MODERN SLAVERY ACT STATEMENT – 2018
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (UK) for the financial
year ended 31 December 2018 in respect of the following State Street entities:••••

State Street Bank & Trust Company;
State Street Global Advisors Limited;
State Street International Bank GmbH; andState Street Europe Limited (together “State Street” or “We”).

State Street provides custody, depositary, investment, research and fund accounting, fundadministration, asset management, investment banking, and alternative investment services.
State Street is committed to fair, ethical and responsible business practices. We recognize that the riskof slavery or human trafficking exists in any supply chain and are taking steps to reduce that risk.
State Street supports fundamental principles of human rights, such as those adopted in the United
Nations’ Universal Declaration of Human Rights. We believe that upholding these principles is an
important component of our culture and values. As a signatory to the United Nations Global Compact(UNGC), we have confirmed our support of the UNGC’s ten principles and our intent to advance thoseprinciples within our organization, which include those principles relating to human rights abuses andforced labor.
Our commitment to fair, ethical and responsible business practices is central to our way ahead.

Supply chain standards
We expect our suppliers and their supply chain to comply fully with all applicable laws and regulations in
the conduct of their business; therefore although respecting human rights and environmental issues inthe supply chain is ultimately our suppliers’ responsibility, we have taken the following steps tocommunicate clearly our expectations to our suppliers.
As part of the supplier request for proposal (RfP) process managed by our global procurement services
team, potential suppliers are asked to confirm whether they have a policy in place prohibiting childand/or forced labor, whether the policy extends to their own suppliers and subcontractors, and toprovide a copy of the policy. Those potential suppliers are also asked for information about social
compliance audits of their own suppliers and subcontractors, with particular reference to significant
risks for incidents of child labor. That due diligence process also seeks information about a potential
supplier’s equal opportunity, human rights, anti-corruption, and health and safety policies.
As part of the RfP process, our global procurement services team also specifically asks potential
suppliers to confirm their compliance with human rights laws, rules and regulations including theModern Slavery Act 2015. Those potential suppliers are also asked to provide information about how
they monitor and comply with those legal standards.
Suppliers who are subject to our standard supplier agreement are asked to represent and warrant thatthey comply with all applicable laws, regulations, and other legal obligations to their personnel
specifically including, but not limited to, employment laws, and prohibitions against insider trading,bribery, and corruption.
Additionally, suppliers who are engaged using our standard supplier agreement are asked to confirm
that they:-

have not committed or been notified that they have been placed under investigation for any
offences relating to human trafficking and/or slavery;
are not aware of any circumstances within their supply chain that could give rise to an
investigation or a prosecution; andwill comply with the Modern Slavery Act 2015 and other legal standards relating to humantrafficking and/or slavery.

Those suppliers are asked to notify us immediately if those circumstances change. Additionally, thestandard supplier agreement asks them to provide us with their own UK Modern Slavery Act statement,
which sets out the steps they have taken to ensure that slavery and/or human trafficking is not taking
place in any of their supply chains or in any part of their business.
From time to time, potential suppliers are not able to provide the information requested in full or seek
to negotiate amendments to the standard supplier agreement. Such requests are dealt with on a case bycase basis, taking into consideration the risks associated with the supplier’s industry and its geographiclocation.

Third Party Risk Management
As part of its commitment to fair, ethical and responsible business practices, State Street continues towork on modern slavery initiatives through its Third Party Risk Management (TPRM) program. TPRM is aprocess and framework designed to enable State Street to consistently assess and manage the risks
associated with our supply chain prior to, and throughout the lifecycle of, third party vendor
engagement. We are taking a number of steps to address the risks associated with modern slavery inthis program, including developing scoping logic to determine which suppliers require review, defining
due diligence program questions and scoring, and defining issue management requirements and anoperational plan. Our work on this project continues, and in 2019 we will be leveraging industry bestpractice guidance for assessing risk related to modern slavery and human trafficking, with a view toincorporating that guidance into our TPRM program.
To facilitate discussions between managers and their teams, we have a “Team Talk” pack explaining how
the Modern Slavery Act applies to the corporate sector. We also have in place a Human Trafficking &Modern Slavery Policy which sets out State Street’s policy and expectations for all its staff and business
units globally. The policy prohibits human trafficking and related activities within State Street’s business,
Information Classification: Limited AccessVersion 18 June 2019
including inappropriate recruitment practices, and mandates the use of applicable RfP and Master
Supplier Agreement templates and compliance with applicable TPRM processes. Finally, as part of ouronline training catalogue we have a course on the UK Modern Slavery Act, which is available to all staff.

Approved for and on behalf of:Signed off by:

State Street Bank and Trust Company, London
BranchName: Elizabeth Nolan
Title: Chief Executive Officer

By its London Branch Supervisory Committee
Date of sign off: 17 June 201917 June 2019
State Street Europe Limited

Name: Brian Allis

By its Board of Directors

Title: CEO State Street Europe Limited

17 June 2019

Date of sign off:17 June 2019

State Street Bank International GmbH

Name: Stefan Gmur

By its Executive Management Board

Title: Executive Vice President

17 June 2019

Date of sign off: 18 June 2019

State Street Global Advisors Limited

Name: Cuan Coulter

By its Board of Directors

Title: Chief Executive Officer

18 June 2019

Date of sign off: 18 June 2019

Information Classification: Limited Access