This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (UK) for the financial
year ended 31 December 2023 in respect of the following State Street entities:•

State Street Global Advisors Limited;•

State Street Bank and Trust Company; and•Charles River Development Limited (together, “State Street” or “we”).

State Street provides custody, depositary, investment, research, fund accounting, fund administration,asset management, and alternative investment services.
We are committed to fair, ethical and responsible business practices. We recognise that the risk ofslavery or human trafficking exists in any supply chain and are taking steps to reduce that risk.
We support 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 importantcomponent 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 organisation, which include those relating to human rights abuses and forced
labour.
Our commitment to fair, ethical and responsible business practices is central to our way ahead, as
outlined in our annual Sustainability report.1

Supply Chain Standards
Our Global Procurement Services team is responsible for executing appropriate due diligence andcontract management procedures, such as an established request for proposal (“RFP”) selection
criterion, standard supplier Master Services Agreement (“MSA”) templates and Engagement

1

State Street 2023 Sustainability Report

Page 1Compliance control mechanisms. We expect our suppliers and their supply chain to comply fully withall applicable laws and regulations in the conduct of their business; therefore, although respecting
human rights and environmental issues in the supply chain is ultimately our suppliers’ responsibility, wetake steps to communicate clearly our expectations to our suppliers.
In 2021, we rolled out a new online Modern Slavery Training course to educate our Global Procurement
Services team on State Street’s Modern Slavery policy and the specific responsibilities of the Global
Procurement Services organisation to mitigate Modern Slavery risks. The training has been amandatory annual requirement for Global Procurement Services staff since July 2021. In 2022 and2023, we updated the training and expanded the coverage of this training to encompass the Accounts
Payable team and the Payment Hub respectively.

Requests for Proposal
State Street uses a variety of approaches to assess and evaluate existing and new suppliers and theselection process may include an RFP where we determine competitive bidding is warranted. Since atleast 2016, as part of the supplier RFP process managed by our Global Procurement Services team,
potential suppliers have been asked to confirm whether they have a policy in place prohibiting childand/or forced labour, 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 labour. 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 theModern Slavery Act 2015. Those potential suppliers are also asked to provide information about how
they monitor and comply with those legal standards.

Supplier contracts
We include clauses specific to Prohibition on Human Trafficking and Modern Slavery in suppliercontracts. Since 2016, suppliers who are subject to our standard form of supplier MSA have beenasked to represent and warrant that they comply with all applicable laws, regulations, and other legal
obligations to their personnel specifically including, but not limited to, employment laws, andprohibitions against insider trading, bribery, and corruption.

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Additionally, since 2016, suppliers who have been engaged using our standard MSA have been 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; and•will comply with the Modern Slavery Act 2015 and other legal standards relating to humantrafficking and/or slavery.

Those suppliers have also been asked to notify us immediately if those circumstances change.
Additionally, the standard MSA asks them to provide us with their own UK Modern Slavery Act
statement, where applicable, 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 MSA. Such requests are dealt with on a case-by-case basis,taking into consideration the risks associated with the supplier’s industry and its geographic location.

Strategic suppliers
In 2020, we augmented our governance processes over strategic suppliers (as determined by
Procurement, considering factors such as risk and spend) to not only provide a copy of their own
Modern Slavery Act statement, but to additionally provide an explanation in the event that such astatement was not made available.
In 2023, we developed criteria to evaluate the sustainability performance of our strategic suppliers,
which takes place during our Quarterly Business Review meetings. We hope to roll out this enhanced
engagement in 2024 so as to enable a more standardized process for suppliers to self-assess andreport on their sustainability standards including those related to modern slavery.

Global Realty Services
In the UK, State Street’s Global Realty Services manages all services related to the operation andoccupation of its offices in London and Edinburgh. Essential services (cleaning, maintenance,
reception and mailroom services) relating to State Street’s permanent global offices are outsourced toa single Facilities Management provider. Under the terms of the agreement with that provider, there isa specific clause requiring the provider (and any vendor that it uses), to adhere to the Modern Slavery

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Act and any other applicable laws, rules or regulations prohibiting human trafficking and/or slavery.
Our Facilities Management provider also maintains its own Modern Slavery Act statement covering its
UK business activities.

Third-Party Risk Management
Third-Party Risk Management (“TPRM”) is a process and framework designed to enable State Street toconsistently assess and manage the risks associated with our third-party service providers prior to,and throughout, the lifecycle of a third-party service provider engagement. Prior to engaging with any
service provider, the contracting business unit completes an Inherent Risk Questionnaire (“IRQ”).
Based upon the results of the IRQ, TPRM performs risk assessment via due diligence questionnaires(“DDQ”) on our third parties. The Compliance DDQ process, which is completed for a subset of thirdparty engagements, includes the review of information about service providers’ ethics policies and ifthey account for human rights, modern slavery, and human trafficking. Where we identify any control
deficiencies, we require our service providers to implement a remediation plan along with a strategy
and timeframe for attaining compliance with the plan.
Additionally, the IRQ lists the countries that the service provider is headquartered in and where they
will provide their product or service from. The selected countries are risk rated based on scoresprovided by the Enterprise Risk Management Sovereign Risk team. These risk ratings factor in ESG risk
(which, among other things, considers civil liberties), vulnerability to human trafficking risk, andgovernment mitigation measures. Engagements in high-risk countries must be reviewed and approvedby the Sovereign Risk team as part of the due diligence process.
In 2023, we evaluated our service provider population for providers located in high-risk countries
operating in high-risk industries in relation to human rights protections and risk of modern slavery. For
this population, we launched a targeted assessment to understand their controls and determine
potential for risks of modern slavery.

Human Resources
Since March 2016 we have had in place a Human Trafficking & Modern Slavery Policy which sets out
State Street’s policy and expectations for all our staff and business units globally. The policy, which
was last reviewed in Q1 of 2022, prohibits human trafficking and related activities within our business,
including inappropriate recruitment practices, and mandates the use of applicable RFP and supplier
MSA templates and compliance with applicable TPRM processes.

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State Street maintains a whistle-blower hotline, known as the Speak Up Line. The Speak Up line is aconfidential third-party resource where State Street employees, contingent workers, clients andvendors can raise concerns about potential or actual misconduct or policy violations. Individuals may
raise concerns anonymously and without fear of retaliation, using either the internet or the telephone.
Approved for and on behalf of:Signed off by:

State Street Bank and Trust Company, acting
through its UK branch

Name: Cuan Coulter

By its UK Country Committee

Title: Head of UK Branch
Date of sign off: 28-06-2024

Date of approval: 25-06-2024

State Street Global Advisors Limited

Name: Alex Castle

By its Board of Directors

Title: Chief Executive Officer

Date of approval: 26-06-2024

Date of sign off: 26-06-2024

Charles River Development Limited

Name: Spiros Giannaros

By its Board of Directors

Title: Chief Executive Officer

Date of approval: 05-06-2024

Date of sign off: 11-06-2024

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