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2023

Modern Slavery Statement
1 Introduction

2 Our structure and operations

This Modern Slavery Statement (Statement) is made by T. RowePrice International Ltd. (TRPIL) in accordance with the requirementsof section 54 of the United Kingdom Modern Slavery Act 2015 and T.
Rowe Price Australia Limited (TRPAU) pursuant to the AustralianModern Slavery Act 2018 (together, the Reporting Entities, we, us,our) for the financial year ended 31 December 2023 (Reporting
Period). This Statement describes the risks of modern slavery andhuman trafficking in our operations and supply chains, the actions wehave taken to assess and address those risks and how we plan toassess the effectiveness of our actions.

TRPAU (ABN 13 620 668 895) and TRPIL (Company Number
03957748) are wholly owned subsidiaries ultimately of T. Rowe Price
Group, Inc. (TRPG), a publicly traded U.S. holding company. TRPAU isa wholly owned subsidiary of TRPIL, which is a wholly owned subsidiaryof T. Rowe Price Associates, Inc., a U.S. company incorporated in
Maryland, which is in turn a wholly owned subsidiary of TRPG.
An extract of our corporate structure is shown below:

T. Rowe Price Group, Inc.

T. Rowe Price Associates, Inc.

T. Rowe Price International Ltd.

T. Rowe Price Australia Limited

TRPAU does not control any other entity in Australia or elsewhere.

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The Reporting Entities provide investment advisory and management
services, and distribution and client support services to intermediaryand institutional investors and separately managed accounts, as wellas in respect of proprietary funds. The Reporting Entities also provide
sub-delegated investment advisory, distribution and client support
and other shared services to affiliate entities, which are subsidiaries of
TRPG. TRPIL is primarily regulated by the United Kingdom Financial
Conduct Authority and TRPAU is primarily regulated by the Australian
Securities and Investments Commission.
TRPAU is a limited liability company with its registered office located at
Level 28, Governor Phillip Tower, 1 Farrer Place, Sydney NSW 2000.
TRPAU also has an office at Level 30, 35 Collins St, Melbourne VIC
3000. TRPIL is a limited company with its registered office located at
Warwick Court, 5 Paternoster Square, London, EC4M 7DX. In
addition to TRPAU, TRPIL has wholly owned subsidiaries located inEngland, Luxembourg, Switzerland, China, Hong Kong, Japan andSingapore.
As at 31 December 2023, TRPAU employed 62 people and TRPIL
employed 924 people. The types of roles performed by the Reporting
Entities’ employees include:■ Accountants and Finance professionals;■ Administration Assistants and Receptionists;■ Business Analysts;■ Business Managers;■ Client Operations professionals;■ Credit Analysts;■ Economists;■ Facilities/Health & Safety professionals;■ Governance/Risk professionals;■ Human Resources professionals;■ Investment Analysts;■ Legal Counsel & Compliance professionals;■ Marketing/Events/Communications/Public Relations
professionals;■ Portfolio Managers/Analysts/Specialists;■ Product Managers;■ Relationship Managers;■ Research professionals;■ Sales Managers;■ Technologists;■ Traders; and■ Procurement & Vendor Management professionals.

MODERN SLAVERY STATEMENT 2023

3 Our supply chain
During the Reporting Period, the Reporting Entities procured goods
and services from approximately 1500 direct suppliers. All
suppliers are expected to comply with our Supplier Code of
Conduct, which articulates our expectations and requirements
regarding the respect of human rights. Our direct supply chains
involve the provision of custody and administration of assets as wellas the procurement of goods and services in the areas of technology,
commercial real estate, facilities, business travel, printing, couriers
and mail, office equipment and supplies, subscriptions,memberships, telecommunications, hiring of temporary and contract
workers and various professional services with expertise in disciplines
such as legal, finance, investments, human resources and marketing.
In addition to the above, the Reporting Entity employees incurred
expenditure relating to meals, hotels and airfares, which are managed
via an expense management platform and such expenditure is subject
to a group wide policy on business expenses.
The majority of TRPAU’s direct suppliers are based in Australia, witha small number of suppliers based in other jurisdictions, including theUnited Kingdom, Hong Kong, India, Japan, the United States, and in
the European Union. Whereas the majority of TRPIL’s direct suppliers
are based in the United Kingdom, with a small number of suppliers
based in other jurisdictions, including Australia, Hong Kong, India,
Japan, Vietnam, Egypt, South Africa, the United States, and in theEuropean Union. Notwithstanding the lower risk country of domicile
for the majority of the Reporting Entities’ direct suppliers, it is likely that
suppliers will procure goods and services from other countries.
Some services are shared across various entities, including theReporting Entities. Shared services such as technology, legal,
compliance, marketing, business management and oversight and subdelegated investment management are procured at an enterprise level
and the costs are allocated across entities globally, including to theReporting Entities.

4 Modern slavery risks in ouroperations and supply chains
We consider the overall risk that our business has caused or contributed
to modern slavery and human trafficking in respect of our workforce tobe low having regard to our skilled office-based workforce operatingin countries with a lower prevalence of modern slavery and humantrafficking according to the Global Slavery Index and as a result of ourglobal human resources policies and procedures.
Our operations may be indirectly linked to risks of modern slavery as aresult of business activities, including via our investments.
Other risks of modern slavery such as forced labour and child labour
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T. ROWE PRICEof certain product categories, such as conflict minerals usedin technology hardware and electronics, the timber and steel used in
the production of office furniture and textiles used in uniforms. In
addition, there may be potential risks of modern slavery such as debt
bondage and deceptive recruiting for labour or services in thesubcontracted workforce supporting some vendor industries
such as cleaning, property maintenance, food services,transportation services, courier services and accommodation.

5 Actions to address and assess
modern slavery risks
References to T. Rowe Price, we, us and our in this section and insection 7 refer to TRPG and its subsidiaries.

Employees
We comply with all applicable employment standards and humanrights laws.
In relation to remuneration, we continued to use benchmarking toensure that our employees are paid in accordance with market rates.
Our employees are remunerated in excess of the minimum wage in allof our locations.
T. Rowe Price periodically updates the global policies and proceduresin place that aim to ensure ethical conduct and fair and equitable
treatment takes place within our business. The following policies
summarise some of the measures in place in respect of our workforce.

Code of Ethics and Conduct
Our Code of Ethics and Conduct (Code) remains in force andestablishes standards of conduct that we require each associate to fully
understand and adopt. All associates and certain contingent workers
are expected to comply with all laws and regulations applicable toour business with a written acknowledgement of their understandingof and compliance with the Code and its amendments on at least anannual basis.

MODERN SLAVERY STATEMENT 2023

individuals are treated with respect and dignity. Associates have theright to enjoy a workplace that is conducive to high performance,
promotes equal opportunity, and prohibits bullying and harassment.
T. Rowe Price will not tolerate bullying, harassment or other types of
inappropriate behaviour directed by or toward an associate, supervisor/
manager, contractor, vendor, customer, visitor, or other business
partner. All allegations of bullying and harassment will be investigatedand, if appropriate, disciplinary action will be taken. T. Rowe Price will
also not tolerate victimisation of a person for making allegations ofbullying or harassment in good faith or supporting someone to makesuch a complaint.

Whistleblowing hotline
Our whistleblower hotline published on our website provides thedetails for anonymous reporting for violations or suspected violationsof any law, rule or regulation. We monitor the reports received via
the hotline to identify and investigate concerns raised including
those raised in relation to modern slavery and human trafficking.

Suppliers
During the Reporting Period, we undertook the following actions:■ Incorporated questions relating to modern slavery and humanrights into the questionnaires completed by key suppliers (whichforms part of the procurement tender assessment for our
Reporting Entities);■ Incorporated terms into our Reporting Entities’ template supplier
agreements regarding the prevention of modern slavery and humantrafficking and compliance with our Supplier Code of
Conduct; and■ Communicated our Supplier Code of Conduct to ensure our
suppliers adhere to high standards and principles across allareas of their business in relation to modern slavery, human rights,
health & safety, integrity and ethics, diversity, equity & inclusion, andenvironmental sustainability.

Equal Opportunity Policy
We continue to remain committed to the principles of equal opportunity.
The aim of our policy is to ensure that all applicants and T. Rowe Priceassociates receive equal treatment regardless of sex, gender, age, race,
disability, marital status, religion, creed, colour, sexual orientation, gender
identity or expression, citizenship status, national origin, veteran status,
pregnancy, or any other classification protected by law. All employment
decisions continue to be made in a non-discriminatory manner.

Dignity at Work Policy
T. Rowe Price continues to remain committed to providing a safe
working environment free of harassment and bullying in which all
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We seek to ensure that suppliers consider their own human rights
impacts by including a clause in the Reporting Entities’ terms andconditions for the purchase of goods and services that requires
suppliers to warrant that they do not employ, engage or use forced
labour, trafficked labour, child labour nor engage in or condone
inhumane treatment of workers, and will mitigate and avoid adverse
human rights impacts.

MODERN SLAVERY STATEMENT 2023

we recognize that many of our clients’ goals are not purely financial. As
such, we offer select investment products that seek to invest in waysthat align with our clients’ values or have the potential to drive positiveenvironmental or social impact.

ESG integration is the incorporation of environmental, social, andgovernance factors into investment analysis for the purpose of
maximizing investment performance. Fiduciary duty remains the top
priority. We view ESG integration as foundational — it is a core investment
Asset Management
capability, which we have embedded in our equity and fixed
T. Rowe Price’s approach to responsible investment includes how we income investment research platform across asset classes. ESG
address human rights risks in our investments and is embedded in our integration is applied to all of our investment products, where
policies and processes. An overview is set out below.
applicable. Additionally, we have strategies that cater to clients whowant to reflect their values or a sustainable objective in theirinvestments.
ESG Policy
At T. Rowe Price, we incorporate environmental, social, and governance(ESG) considerations across our investment platform. We believe that Responsible Investing
ESG issues influence investment risk and return, and, therefore, we
As summarised in the latest Stewardship Report1, our proprietary
incorporate them into our fundamental investment analysis. Additionally,
Responsible Investing Indicator Model (RIIM) allows us to proactively and systematically screen for whether or not an investee
Illustration of a company RIIM profile
company has been involved in controversies tied to modern slavery or
human rights. RIIM is one of many components that contribute toour deep, fundamental investment research. It builds a distinct ESG
profile of each corporate entity by scoring companies onenvironmental, social and governance criteria, largely using nonfinancial data and incident history – data not traditionally used inmainstream investing. An illustrative example of the metrics is shown inthe chart opposite.
Our RIIM analysis covers approximately 15,000 corporate securities
and is available on our investment analysts’ desktops, so analysts,
and portfolio managers have ready access to this data ahead ofmaking any investment decisions. Additionally, the Responsible
Investment team conducts quarterly portfolio reviews using our RIIM
analysis and would highlight any issues around mismanagement and/or
controversies related to human rights and modern slavery during theseportfolio reviews.

Engagement Policy

1 https://www.troweprice.com/esg

At T. Rowe Price, we believe it is our responsibility as an asset
manager to safeguard our clients’ interests through active
ownership, monitoring, and mutual engagement with the issuers of
the securities we hold in our clients’ portfolios. Thanks to the trust ourclients have placed in us, T. Rowe Price is a significant investor for many of
the world’s leading companies. This affords us, in most cases, access tocompany management teams and board members. We believe our
responsibilities as diligent investors do not cease with the decision topurchase a security. Where we find areas of concern, we make thoseconcerns known to them. During the Reporting Period, we continued tohold these discussions as part of our active engagement with companies.

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Human Rights Violators Exclusion Policy
During the Reporting Period, T. Rowe Price continued to implement a
policy not to finance companies deemed by the firm to demonstrate
a disregard for supporting governments that have been involved in
genocide and/or crimes against humanity.

Training
All employees must complete our ethics training program on an annual
basis. All new associates in Australia participated in specific training
designed to educate individuals on issues relating to slavery andhuman trafficking in order to help them identify potential issues
relating to modern slavery. Other associates have access to thistraining.

Raising Concerns and Complaints
In the event that we cause or contribute to modern slavery, we would
take guidance from the United Nations Guiding Principles on Businessand Human Rights, which provides that businesses in this situationneed to remediate the impact by taking a person-centred approach inprotecting the safety, privacy and wellbeing of the affected person. We
would seek to undertake a full investigation of the situation to ensurethat an appropriate corrective action plan is implemented and assess
how similar impacts could be avoided in the future.

MODERN SLAVERY STATEMENT 2023

6 Assessing the effectiveness of
our actions
We will seek to assess the effectiveness of our actions over thecourse of the next reporting period by tracking the progress of thefollowing goals:■ Assessing current modern slavery and human rights training for our
associates to ensure it remains appropriate and relevant;■ Reviewing and improving our Supplier Code of Conduct;■ Continuing to embed and broaden human rights
considerations in our procurement policies and procedures,
including reviewing and augmenting an updated version of our
supplier questionnaire for tender responses to address modern
slavery and human trafficking issues in detail;■ Reviewing modern slavery statements of key suppliers (whereavailable) as part of our supplier evaluation process;■ Publishing our Investment Policy on Human Rights; and■ Continuing to monitor the reports made via our reporting hotline
for any grievances relating to modern slavery or human rights.

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7 Other relevant information
T. Rowe Price joined, or led, various industry-level initiatives aimed at
facilitating opportunities for collaborative engagement, advocacy, andimproving ESG disclosure and business practices. The following tabledetails relevant global memberships held by T. Rowe Price.
Organization

StatusJoinedCouncil of Institutional Investors (CII)

Associate Member

1989

Principles for Responsible Investment (PRI)

Signatory

2010

UK Stewardship CodeSignatory

2010

Japan Stewardship CodeSignatory

2014

Associacão Investidores no Mercado de Capitais (AMEC)

Member2015

Asia Corporate Governance Association (ACGA)

Member2016

UK Investor Forum

Founding Member

2016

Investor Stewardship Group (ISG)

Founding Member

2017

Japan Stewardship Initiative

Founding Member

2019

Investment Association Climate Change Working Group

Member2020

Institutional Investors Group on Climate Change (IIGCC)

Member

2020

Emerging Markets Investors Alliance

Member2020

PLSA Stewardship Advisory Group

Member

2020

Emerging Markets Investors Alliance

Member2020

Task Force on Climate-related Financial Disclosures (TCFD)

Supporter

2020

Responsible Investment Association Australasia (RIAA)

Member2020

Farm Animal Investment Risk Return

Member2020

Access to Medicine Index

Signatory

2021

Task Force on Climate-Related Financial Disclosures Consortium (Japan)

Member2021

Global Impact Investing Network (GIIN)

Member

2021

IFRS Sustainability Alliance (formerly the SASB Alliance)

Member2021

UN Global Compact

Signatory

2021

International Corporate Governance Network (ICGN)

Member

2021

IMEA (Investment Management Education Alliance) ESG Committee

Member2021

30% Club Investor Group – UK Chapter

Member2021

International Capital Market Association

Member2017- Member of the ICMA Principles - Green Bond Principles (GBP), Social Bond Principles (SBP),- Sustainability Bond Guidelines (SBG) and Sustainability-Linked Bond Principles (SLBP)Member2022

Net Zero Asset Managers Initiative

Signatory

2022

Access to Nutrition Initiative

Signatory

2022

Japan Impact-driven Financing Initiative

Signatory

2022

Taskforce on Nature-related Financial Disclosures (TNFD)

Forum Member

2022
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8 Process of consultation and approval
Various business lines and functions within the Reporting Entities wereconsulted in the drafting of this Statement, including: Legal, Compliance,
Communications, ESG, Finance, Human Resources, Procurement,
and Supplier Management. These groups have global mandates,
which includes the Reporting Entities to which this Statement applies.
Accordingly, these internal stakeholders provided input in relation to
the Reporting Entities.
This Statement is updated on an annual basis in collaboration withall relevant business units and functions from each of the Reporting
Entities. The Statement has been approved by the principal governing
body of the Reporting Entities, namely the Board of Directors of TRPIL
and the Board of Directors of TRPAU, and has been signed by a
responsible member of the Reporting Entities:

Signed by:

6/6/2024
Date:
Director of T. Rowe Price International Ltd.

6/14/2024
Date:
Director of T. Rowe Price Australia Limited

Name: Scott E Keller

Name: Darren Hall

CCON0150004

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