MODERN SLAVERY ACT STATEMENT – 2022
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (UK) for the financial year
ended 31 December 2022 in respect of the following State Street entities:••••

State Street Global Advisors Limited;
State Street Bank and Trust Company;
State Street Bank International GmbH; andCharles 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 of slavery 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 important component of ourculture and values. As a signatory to the United Nations Global Compact (“UNGC”), we have confirmed oursupport of the UNGC’s 10 principles and our intent to advance those principles 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 ESG report.1
Supply chain standards
Our Global Procurement Services team is responsible for executing appropriate due diligence and contract
management procedures, such as an established request for proposal (“RFP”) selection criterion, standard
supplier Master Services Agreement (“MSA”) templates and Engagement Compliance control mechanisms.
We expect our suppliers and their supply chain to comply fully with all applicable laws and regulations in theconduct of their business; therefore, although respecting human rights and environmental issues in thesupply chain is ultimately our suppliers’ responsibility, we take steps to communicate clearly ourexpectations 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 a mandatory
annual requirement for Global Procurement Services staff since July 2021. In 2022, we expanded thecoverage of this training to encompass the Accounts Payable team.

1

State Street 2022 ESG Report1Requests for Proposal
State Street uses a variety of approaches to assess and evaluate existing and new suppliers and the selection
process may include an RFP where we determine competitive bidding is warranted. Since at least 2016, aspart of the supplier RFP process managed by our Global Procurement Services team, potential suppliers havebeen asked to confirm whether they have a policy in place prohibiting child and/or forced labour, whether
the policy extends to their own suppliers and subcontractors, and to provide a copy of the policy. Thosepotential suppliers are also asked for information about social compliance audits of their own suppliers andsubcontractors, with particular reference to significant risks for incidents of child labour. That due diligenceprocess 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 toconfirm 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.
Supplier contracts
We include clauses specific to Prohibition on Human Trafficking and Modern Slavery in supplier contracts.
Since 2016, suppliers who are subject to our standard form of supplier MSA have been asked to represent
and warrant that they comply with all applicable laws, regulations, and other legal obligations to theirpersonnel specifically including, but not limited to, employment laws, and prohibitions against insider
trading, bribery, and corruption.
Additionally, since 2016 suppliers who have been engaged using our standard MSA have been asked toconfirm 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 human trafficking
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, whereapplicable, which sets out the steps they have taken to ensure that slavery and/or human trafficking is nottaking 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 tonegotiate 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,2

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 a statement was not madeavailable.
Global Realty Services
In the UK, State Street’s Global Realty Services manages all services related to the operation and occupationof its offices in London and Edinburgh. Essential services (cleaning, maintenance, reception and mailroomservices) related to State Street’s primary UK offices are outsourced to a single Facilities Management
provider under the terms of an MSA containing a specific clause requiring the provider, and any vendor thatit uses, to adhere to the Modern Slavery Act and “any other laws, rules or regulations prohibiting humantrafficking and/or slavery”. Our Facilities Management provider 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, andthroughout, 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 theresults of the IRQ, TPRM performs due diligence via due diligence questionnaires (“DDQ”) on our thirdparties. The Compliance DDQ process, which is completed for a subset of third-party engagements, includes
the review of information about service providers’ ethics policies and whether they account for humanrights, modern slavery, and human trafficking. Where we identify any control deficiencies, we require ourservice 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 will provide their product or service from,and the countries selected are risk rated based on scores provided 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, and government mitigation measures. Engagements in high-riskcountries must be reviewed and approved by the Sovereign Risk team as part of the due diligence process.
In 2023, State Street will undertake an effort to review and enhance, where required, the modern slavery
diligence performed, focusing on the population of third parties that introduce the highest levels of modernslavery risk.
Human ResourcesSince 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.
3

To facilitate discussions between managers and their teams, since 2017 we have had a “Team Talk” packexplaining how the Modern Slavery Act applies to the corporate sector.
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 and vendors
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
Title: Head of UK Branch

By its UK Country Committee

Date of sign off: 22 June 2023

Date of approval: 26 May 2023
State Street Bank International GmbH

Name: Dr. Andreas Przewloka

By its Executive Management Board

Title: Chief Executive Officer

Date of approval: 20 June 2023

Date of sign off: 21 June 2023

State Street Global Advisors Limited

Name: Alex Castle

By its Board of Directors

Title: Chief Executive Officer

Date of approval: 20 June 2023

Date of sign off: 21 June 2023

Charles River Development Limited

Name: Spiros Giannaros

By its Board of Directors

Title: Chief Executive Officer

Date of approval: 7 June 2023

Date of sign off: 21 June 2023

4