MODERN SLAVERY ACT STATEMENT – 2019
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (UK) for the financial year
ended 31 December 2019 in respect of the following State Street entities:••••

State Street Bank and 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, fund administration,asset management, investment banking, and alternative investment services.
State Street is committed to fair, ethical and responsible business practices. We recognize that the risk ofslavery 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 take the following steps to communicate
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 child and/orforced labor, whether the policy extends to their own suppliers and subcontractors, and to provide a copyof 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 childlabor. 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 andcomply 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, andcorruption.
Additionally, suppliers who are engaged using our standard supplier agreement are asked to confirm thatthey:-

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 tonegotiate 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 has evaluatedmodern slavery considerations 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. In 2019 we updated our due diligence questionnaires to align more closely to industry
standard and best practice. These updates include enhancements to our Compliance and Operational
Risk assessments to verify third parties have processes ensuring compliance with laws and regulations forboth their own organizations and any sub-contractors used to provide services to State Street. Any
control deficiencies identified will require a remediation plan along with a strategy and timeframe forattaining compliance with the plan.

Information Classification: Limited Access2Human Resources
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,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: Cuan Coulter
Title: Branch Manager

By its UK Country Committee
Date of sign off: 23 June 2020
Date 10 June 2020
State Street Europe Limited

Name: Brian Allis

By its Board of Directors

Title: Director

Date 10 June 2020

Date of sign off: 10 June 2020

State Street Bank International GmbH

Name: Stefan Gmur

By its Executive Management Board

Title: Executive Vice President

Date 15 June 2020

Date of sign off: 24 June 2020

State Street Global Advisors Limited

Name: Cuan Coulter

By its Board of Directors

Title: Director

Date 5 May 2020

Date of sign off: 23 June 2020

Information Classification: Limited Access3