Modern slavery
statement

June 2024

www.hermes-investment.com

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Modern Slavery
June 2024

1. Federated Hermes Limited –Modern Slavery Statement
At Federated Hermes Limited (“FHL”), we are committed torunning our business responsibly. We endeavour to upholdhigh ethical principles and to respect human rights. We do
our best to encourage high standards in our business andsupply chain. In this context, we use the requirements set out
in the Modern Slavery Act 2015 (the “Act”) as an opportunity
to review the way in which we operate our own business,
together with the way that we interact with others, including
our clients and suppliers. We have also considered the area
where we have the ability to make the most impact – ourinvestments. Our objective is to ensure that there is no
modern slavery or human trafficking in any of our businessdealings.
The Act defines modern slavery as the offences of ‘slavery,
servitude and forced or compulsory labour’ and ‘humantrafficking’.

2. About Federated Hermes Limited
This Modern Slavery Statement is made by FHL on behalf of
itself and its subsidiaries (including but not limited to Hermes
Investment Management Limited and Hermes GPE LLP), forthe financial year ending 31 December 2023. FHL and its
subsidiaries are collectively referred to throughout thisStatement as “FHL”.
FHL is a wholly owned subsidiary of Federated Hermes, Inc(“FHI”).
Since our beginnings, we have sought to help clients achievestrong risk-adjusted returns through our specialised equity,
fixed-income, and private-market strategies and, more
recently, our multi-asset and proven liquidity-management
solutions. Through EOS at Federated Hermes (“EOS”), ourstewardship service provider, we engage companies on
strategic and material environmental, social and governance(“ESG”) concerns to promote investors’ long-term
performance and fiduciary interests. Our goals are to help
individuals invest and retire better, to help clients achieve
better risk-adjusted returns and, consistent with client
objectives and applicable requirements, to strive tocontribute to positive outcomes in the wider world.
We always endeavour to meet our legal and regulatory
responsibilities, conducting our business with the highest
standards of integrity and honesty, and we expect all
employees and suppliers to maintain the same standards.
We consider any failure to achieve these standards as aserious matter.
As of 31 December 2023, FHL had £39.3bn in assets undermanagement and EOS, had approximately £1.2tn in assets
under advice. EOS offers a shared service model, providing
voting recommendations, portfolio screening, public policy
and market best practice work and advisory services on behalfof both FHL and third-party clients.

Modern Slavery
June 2024

3. Our business & supply chain
FHL had 589 permanent employees and 70 full-time
contractors as at 31 December 2023, most of whom are basedin the UK with some employees also located in Singapore,
Ireland, Germany, Denmark, Spain, Switzerland, Australia,
Japan, US, Italy and Norway. We outsource both material andother functions to service providers and in some cases thisinvolves employees of our service providers working onsite in
our offices. We also use several professional services firms
including lawyers, accountants and other contractors and wehave contracts with suppliers to receive brokerage services
both for FHL and on behalf of our clients. Additionally, we
purchase a variety of products, including IT hardware andcorporate branded merchandise (including clothing). Some ofour suppliers who are appointed on behalf of our clients (inparticular in relation to our Real Estate business, including
MEPC Limited) operate in sectors identified by theInternational Labour Organisation as high-risk for modern
slavery, and we therefore recognise the importance ofappropriate levels of due diligence in relation to our supply
chain.
We are a signatory of the United Nations Global Compact(“UNGC”) and from 2024 will report annually in line with the
new Communication on Progress framework.

a) Culture and behaviours at Federated Hermes
LimitedOur Code of Business Conduct and Ethics sets forth certain
minimum expectations that FHL has for all employees.
Employees are expected to conduct the firm’s business in fullcompliance with both the letter and the spirit of the law andany other policies and procedures that may be applicable tothem. This includes the Act.
At FHL we have a strong culture of responsibility and believethat it is a far wider concept than just shareholder
engagement. We believe we should lead by example, and wehave therefore created the Federated Hermes Pledge, an
expression of our commitment to always act responsibly andtransparently. This was first established by FHL in 2015 andadopted by FHI in 2018. The Federated Hermes Pledge (seeAppendix 1) makes clear our commitments, obligations andresponsibilities as an organisation and as individuals. FHL iscommitted, in the way that it interacts with others, to treating
everyone fairly, and with dignity and respect. We expect all of
our employees to match this commitment throughout their
day-to-day work and activities.
FHL has also articulated a set of behaviours innate to ourculture that contribute to the success of the business and are
visible manifestations of our Pledge. Every employee has a
responsibility to act in a way that upholds our core behaviours
through their day-to-day activities. All individuals are rated
equally on their behaviours and on their technicalperformance as part of the performance management
process, to encourage a focus on meeting the needs of ourclients and beneficiaries and, where possible, supporting ourcommitments to society and to the environment. Individuals

will be highly rated if they perform successfully while
embodying our behaviours as conveyed in the Pledge.
Where relevant to specific roles, ESG objectives areembedded into this process.
At FHL we support and respect the protection ofinternationally proclaimed human rights. We are committed
to preventing and ending all forms of human rights, childlabour and modern slavery abuses; and are committed tofostering a work environment that is diverse, inclusive, andfree from discrimination and harassment (physical or verbal).
The Code of Business Conduct and Ethics, the Federated
Hermes Pledge and our behaviours support our efforts toensure we act as a transparent, responsible, and ethicalbusiness. We believe this will help us to identify and hopefully
prevent instances of human exploitation in our businessdealings. In 2019, the Financial Conduct Authority (“FCA”)
introduced the Senior Managers and Certification Regime(“SMCR”). This introduced new Conduct Rules for all
employees. The rules include, but are not limited to, arequirement to act with integrity; to act with due skill, careand diligence; and to observe proper standards of market
conduct. Certain employees who, because of their role aredefined as Senior Managers under SMCR, are also subject toan additional set of Conduct Rules. All employees at FHL
receive training on these Conduct Rules and have access toan intranet microsite with information on SMCR.

b) Protecting employees
Background checks are conducted on all new employees toensure they have the right to live and work in the relevant
jurisdictions, with periodic checks being repeated for certain
employees throughout their employment.
We encourage open communication, in keeping with theFederated Hermes Pledge, and regard integrity as a central
part of our beliefs. We encourage employees to bring any
concerns to the attention of their immediate supervisor or
manager. To that effect, we have a Whistleblowing policy inaccordance with the Public Interest Disclosure Act 1998(“PIDA”) – also referred to as ‘The Whistleblowers’ Act’ in the
UK and the Whistleblower program in the US – which stipulates
that employees are legally protected from dismissal orunfavourable treatment by their employers as a result of raisingconcerns. Employees can raise concerns around any suspicionsof, or any circumstance that may give rise to an enhanced riskof, modern slavery or human trafficking. Employees may also
report such matters directly to the Chief Compliance Officer or
the Chairman of FHL. However, we recognise the difficulty inreporting through internal channels and that employees may
prefer to remain anonymous. To that effect, we also provide
several secure, anonymous reporting routes via a hotline andonline reporting.
All statutory requirements of minimum pay are met across ouroffices. Since 2012, FHL has been accredited as a Living Wage
employer, affirming its commitment to provide all employees
and on-site contracted staff in the UK with compensation andbenefits at or above the London Living Wage. As an
accredited employer, we ensure that all employees are paid
at a minimum the London Living Wage, which is an hourly
rate, set independently every year. As part of ouraccreditation as a London Living Wage employer, we also
contractually require our service providers who have
employees working onsite in the London office to pay the
London Living Wage or more. This ensures that all employees
and contractors can meet the costs of living in London. We
also expect our suppliers in the UK to meet Living Wage
Foundation minimum requirements.

c) Procurement & Suppliers
At FHL, we are committed to running our business responsibly.
This requires high standards to be maintained within our supply
chain. We expect all our Suppliers to meet the minimum
standards set out in this Statement and fully comply with allapplicable laws and regulations in relevant jurisdictions when
conducting business with, and on behalf of, FHL. Our
procurement processes apply across all offices of FHL. We havea Supplier Code of Conduct, available on our website, which
we ask all new suppliers to sign. Please see Appendix 2 for an
extract of our Supplier Code of Conduct. We promote bestpractice for responsible procurement and ask suppliers forevidence of their ESG practices when sourcing, covering thefollowing core areas: environmental, social, diversity andinclusion, economic and governance issues.
Like many of our peers, our supply chain is large and complex,
with multiple layers and across many industries. We haveconsidered how our business operations may be affected bymodern slavery issues. Where necessary, increased levels ofdue diligence are performed to ensure suppliers not only
deliver a quality service, but also manage risks. Basic due
diligence is performed on all suppliers through policies, tax
compliance, and ongoing screening of financial stability,
conflicts of interest and compliance monitoring. We endeavour
to use suppliers that have values aligned to our own.
As part of the basic due diligence checks, all suppliers arescreened at onboarding and on an ongoing basis to identify
any adverse information or sanctions that may suggest our
suppliers are not acting in accordance with our Supplier Codeof Conduct or are designated under Global Human Rights
Sanctions regimes. Certain supplier arrangements that are
deemed to be material outsourcers or business critical are
subject to enhanced due diligence and on-going monitoringon a quarterly basis. This includes carrying out periodic onsite
due diligence with our material and outsourcing suppliers. In
2018, we added modern slavery to the scope of our due
diligence and suppliers are requested to provide information
on how they manage modern slavery risks within their own
supply chains. In addition to performing due diligence on our
suppliers, we also perform due diligence on other business
relationships with investors and investees as part of our KnowYour Customer checks to identify areas of higher modern
slavery risk.

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4. Responsible investment and ownershipAs a leading investment management house, we invest in avast range of public and private markets across the globe.
Although the Modern Slavery Act does not, strictly speaking,require us to consider our investments for the purposes of thisStatement, our position as an investor gives us an opportunity
to exert influence over other businesses and it is a
responsibility that we recognise and which is encouraged by
the Organisation for Economic Cooperation andDevelopment (“OECD”).
From our 1983 inception through to the present day, ourpurpose has been to deliver enduring, responsible wealthcreation for investors over the long-term. We believe there
are four mutually reinforcing strands of being a responsible
investment manager: active ownership and management;
advocating in beneficiaries’ interests; ESG-integrated
investments; and behaving as a responsible business.
Together, these aim to generate enduring, responsible wealthcreation for the end beneficiary investors, encompassing
investment returns and their social and environmental impact.
With our past and future aims firmly based around a longterm and responsible approach, our structure provides thebenefit of access to a broad range of dedicated, highconviction investment teams, combined with an establishedand robust operating platform. Our engagement team EOS
enables institutional asset owners around the world to meettheir fiduciary responsibilities and become active owners of
their assets.
As responsible investors, we embrace high-active-shareinvesting. We take a holistic approach that integrates material
ESG considerations and engagement insights into all of ourinvestment products, something that offers our fundmanagers an additional vantage point with which to assess
an asset’s potential to deliver long-term sustainable wealth.
We firmly believe that our ability to mitigate ESG risks andcapture the investment opportunities arising from these
considerations is essential to achieving consistent investment
outperformance for our clients.
As signatories to the UK Stewardship Code and in accordancewith our Engagement Policy, we are committed to be active
owners of the companies in which we invest. Meanwhile, ourEngagement Plan sets out the expectations we have of ourinvestee companies with which we engage. This includes our
expectations around relationships with stakeholders, workers
and human rights. Companies are expected to ensure thatthey respect the human rights of those affected by theiroperations and their value chains. They should develop plansto identify and manage these human rights risks to minimise
adverse and encourage positive human rights outcomes. At
the very least, companies should not only obey the law but
respect the human rights of those affected by their activities
and be open about and prepared to discuss the impact of
their activities.

Modern Slavery
June 2024

In September 2023 we published our inaugural Human Rights
Policy Statement. This statement sets out our commitment
to respecting human rights in accordance with the United
Nations (“UN”) Universal Declaration of Human Rights; theInternational Labor Organization’s (“ILO”) Declaration on
Fundamental Principles and Rights at Work; the UNGC;
and the UN Guiding Principles on Business and Human
Rights (“UNGPs”). This commitment applies to all of ourinvestments, in all asset classes and in all geographies. We arecommitted to integrating human rights issues (as one aspectof wider sustainability and governance issues) into ourinvestment analysis and decisions across all asset classes.
We are also committed to using our influence as a large
asset manager to engage with the companies we invest in
to protect and respect human rights.
Research and analysis by all of our investment teams includes
an evaluation of performance on strategy, financials, risk,
and material ESG factors, and the overlaps between theseelements. The teams supplement fundamental financial
analysis with information provided through a range ofproprietary ESG and engagement tools, qualitative analysis
and the insights gleaned through engagement. Our
dedicated Responsibility Office – which reports directly into
our CEO via the Head of Responsibility - works with all
investment teams across all asset classes to support them in
integrating material ESG and engagement insights into theirinvestment decisions and the monitoring of investees.
We have two employees working full-time on public policy
matters in the Responsibility Office. This includes the Head of
Policy and ESG Integration, whose team works with experts
across our firm to ensure advocacy work is well informed,
relevant, and impactful. EOS also has a comprehensive
programme of engagement with legislators, regulators,
industry bodies and other standard setters to help shapecapital markets. The result is an advocacy policy that aims tolead rather than follow the policy debate. For example, we
work with the Living Wage for US and the Living Wage
Foundation in the UK.

a) Public markets
For public markets, we have acquired a number of different
datasets from multiple third-party vendors that provide us
with information on a company’s exposure to ESG risks andopportunities. This also allows us to screen for controversies
linked to human rights as well as identify companies that may
be in breach of the UNGC Principles, including Principles 1
and 2 which are linked to human rights.

controversies and identifies contingent risks. Our portfolio
managers use this tool to evaluate a strategy’s ESG
performance over time. It also provides insights into
engagement and the progress made, and our voting choices
relative to the benchmark. Through these tools, along withadditional EOS engagement information, the public-equities
and fixed-income teams have access to third-party ESG data,
as well as insights on engagement carried out by EOS withinvestee companies and the broader investable universe.
These sources are a valuable input to the investment process,as well as to the ongoing monitoring of and engagementwith companies.
Since first engaging for stronger corporate governance in
1983, we have built a compelling story for responsible
ownership. Insights from engagement with company
management, boards, subject specialists and othershareholders and stakeholders – including the extent ofengagement progress – is a key input into our investment
strategy. Such engagement is carried out both by ourinvestment teams and by our stewardship business, EOS,
on their behalf.
Through EOS, we engage companies on strategic andmaterial ESG concerns to promote investors’ long-term
performance and fiduciary interests. EOS offers a sharedservice model, engaging on behalf of both FHL and thirdparty clients. EOS provides a platform for like-minded
investors, creating a powerful force for positive change.
The team works on behalf of long-term global investors who
entrust us with the stewardship of approximately £1.2tn /€1.3tn / $1.4tn (as at 31 December 2023) invested in over
10,000 companies worldwide, working collectively in supportof shared goals. This pooling of assets increases the influence
we can have with companies, which means we can have amore meaningful impact on the issues of most collective
importance to our clients. EOS engaged with 1,041
companies in 2023 on 4,272 identified environmental, social,governance, strategy, risk and communication issues andobjectives, as well as offering voting recommendations forover 12,963 company meetings.1
EOS engages in active stewardship on behalf of FHL, FHI andthird-party clients, providing voting recommendations forannual shareholder meetings and other shareholder
gatherings to achieve our clients’ responsible ownership aims
and fulfil their fiduciary duty to be active owners. EOS also
screens clients’ aggregate holdings for ESG characteristics.
Our Controversial Companies Report highlights to
subscribing clients those companies which are considered

We have also developed a number of proprietary ESG tools
to support company and portfolio level ESG analysis,
including on human and labour rights. Our ESG Dashboard
includes our proprietary Quantitative ESG (QESG) Score andidentifies stocks with positive ESG characteristics and/or
stocks demonstrating positive ESG change. The QESG score
captures how a company manages its ESG risks. The
dashboard includes a snapshot of what themes that company
has been engaged on along with progress made. The
Portfolio Snapshot allows us to examine ESG ratings and1

On behalf of both third-party clients and FHL Managed Funds.

to be in violation of internationally recognised guidelines andprovides insight into the nature of those guideline violations
and a view on engagement with the company on the issues.
The list identifies companies that are either in breach of or
likely to breach the UNGC Principles. This includes principles
relating to human rights and labour, in particular UNGC
Principle 4: ‘the elimination of all forms of forced andcompulsory labour’. The report also highlights for eachcompany where we are engaging on these issues.
EOS engages with companies on human and labour rights toensure they respect all human and labour related rights linked
to a company’s operations, products and supply chains,
including through the provision of affordable essential goods
and services to help reduce poverty. We encourage companies
to apply the UNGPs and to carry out appropriate due diligence
which seeks to identify forced labour indicators, such as
potential exploitation of migrant workers in supply chains. Our
engagement on supply chain worker rights specifically focuseson aligning company activities with UNGPs; developing anapproach to manage risks associated with forced labour, childlabour, working conditions, and other relevant issues in its
supply chain; and implementing purchasing practices tomanage supply chain human rights risks.
FHL generally favours engagement over exclusion, as we
believe that having a seat at the table gives us greater power
to influence than exclusion and divestment.
In 2023, both FHL and EOS participated in the PRI’s Advanceinitiative, the collaborative stewardship initiative for humanrights and social issues launched in 2022. The objective of theinitiative is to advance respect for human rights, minimisingnegative outcomes and drive positive outcomes for people.
The metals and mining and renewables sectors were selected
as the initial focus based on an assessment of the highest risk
sectors and the practicality of engaging with these sectors. 40
focus companies have been selected for engagement,
comprising 25 metals and mining companies and 15
renewables companies. Three key expectations have been set
for the focus companies: to implement UNGPs, to align theirpolitical engagement with their responsibility to respecthuman rights, and to deepen progress on the most severe
human rights issues in their operations and across their value
chains. As participants, both FHL and EOS committed to takeon the role of lead engager with at least one company as wellas supporting other engagements. As of 31st December 2023,
FHL and EOS combined are involved in 11 company
engagements: leading engagements with 4 companies
and supporting with a further 7 companies.

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Modern Slavery
June 2024b) Real Estate
CASE STUDY

Hon Hai Precision Industry

Background
Hon Hai Precision Industry Co., Ltd. (known internationallyas Foxconn) is a Taiwanese multinational electronics
contract manufacturer.
EOS have engaged with Hon Hai on the topic of labour
policy and practices since 2010, including improving its
human capital management strategy to address labour
rights concerns. In April 2023, EOS were invited by thecompany for a production campus tour in Zhengzhou,
China where we could see first-hand the implementationof the company’s human capital management strategy.

Engagement
EOS began engaging on labour standards in 2017 after
controversies arose surrounding working conditions.
Despite being an employer of over one million people
globally, Hon Hai did not appear to have a robust humancapital management strategy. It recognised that staff
turnover was high, with most of its human resources work
focused on administration, and it was unclear to what
extent the issue was on the board’s agenda. Although thecompany was tracking various human capital metrics, none
were disclosed.
In 2017, media reports claimed that student workers aged
17 to 19 were working long hours and overtime, which
violated local law.2 The company acknowledged that
there were operational oversight issues. EOS discussed
responsible remedial actions including the terminationof the existing student worker programme and for thecompany to raise the working age to the international
labour standard of 18 years old, rather than adhering to the
local standards in China of 16 years old. We continued toengage with the company on human capital management
topics over this period.
In October 2022, we turned our attention to ensuring thatthe company demonstrates that working conditions acrossits supply chain outside of China meet international
standards. Following media reports that indicated subpar
working conditions in the company’s Indian plant3, wepressed for better disclosure of audit results and actions
taken to address labour standards, with more emphasis on
grievance mechanisms, employee engagement and welfare.

2
3

In early 2023, EOS was invited by the company to a factory
tour in Zhengzhou, the location of the protests. One of theaims was to understand the circumstances leading toemployee protests and to conduct a due diligence visit at
the social and living facilities for employees. EOS was the
only investor representative to gain access to the site,
providing a unique opportunity for direct engagement withthe most senior management of the Zhengzhou plant.
During the tour, we were able to visit most of the social
facilities, including the learning and development centre,
job training centre, canteen and, most importantly, theliving quarters. Positively, the company allowed EOS toselect any room, floor and block of any dormitory in aneffort to meet our due diligence requirements. Our EOS
engager stayed in an employee dormitory during the twoday tour and also dined in the assembling worker canteen
before departure.

Engagement Outcomes
In addressing our labour rights concerns over the years, thecompany stated in 2020 that it had developed a labour
strategy, approved by the board, which prevented students
under the age of 18 from working in production. In May
2022, we were pleased to see the company’s new longterm social goals as part of its ESG strategy.
During the 2023 engagement, the company provided an
update on its revised value chain code of conduct. It also
provided updates on its recent labour issues, which included
a comprehensive update on how issues arose and wereresolved. The company added that 100% of its production
plants are internally audited as well as an independent thirdparty audit of its principle customers. It also confirmed that
it would expand disclosure of data outside of China in its
next ESG report, due for release in 2024.
We believe that through these and other measures, Hon
Hai has made significant positive steps towards a more
holistic human capital management strategy.

Financial Times, ‘Apple’s iPhone X assembled by illegal student labour’ (November 2017).
Reuters, ‘Foxconn India’s iPhone plant restarts production after December protests’ (January 2022).

Modern Slavery is an area that the team assesses andmonitors when managing real estate assets and deliveringurban regeneration schemes. We include specific references
to the Act in all of our property management agreements,
which have recently been updated and cover the whole of ourmanaged portfolio including the related supply chain. In all
new lease agreements we endeavour to include arequirement to comply with the Act. Across our construction
and appointment documents with professional consultants inthe portfolio we also endeavour to make specific reference to
the Act, requiring compliance with all relevant legislation.
Where this has not already been done, we are working on
adding these clauses.

c) Infrastructure
Our engagement with infrastructure portfolio companies
includes continued assessment of social matters consideredmaterial to the portfolio as a whole and includes modern
slavery, alongside workforce health, safety and wellbeing,
diversity, equity and inclusion, fair working conditions andcommunity engagement. We are particularly focused on
businesses with significant numbers of employees and/or
contractors, as well as businesses with supply chains wheremodern slavery may be considered a more material risk.
Our engagement is focused on commitment to the principlesof the Act and the application of those principles in policies,
controls and processes across companies’ workforces andsupply chains. In our capacity as an investor in large
operational businesses with their own executive management
teams, we engage with boards, management, operational
teams and contractors to raise awareness, challenge
processes and interrogate controls. As an investor in smaller
assets with fully (or largely) contracted workforces, we workwith our contractors to ensure sufficient awareness, toenshrine commitments to not rely on forced or compulsory
labour and ensure adequate labour standards and working
conditions in corporate policies dealing with health andsafety, inclusion and diversity and supply chain management
and to undertake supplementary due diligence on suppliers
where necessary.

d) Private equity
Our private equity team invests both in private equity funds
raised by third party managers (GPs) as well as directly into
private companies as a minority co-investor in transactions led
by funded or partner GPs.
Given this indirect approach to investment, the team rely on
the lead GPs to ensure all direct and indirect investments tocomply with all applicable regulations including the Act andonly invest with GPs where there is enough comfort on the
rigour of their policies and practices including continuing
assessment of social risks such as health and safety, safety

culture, employee welfare, diversity, equity and inclusion,community involvement, supply chain management andmodern slavery.
Ahead of investments in funds, the team assess the ESG
policies and practices of each GP and for direct investment
opportunities the team assess the ESG risks of each
investment and will conduct additional ad-hoc due diligence
where relevant. Post- investment all deals are monitored for
ESG risks including modern slavery on a quarterly basis.

5. Training
We regard training as fundamental to raising awareness ofthese issues. A copy of our latest Modern Slavery Statement
is available to all employees and included in all new joiner
welcome emails.
As a financial services firm, we provide anti-money laundering,terrorist financing and anti-bribery training to all new
employees and then annually across the firm. We haveintroduced information on the Act and an overview of ourModern Slavery Statement into the Compliance training for
all of our new starters.
We will also consider appropriate internal education for ourinvestment teams to help them identify red flags whenassessing investment opportunities. Human rights is one of
our key themes for our engagement and stewardship work.
We have a dedicated human rights theme team which
supports EOS’ engagements with companies on this topic,
where it is identified as a material ESG consideration. The
insights gleaned from our engagements with companies aswell as our thinking about human rights as an engagement
theme are made available to the investment teams and assuch are integrated into the investment decision making
process. We also run regular sectoral knowledge sharing
sessions between our engagement team and the investment
teams, so that the investment teams get a better
understanding of the sectors in which human rights practices
constitute a material ESG issue.

6. Identification and measurement of
our success
By encouraging our employees to speak up if they haveconcerns about working conditions and by asking our
suppliers to agree to our Supplier Code of Conduct, we hopethat we are equipped to identify issues of modern slavery andhuman trafficking, should they occur. In line with FHL’s
investment philosophy, if we do identify issues, we will not
automatically withdraw from the relationship or investment.
We will seek to engage with relevant stakeholders, with theaim of resolving the issue. We will take a similar approach toengaging with any suppliers where we have concerns in orderto encourage full compliance with the Modern Slavery Act.

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There are occasions where small and medium enterprise
suppliers bid for work but fall short of our standards onpolicies and procedures in this area. In such cases, we haveoffered assistance to help the suppliers to upskill in order toalign to our standards.

Modern Slavery
June 2024

APPENDIX 1 – Federated Hermes Pledge

Compliance with the Code, laws and regulation

Social Obligations

The Federated Hermes Pledge underpins our firm-widecommitment to always put clients first, and to act responsibly
and transparently.

A I will act ethically, responsibly and with integrity.

To drive continuous improvement and to ensure Suppliers arealigned with our commitment to high environmental, socialand governance standards and behaviours, FHL will consider
a Supplier’s performance in line with this Code when making
sourcing decisions and through supplier management. When
conducting business with, and on behalf of, FHL, we expect
our Suppliers to:

At FHL we support and respect the protection ofinternationally proclaimed human and labour rights. We arecommitted to preventing and ending all forms of humanrights, child labour and modern slavery abuses; and arecommitted to fostering a work environment that is diverse,
inclusive, and free from discrimination and harassment. We
expect our Suppliers to:

A I will put the interests of our clients first, consistent with our

A Comply with all relevant laws and regulations in the

A Manage their operations and supply chain in a manner

I pledge to fulfil, to the best of my ability and judgment and inaccordance with my role, this covenant:Saker Nusseibeh, CBE, Chief Executive Officer
This Modern Slavery Statement was approved by the board of
directors of Federated Hermes Limited on 20 June 2024.

fiduciary responsibilities.

A I will encourage responsible behaviour in the firms in which
we invest and on which we engage.

A I will act with consideration for our community and theenvironment both now and in the future. I will encourageothers to do the same.

A I will work with industry colleagues and other key
stakeholders to develop and improve our industry’s
contribution to society.

A I will treat my clients, my colleagues and all otherstakeholders with dignity and respect and as I would wish
to be treated.

A I will deal with our regulators in an open, co-operative andtimely way.

A I will communicate clearly and honestly with all parties
inside and outside our firm.

A I will manage conflicts of interest fairly between all parties.
APPENDIX 2 – Extract from our Supplier Codeof Conduct
PurposeAt Federated Hermes Limited (“FHL”) we are committed torunning our business responsibly and to upholding the highest
environmental, social and governance standards, as well as
ethical conduct. We believe we have a responsibility as abusiness to make the right choices and play our part in acting
as a responsible owner, investor and firm, by considering theimpact our decisions have on the environment, society and thewider world. We have a mission to promote best practice for
Responsible Procurement and are committed to managing ourexisting and future Supplier relationships in an ethical,
transparent and responsible manner.

Scope and application
This Code outlines the minimum standards and expectations
FHL has for all its Suppliers, contractors and business partners(“Suppliers”), including, where relevant, their respective supply
chains. Suppliers are responsible for all activities associatedwith disseminating and educating its employees, affiliates,and subcontractors on this Code, verifying regularly that it
is complied with, and acting in response to any areas ofnon‑compliance.

jurisdiction they operate in;

A Not to commit any act or omission that would result
in FHL being in breach of any Anti-bribery andcorruption legislation;

A Comply with the minimum requirements set out inthis Code;A Implement and maintain appropriate procedures andcontrols to ensure their operations and supply chain
operate in line with FHL’s requirements and expected
standards;

A Promptly advise FHL of any areas of non-compliance withthis code;

A Respond to information requests from FHL in a timely
manner and provide a true and accurate account of theiroperations and supply chain when responding to requests.

Environmental Obligations

that upholds the United Nations’ Universal Declarationof Human Rights, UN Guiding Principles on Business andHuman Rights and the International Labour Organisation’sCore Conventions;

A Comply with the Modern Slavery Act 2015 and never use
modern slavery practices in their operations or supply
chain;A Fully comply with all applicable laws and regulations
relating to human capital management, including whensetting employee conditions on working hours, benefits
and wages and workplace Health and Safety. In the UK,
Living Wage Foundation minimum requirements must also
be met;A Ensure work environments are inclusive and recruitment
and employment practices are free from discrimination
based on age, religion, culture, ethnicity, gender, sexual
orientation, marital status, family responsibilities, disability,or health status of employees, in accordance with law;

At FHL, we believe that the investment management industry
should be a potent force in making a climate-resilient world areality. We believe we have a responsibility as an industry, andas a business, to make the right choices and play our part indelivering the goals of the Paris Agreement. As such, we will
only conduct business with Suppliers who share ourcommitment to establish environmentally responsible businesspractices and proactively improve their own environmental
performance. We expect our suppliers to:

A Address any adverse impacts on human rights and/or

A Comply with relevant environmental protection laws,

A Promote and increase diversity within their organisation

regulations and recognised standards including thoserelated to waste disposal, air emissions, plastics andpollution;

A Take steps to measure, report and minimise theenvironmental impact of their operations including
greenhouse gas emissions, energy consumption, water use
and waste generation and require their subcontractors andsuppliers to do the same.

working conditions, arising from decisions made by the
Supplier, as a matter of priority and urgency.

Diversity and Inclusion
At FHL, our mission is to foster and promote a culture ofinclusion which celebrates all forms of diversity, enables ourpeople to maximise their potential, and encourages innovationand creativity. We expect our Suppliers to:and supply chain by seeking equitable, mutually beneficial
opportunities with a broad range of businesses, forexample: small and medium-sized enterprises (SMEs),social enterprises, women-owned businesses, businesses
that support and employ people with disabilities and
LGBTIQA+ owned businesses.

89Modern Slavery
June 2024

Fraud, Bribery and Corruption
At FHL, we fulfil our purpose in accordance with the highest
standards of ethics and conduct. We do not tolerate behaviour
that is dishonest, illegal, fraudulent, corrupt or unethical. We
expect our Suppliers to:

A Employ reasonable measures and controls to ensure that
the Supplier’s employees and supply chain do not commit
fraud, bribery or corruption, or become involved in any
such activities;

A Avoid offering or receiving gifts, entertainment or travel that
could affect, or be seen to affect, their dealings with FHL;

A Ensure that they do not source goods and services onbehalf of FHL from, or transact in their supply chain withany country, entity or person(s) subject to internationallyrecognised sanctions.

Reputation and brand
At FHL, we are committed to communicating clearly andhonestly both internally and externally. FHL seeks to educate
and raise awareness of important ESG issues to effect genuine
and positive change for our stakeholders, communities andthe world. We use external social media platforms responsibly,
whilst being clear, honest and respectful of others. We expect
Suppliers to:Federated Hermes
Federated Hermes is a global leader in active, responsible investing.
Guided by our conviction that responsible investing is the best way to create long-term wealth, we provide
specialised capabilities across equity, fixed income and private markets, multi-asset and liquidity management
strategies, and world-leading stewardship.
Our goals are to help people invest and retire better, to help clients achieve better risk-adjusted returns and, where
possible, to contribute to positive outcomes that benefit the wider world.

Our investment and stewardshipcapabilities:
Active equities: global and regional
Fixed income: across regions, sectors and the yield curve

A Refrain from unprofessional, disrespectful, harassing,

Liquidity: solutions driven by five decades of experience

defamatory, discriminatory and prohibited activity on social
media platforms that may adversely impact upon FHL;	
Private markets: private equity, private credit, real estate,
infrastructure and natural capital

A Not act or speak on behalf of FHL, represent themselves
as FHL, or express any views attributable to FHL unlessexpressly authorised to do so by FHL.
The signing of this Code is a commitment from the Supplier to
FHL that they will supply goods and/or services in accordancewith this Code.

Stewardship: corporate engagement, proxy voting,policy advocacy

For more information, visit www.hermes-investment.com or connect with us on social media:

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