D. E. Shaw & Co. (London), LLP
D. E. Shaw & Co. (U.K.), Ltd.
Statement on Modern Slaveryand Human Trafficking
Introduction
This statement is published by D. E. Shaw & Co. (U.K.), Ltd. and D. E. Shaw & Co. (London), LLP(together, “we”, “our”, or “us”) pursuant to section 54 of the UK Modern Slavery Act 2015 (the“Act”) in respect of the financial year ended 31 March 2023.

Business and Organizational Structure
We are members of the D. E. Shaw group, a global investment and technology development firm
founded in 1988. Our parent company is D. E. Shaw & Co., L.P., a U.S.-based investment adviser
registered with and regulated by the United States Securities and Exchange Commission.
D. E. Shaw & Co. (London), LLP is authorised and regulated by the Financial Conduct Authority in
the United Kingdom and provides investment management services to various members of theD. E. Shaw group on a sub-advisory basis.
D. E. Shaw & Co. (U.K.), Ltd. is a member of D. E. Shaw & Co. (London), LLP and a wholly-owned
subsidiary of D. E. Shaw & Co., L.P. Its business activities are limited to actions taken in relation toits membership in D. E. Shaw & Co. (London), LLP.
References in this statement to “the D. E. Shaw group” refer to D. E. Shaw & Co., L.P. andits affiliates.

Policy regarding Modern Slavery and Human Trafficking
The D. E. Shaw group is committed to maintaining the highest possible ethical and legal
standards. As part of that commitment, it is our policy not to tolerate modern slavery, servitude,
forced labour, or human trafficking in our business activities or employment arrangements. Weexpect each of our suppliers to comply with applicable laws in conducting its business and tooperate a fair and ethical workplace for its staff.

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Members and Employees
The substantial majority of our members and employees carry out highly-skilled activities, and all
staff receive remuneration and benefits that exceed those required by applicable laws andregulations. The risk of our staff being subject to modern slavery is low.
We seek to provide a safe, healthy, and desirable workplace. Our staff benefit from the protections
afforded by employment law in the United Kingdom, relevant aspects of which are reflected in ourpolicies and procedures. We are satisfied that there is no evidence of any act of modern slavery or
human trafficking involving our members or employees.

Supply Chain
Our business activities are limited to the provision of investment management services on a subadvisory basis and related technology development. As such, we have a limited supply chain that
includes providers of financial data, software, and investment research, as well as suppliers ofoffice supplies and equipment and services relating to non-core activities such as cleaning,catering, and transportation. The risk of modern slavery in our supply chain is low whencompared to typical businesses that manufacture or sell physical goods, or businesses that operate
in regions at higher risk of modern slavery.
We will not knowingly deal with, support, or purchase goods or services from suppliers engaged inmodern slavery, human trafficking, or other practices criminalized by the Act. Any supplier orservice provider found to violate our ethical business expectations may be subject to terminationof the business relationship.

Existing Policies
We operate policies and procedures designed to ensure compliance with applicable law andregulation. We believe that certain of those policies and procedures are relevant to our efforts todetect and prevent modern slavery and human trafficking in our business and supply chain,including policies relating to money laundering, bribery, whistleblowing and escalation,harassment and discrimination, equal opportunity, and remuneration.

Training and AwarenessWe have taken steps to inform all members and employees of our policy regarding modern slavery
and human trafficking. All of our staff receive annual training, including in relation to the Act, andare encouraged to report in good faith any issues or concerns relating to, among other things,
potential ethics, human rights, legal, or regulatory violations.

Review and Approval
The effectiveness of our efforts to ensure that modern slavery and human trafficking are not taking
place in our business or supply chain will be kept under periodic review.

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This statement was approved by the sole director of D. E. Shaw & Co. (U.K.), Ltd. and themanagement committee of D. E. Shaw & Co. (London), LLP on 3 October 2023.

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