MODERN SLAVERY ACT STATEMENT – 2021
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (UK) for the financial year
ended 31 December 2021 in respect of the following State Street entities:•••

State Street Global Advisors Limited;
State Street Bank and Trust Company; andState Street Bank International GmbH (together, “State Street” or “we”)

State Street provides custody, depositary, investment, research, fund accounting, fund administration,asset management, 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, 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
the conduct of their business; therefore, although respecting human rights and environmental issues inthe supply chain is ultimately our suppliers’ responsibility, we take steps to communicate clearly ourexpectations to our suppliers.
In 2021, we developed and mandated 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 the1

State Street 2021 ESG Report, available athttps://www.statestreet.com/content/dam/statestreet/documents/values/state -street-esg-report-04-2021.pdf

Global Procurement Services organization to mitigate Modern Slavery risks. This training was required forall employees in Global Procurement Services as of July 2021 and is an annual requirement going forward.
Requests for Proposal
State Street uses a variety of approaches to assess and evaluate existing and new suppliers and theselection process may include a Request for Proposal (“RFP”) where we determine competitive bidding iswarranted. Since at least 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 placeprohibiting child and/or forced labor, whether the policy extends to their own suppliers andsubcontractors, and to provide a copy of the policy. Those potential suppliers are also asked for
information about social compliance audits of their own suppliers and subcontractors, with particularreference 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 andcomply with those legal standards.
Supplier contracts
We actively and intentionally include clauses specific to Prohibition on Human Trafficking and ModernSlavery in supplier contracts. Since 2016, suppliers who are subject to our standard form of supplieragreement (“MSA”) have been asked 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, 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 aninvestigation or a prosecution; andWill 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 humantrafficking is not taking place in any of their supply chains or in any part of their business.

2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 byProcurement, 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 wasnot made available. We continued this approach in 2021.

Third Party Risk Management
In 2017 and 2018, as part of our commitment to fair, ethical and responsible business practices, we started
to build modern slavery considerations into our Third Party Risk Management (“TPRM”) program. TPRM
is a process and framework designed to enable us to consistently assess and manage the risks associatedwith our supply chain prior to, and throughout the lifecycle of, a third party vendor engagement.
Our due diligence questionnaires are aligned to industry standard and best practice. Among other things,since 2020 we have been requesting information about suppliers’ ethics policies and whether they
consider human rights, modern slavery, and human trafficking. Through our Compliance and Operational
Risk Assessments we evaluate whether those suppliers have processes ensuring compliance with laws andregulations within their own organizations and by any sub-contractors that they intend to use to provide
services to State Street. Where we identify any control deficiencies, we require our suppliers to implement
a remediation plan along with a strategy and timeframe for attaining compliance with the plan.
Additionally, prior to any supplier being engaged, we complete an Inherent Risk Questionnaire (“IRQ”).
Since 2016, within the IRQ we have asked which countries the supplier will provide their product or service
from, and the countries selected are risk rated based on scores provided by the Enterprise Risk
Management (ERM) Sovereign Risk team. These risk ratings include ESG risk, which considers civil liberties,
including vulnerability to human trafficking risk and government mitigation measures, as a factor.
Engagements in high risk countries must be reviewed and approved by the Sovereign Risk team as part ofthe due diligence process.

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.

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.
Finally, since 2018 as part of our online training catalogue we have had 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, acting
through its UK branch

Name: Cuan Coulter
Title: Head of UK Branch

By its UK Country Committee

Date of sign off: 30 May 2022

Date of approval: 30 May 2022
Signature: ________________________
State Street Bank International GmbH

Name: Stefan Gmuer

By its Executive Management Board

Title: Chief Executive Officer

Date of approval: 29 June 2022

Date of sign off: 30 June 2022

Signature: ________________________
State Street Global Advisors Limited

Name: Alex Castle

By its Board of Directors

Title: Chief Executive Officer

Date of approval: 14 June 2022

Date of sign off: 16 June 2022

Signature: ________________________

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