ACTIONS TAKEN BY THE REPORTING ENTITY TO ASSESS AND ADDRESS RISKS,INCLUDING DUE DILIGENCE AND REMEDIATION PROCESSESPOLICIES AND PROCEDURES
We are committed through our Corporate Sustainability Initiative (CSI) to incorporating socially and environmentally
sustainable behaviour into everything we do, including sound governance and engagement with our employees, ourcommunity, and our environment. We will utilise our procurement procedures and employment policies to raiseawareness of the Act with employees and suppliers to help mitigate the risks of slavery and human trafficking in ourbusiness. These global policies and procedures 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
Escalation of Concerns
Harassment and Discrimination Policy
Reference Checking

Employees are encouraged, and in some cases our policies require, that they share any concerns they may haveregarding misconduct or wrongdoing with their immediate line manager, or an appropriate representative from ourEmployee Relations / Human Resources department. Additionally, employees are directed to share any concerns
relating to money laundering with the firm's anti-money laundering officer.
SUPPLY CHAIN
WMA is committed to continuously improving awareness and responding to the risk of modern slavery in its
operations and supply chain. The nature of our business activities and the high standards that we expect from both
our suppliers and ourselves is reflected in our overall assessment that the risk of modern slavery in our supply chain islow. We have a centralised procurement function responsible for Wellington Management’s vendor management
processes globally. Within this function, there is a Third-Party Risk Management (TPRM) team that initiates the due
diligence review process for new suppliers as well as periodic ongoing reviews for certain existing suppliers.
In order to assess and reduce risk, we undertook a review of suppliers utilised during the 2021 financial year, alongwith our procurement and vendor oversight processes. As part of our initiative to identify and mitigate slavery andhuman trafficking risk, we have taken a risk-based approach to our evaluation. With regards to our own supply chain,
we have a zero-tolerance policy to modern slavery and human trafficking. Where applicable, we may incorporate
modern slavery related provisions in our contractual agreements, and we may also request that a supplier provide
information regarding the necessary actions it has taken to prevent or remediate modern slavery in its business or its
supply chain. Third party service providers are systematically identified and reviewed for potential modern slavery
risks at onboarding, based on risk factors such as the third party’s industry and country of operation. On a periodic
basis, the subset of the vendor population meeting these high-risk criteria are compared against the broader service
provider population to validate that applicable third parties presenting potential modern slavery risk have been
identified, and that the associated risk has been evaluated and appropriately mitigated where applicable. Should any
supplier be 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 modern slavery
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.

INVESTMENT MANAGEMENT
Wellington Management is taking a multi-layered approach to tracking and managing the risk of modern slavery inclient portfolios. First, we have provided training to sector and sovereign research analysts to increase theirunderstanding of modern slavery, how it might show up in company and country securities, and the questions analysts
might ask when meeting with company and country leadership. Second, we have worked closely with MSCI to ensurethat we are making full use of their current screening tools and are collaborating with their research team as they
develop new screening tools for sovereign issuers in particular. Additionally, we have developed a proprietary surveythat portfolio managers may leverage to assess the quality of investee company awareness and diligence in managing
this risk in their own operations and supply chains. In order to assess a company, we believe there are multiple factors
we should consider.


Industry: Products and services linked to the use of low skilled labor or where the use of migrant labor iscommon in the production and/or delivery the products and services are at highest risk of modern slavery.
These commodity-like/low-skilled workforces typically have less power in the workplace and workers are moreeasily substituted if they complain about working conditions and worker rights. As a result, findings of ModernSlavery are most commonly found in specific industries. Recognizing the industries where this risk is highest isa critical part of focusing our effort.
Country: Governments play a critical role in developing and implementing the laws, policies, and programs
needed to prevent and respond to Modern Slavery risk. The Global Slavery Index is produced by a globally
recognized NGO with a long track record of assessing Modern Slavery risk and generating in depth research ata country and product level. To that end, the Global Slavery Index has created a Government Response index
which includes an assessment of the actions governments are taking to respond to Modern Slavery:
https://www.globalslaveryindex.org/2018/methodology/government-response/. The framework wasdeveloped in consultation with an independent Expert Working Group (“SME Group”) and is based on findings
from NGO research and scholars in fields related to modern slavery, such as harmful traditional practices,
health, social welfare and migration.
This assessment is based on tracking government progress towards the achievement of five milestones:
No. ofMilestone
activities
Survivors of slavery are identified and supported to exit and remain out of slavery
9
Criminal justice mechanisms function effectively to prevent modern slavery
6
Coordination occurs at the national and regional level, and governments are held
4
accountable for their response
Risk factors such as attitudes, social systems and institutions that enable modern
7
slavery are addressed
Government and business stop sourcing goods and services that use modern
2
slavery
Total:
28

Percentage
weight
32%
21%
14%
25%
7%
100%**** Percentages add to total of 99% due to rounding
Across the 28 activities identified, each country is awarded a % score in the range of 0-100, with 100 being thehighest possible score. 181 countries have received ratings as part of the Global Slavery Index’s analysis. Toensure consistency with all other factors we have converted this score to 0-10 by dividing the published score by10. All Country Risk Scores will be tracked and monitored in a master spreadsheet maintained by a group ofsubject matter experts within Wellington comprised of ESG Analysts, Sustainable Investment researchers, andinvestment directors focused on the portfolios in scope.

MSCI Controversy Score: MSCI ESG Controversy scores allow institutional investors to analyze a company’s
significant social, environmental, and governance impacts by identifying company involvement in major ESG
controversies, adherence to international norms and principles, and assessing company performance withrespect to these norms and principles. Given that our focus is on reducing risk of forced or child labor
practices, we are leveraging the “Labor Rights and Supply Chain” scores specifically. All MSCI Controversy
scores are tracked and monitored in a master spreadsheet maintained by a group of subject matter experts
within Wellington comprised of ESG Analysts, Sustainable Investment researchers, and investment directors
focused on the portfolios in scope.
Company Survey: Portfolio Managers have access to proprietary company surveys. A scoring system wasdesigned by a group of subject matter experts within Wellington comprised of ESG Analysts, Sustainable
Investment researchers, and investment directors focused on the portfolios in scope. Surveys are scored outof a possible 100 points, with more weight allocated to questions that we believe are more critical to helping
companies effectively reduce Modern Slavery risk throughout their business operations and supply chains.

Ongoing interactions between the centralised Sustainable Investment Team and portfolio managers related tocompany engagement, proxy voting, and portfolio reviews are all opportunities to educate investors on ESG issues
and trends. Portfolio managers, industry analysts and ESG analysts all take part in our ongoing dialogue withcompanies, and we share engagement information using a central collaboration platform. Analysts regularly discuss
issuers, write investment notes and make comments in our morning investment meeting. This collaboration is a formof ongoing training within our firm.
In addition, Wellington Management maintains multiple internal e-mail distribution lists related to ESG and sustainable
investing in order to facilitate information sharing across multiple functions of the firm. Content shared in this forum
could include trends or common questions among clients of a certain channel and recent academic studies regarding
ESG.
We have become increasingly aware of the pernicious nature of modern slavery—particularly the potential for supply
chains and those not directly controlled by companies marketing goods to end users—to be at greater risk for humantrafficking and other human rights abuses. Wellington Management is currently undertaking a comprehensive reviewof the ways in which we can improve our due diligence and engagement efforts on this issue across our clients’portfolios.
Andria Weil, our Director of Sustainable Investment Policy, has led regional training sessions open to all colleagues on
the topic of Modern Slavery in company supply chains, in addition to dedicated sessions for our Investment Research,Client and Investment Product and Fund Strategies groups.
During the first half of each year, the Sustainable Investment Team hosts a proxy season preview to educate investors
about major governance developments, focusing on a selection of “hot topics” we expect to be most pertinent
throughout the season. This gives the Sustainable Investment Team an opportunity to reiterate any shifts in ourapproach to vote recommendations on certain topics. These sessions deepen understanding of key issues ahead oftime so that we can have more productive debates about significant votes.

HOW THE REPORTING ENTITY ASSESSES THE EFFECTIVENESS OF ACTIONS TO
ASSESS AND ADDRESS RISKSWe are in the early stages of assessing the effectiveness of our risk-based approach. Addressing the risk of Modern
Slavery within investment portfolios starts with investor awareness of the risk and where these risks are likely to beelevated. The best way to ensure there is awareness is through training. In the course of 2021 Wellington’ssustainability team provided two trainings to investors on this issue. This training has been supplemented throughinvestor discussion in common investor forums including daily morning meetings and through investor notes. To thatend, Wellington Management began tracking its engagements by topic at the end of 3Q2021. As such, in the 4Q2021
Wellington investors recorded 29 engagements across 17 issuers specifically focused on human rights/modernslavery. To support these engagements the survey described above provides investors with a structured format toengage with management. To-date Wellington has shared our survey with over 300 companies and has received
detailed responses from eighty companies. We expect over time to receive responses from substantially all companies
to which we send it but as this is a newer area of due diligence, some companies require a direct conversation toobtain their responses.
In order to ensure the effectiveness of our actions as it relates to modern slavery risk in WMA’s supply chain, thecentralized procurement team (inclusive of Third Party Risk) periodically reviews our risk assessment andprocurement processes to ensure they remain up to date and appropriate (leveraging a risk-based approach). As anadditional measure, we reviewed a subset of the suppliers paid by WMA in calendar year 2021 to ensure whereappropriate, such suppliers are committed to adhering to the Modern Slavery Act.

CONSULTATION PROCESSAs there are no subsidiaries or entities owned or controlled by WMA, this requirement is not applicable.

OTHER RELEVANT INFORMATION
There is no other relevant information for this reporting period.

APPROVALThis Statement was approved by the Board of Directors of Wellington Management Australia Pty Ltd on 27 June 2022.

Signed by:-------------------------Name: Aisling Freiheit
Title: Director