Modern Slavery and Human Trafficking Statement

This Modern Slavery and Human Trafficking Statement (the “Statement”) is made pursuant to section 54 of the UK Modern Slavery Act 2015 (the “Act”) for the year to 31 August 2025. This Statement sets out the steps that Waystone, as defined in the Appendix to this statement, has taken and continues to take to ensure that modern slavery and human trafficking are not taking place in its business or supply chains.

Waystone opposes slavery and human trafficking in all its forms and has a zero-tolerance approach to modern slavery. It makes this Statement to convey its values and commitment to ethical behaviour and its stance against slavery and human trafficking.

Modern slavery encompasses situations of exploitation where individuals cannot refuse or leave due to threats, violence, coercion, deception, or abuse of power. This includes, but is not limited to, forced labour, human trafficking, debt bondage, and the exploitation of children.

About Waystone

Waystone is one of the world’s leading providers of governance, risk, and compliance services to the asset management industry offering fiduciary, administration, and advisory services to funds and fund managers. Given its business operates predominantly in highly regulated environments, Waystone’s workforce consists mainly of highly educated professionals, which presents a lower risk of exposure to modern slavery.

While compliance with the Act is a legal requirement, this Statement extends beyond these obligations, encompassing Waystone’s global commitment to eradicating unethical labour practices across all jurisdictions in which it operates.

Waystone’s supply chains are made up of the following:

investment services related to funds under management;
outsourced services such as IT, legal, audit, payroll, and other professional support;
cleaning, office equipment, and supplies, and other operational support for company offices;
private healthcare, employee benefits, and associated services to support staff welfare; and
professional advisory and consulting services to assist with regulatory compliance and strategic initiatives.

Waystone recognises that its global footprint includes subsidiaries in jurisdictions that are higher risk for modern slavery (India, the Philippines, the United Arab Emirates, and Singapore). However, the risk to Waystone is limited due to these being wholly owned subsidiaries, performing financial services activities, with professional highly educated personnel.

Policies relating to slavery and human trafficking

Waystone has implemented comprehensive corporate policies that guide ethical behaviour, promote accountability, and facilitate the identification and reporting of concerns. These policies address key themes such as ethical labour practices, sustainability, integrity in procurement, anti-corruption measures, and mechanisms for raising concerns safely and confidentially. Relevant policies and procedures include:

Ethical Labour (Modern Slavery) Policy Statement
Sustainability Policy Statement
Code of Ethics
Regional AML Handbooks
Anti-Bribery and Corruption Policy
Whistleblowing Policy
Regional Employee Handbooks
Third Party Management Policy
Client Risk Assessment Procedure and the associated Jurisdiction Risk Assessment
Procurement Policy

Waystone’s Code of Ethics reflects its commitment to acting ethically and with integrity in all its business relationships and to implementing and enforcing effective systems and controls to prevent unethical business practices and criminal activity.

Waystone has corporate policies in place under which employees are encouraged to report concerns of non-compliance with regulatory rules or statutory obligations.

Waystone is committed to ethical trading principles and to acquiring goods and services without harm to others.

Due diligence processes and risk assessment

Waystone recognises that the risk of exposure to modern slavery exists primarily within its supply chain. Given the nature of its business and the regulated environment in which it operates, Waystone considers exposure to this risk to be limited. Nonetheless, it remains vigilant and is committed to taking all reasonable steps to minimise and mitigate this risk. These steps include:

considering modern slavery risks during procurement for material contracts, and avoiding engagement with suppliers where identified risks are judged to fall outside of Waystone’s risk appetite;
applying post-engagement due diligence through Waystone’s Third Party Management framework, which includes controls to assess and manage modern slavery risk;
adopting a zero-tolerance approach: Waystone will not engage or maintain relationships with any business knowingly involved in modern slavery; and
confirming through the legal review process that contracts contain appropriate clauses to ensure compliance with all applicable laws, including the Act.

Waystone applies these measures proportionately, based on the level of risk associated with each third-party relationship. Consideration is given to both the type of service or product provided and the location of delivery.

Waystone maintains a vendor database in the Supplier Vision platform, through which third party due diligence is consistently managed.

Effectiveness in combating slavery and human trafficking

Waystone maintains appropriate records to evidence compliance with its policies, including:

client and vendor negative news screening results;
vendor due diligence assessments, both initial and ongoing;
reports of any breaches of Waystone policies; and
details of any identified instances or allegations of modern slavery and the actions taken in response.

Waystone monitors the effectiveness of its approach through an established governance framework and regular policy reviews.

Training

All Waystone staff must complete Global Mandatory Training which includes the Code of Ethics, Whistleblowing Policy, and Anti-Bribery and Corruption Policy. This training reinforces the importance of ethical conduct and underpins the requirement that modern slavery has no place within Waystone’s operations and supply chains.

Waystone is committed to exploring opportunities to raise awareness among colleagues on how to identify and avoid modern slavery risks. Waystone’s Legal, Compliance, and Sustainability teams offer ongoing guidance and support to staff, ensuring they are equipped to address ethical challenges and uphold the company’s integrity.

Responsibility and governance

It is the responsibility of all staff to escalate any potential infringement of Waystone policies to their line manager, Head of Function, or via a whistleblowing channel. Specific responsibilities include:

People & Development: responsible for employment screening and ensuring ethical labour practices in the Waystone workforce;
Client Onboarding and Compliance Teams: conduct client screening for negative news and adverse media under Anti-Money Laundering responsibilities, which may include indicators of unethical labour practices;
Third Party Management team: conduct due diligence ensuring suppliers adhere to relevant standards;
Risk and Compliance functions: support oversight and monitoring of policy compliance and provide advice and escalation routes where potential breaches are identified;
Legal team: provide legal support in relation to contractual obligations and legislative compliance, including obligations under the Act;
Sustainability team: maintain and update policies and provide guidance and support across Waystone to ensure understanding and implementation.

All employees have a shared responsibility to remain vigilant and to speak up and report any suspected instances of modern slavery.

Waystone’s commitment going forward

Waystone recognises that even though it operates within an industry with a lower prevalence of modern slavery risks, continued attentiveness and diligence is required due to the complex and clandestine nature of modern slavery. Waystone is committed to transparency in its efforts to prevent modern slavery and will meet all applicable disclosure obligations. It will continue to assess and improve its processes to ensure it maintain the highest standards of ethical conduct across its global operations and supply chains.

Approval

This Statement was approved by Karl Midl, UK Country Head, Waystone Group, on 27 August 2025 and subsequently noted by the Boards of the entities listed in Appendix 1.

Appendix 1

Waystone shall be understood to mean the following entities:

Waystone Administration Solutions (UK) Limited
Waystone Compliance Solutions (UK) Limited
Waystone Financial Investments Limited
Waystone Governance UK Limited
Waystone Management (UK) Limited
Waystone Nominees (UK) Limited
Waystone Transfer Agency Solutions (UK) Limited
Waystone UK Holdings Limited