Modern slavery act | Insight Investment

BNY is a global financial services company that provides institutional trust and custody, investment management, banking and securities-related services to a range of clients across government entities, pension funds, banks, corporations and financial institutions.³ BNY has approximately 174 subsidiaries, the majority of which are located in North America, Europe and Asia.

For the avoidance of doubt, investee companies selected in connection with investment-related services offered by BNY's investment-related businesses are not considered suppliers. Please see "Our Supply Chain-Risk Identification" and "Our Supply Chain-Risk Mitigation" sections for how BNY is assessing and managing our Modern Slavery Risks.

BNY's risk management principles provide an enterprise-wide approach to effectively and
appropriately manage risk, including: 1) a strong risk management culture across the company, 2) clear risk ownership by the businesses and corporate functions, and 3) comprehensive oversight by Risk and Compliance, and Audit. This approach enables us to identify, assess and mitigate risks across the enterprise. We believe that any form of modern slavery is a severe and unacceptable violation of human rights, and we manage and mitigate potential modern slavery risks in our operations and supply chain. 

As part of our business-as-usual processes, we conduct regular reviews of our business operations, supply chain, clients and business transactions for potential risks, including modern slavery and human trafficking risks where applicable.

Risk Identification
Our global workforce consists mostly of skilled professionals in specialist roles, we therefore assess the risk of modern slavery in our direct operations as low. We provide a healthy and safe work environment, listen to our people and offer flexible policies and resources to help employees manage their personal growth, life balance and mental wellbeing.

Risk Mitigation
To mitigate any potential risks:

• BNY complies with local employment laws in all office locations, conducts background checks (including verifying an individual's identity, age and right to work) in accordance with
  applicable regulations, and issues offer letters prior to beginning work that clearly affirm each employee's right to resign at any time (applicable with reasonable notice).
• BNY recognizes that educating our staff is fundamental to identifying and mitigating potential human rights and modern slavery risks. We deliver training on Ethics and BNY's Code of Conduct and Anti-Modern Slavery:
  • Our onboarding and refresher training for staff covers BNY's Code of Conduct, with specific focus on conducting business in full compliance with all applicable laws and
    regulations and in accordance with the highest ethical standards; and the duty to report and prevent any improper activity. All BNY employees are expected to complete the mandatory Ethics and BNY's Code of Conduct training course.
  • The Anti-Modern Slavery training explains the specific risks for financial institutions and educates employees on warning signs for those potential risks. The training is mandatory for a core group of employees within the global Enterprise Sourcing Office, select members of our Legal and Risk and Compliance teams, our Sustainability Hub, and other relevant teams.
• BNY is committed to providing equal pay for equal work. To achieve our goal, we periodically review our pay practices and processes. In the United States, BNY paid a minimum hourly salary rate of $25 to employees - more than three times the current federal minimum wage. In the UK, BNY holds an accreditation with the UK Living Wage Foundation (the "Foundation") for paying at least the UK Living Wage, as defined by the Foundation, to all our U.K. employees. In Australia, BNY adheres to the working standards and conditions set by the Banking, Finance and Insurance Award (the "Award") governed by the Fair Work Commission for employees covered by the Award.

Our Supply Chain

• Facilities - including leases, maintenance, construction and renovations
• Financial services solutions - including market data and finance technology
• Professional services - including consulting, contingent labor and legal outside counsel
  
• Technology infrastructure - including hardware, software and telecom

Continuing into 2025, BNY considered a number of higher-risk categories and related products and services that may be present in the operations and supply chains of the reporting entities and theirowned or controlled entities, including the following:

• Accommodation - Corporate travel hotels
• Business Process Outsourcing (Offshore) - IT systems support
• Business Process Outsourcing (Onshore) - Mail sorting, document scanning and call centers
• Cleaning and Maintenance - Services in our corporate buildings
  
• Construction - Construction projects in our corporate buildings
• Food, Beverage and Hospitality - Catering and hospitality services in our corporate buildings
• IT Hardware - IT and telco hardware and consumables
  
• Labor Hire - Contingent labor/contractors
• Manufactured Products - Merchandise, stationery, security equipment and commercial print
  
• Security Services - Security, guarding services and mobile patrols for our corporate buildings

For suppliers critical to the operations of our company, we conduct ongoing news screening, covering various risk domains and areas of focus, including several keywords related to human rights and modern slavery. BNY continues to conduct daily sanctions screening for suppliers and considers our screening to be supportive to our efforts to mitigate modern slavery risk and human rights risks in our supply chain. In mid-2025, we began to implement EcoVadis, a third-party sustainability platform that will ultimately review all vendors from a low to critical risk designation as they are onboarded to the system.

Risk Mitigation
BNY seeks contractual representations on anti-slavery from its suppliers, including requirements to maintain appropriate policies, comply with applicable anti-slavery laws and communicate these requirements throughout their organization and to their subcontractors. Beginning with BNY's Request for Proposal ("RFP") process, we require potential suppliers to provide information relating to their anti-modern slavery and human trafficking policies, including responses to human rights-related questions. Suppliers that are selected go through our Risk-Based Due Diligence Process before being fully onboarded as a supplier to BNY. This approach fosters trust and strengthens our ability to manage risk effectively.

Our Clients

Risk Identification
BNY takes identifying modern slavery risks seriously. The firm's client assessments include modern slavery considerations through its Anti-Money Laundering ("AML"), Know Your Customer ("KYC") and Counter-Terrorist Financing ("CTF") programs, as well as additional client adverse media screenings to identify any risks.

Risk Mitigation
BNY continuously monitors risk through our AML, KYC and CTF programs, as well as through a client screening process; this includes client due diligence, ongoing screening and transaction monitoring, where applicable. BNY has a published set of Red Flags for potentially suspicious activity related to customer or counterparty behavior that may be indicative of activity associated with criminal behavior, such as trafficking or smuggling of persons. Through our AML, KYC and CTF programs, any indication of modern slavery or human trafficking is reviewed further to determine the materiality and escalated as appropriate through an Incident Report ("IR"). Where confirmed offenses have occurred, BNY will report a suspicious activity report to applicable regulators, adjust the client's risk rating or offboard the relationship, as applicable.

We have internal and external reporting channels that allow employees and others to report concerns including modern slavery and human trafficking. The formal channels are as follows:

• An electronic internal incident reporting system for employees and contractors
• Internal and external ethics help/hotlines
• Internal electronic People Team reporting system
• Non-Management Director's Mailbox for employees and external parties.

In addition, internal and external parties can also raise concerns through less formal communication channels.

In addition to the Code of Conduct, additional reporting policies include:

– Escalation, Speaking Up and Non-Retaliation Policy
– Suspicious Activity Reporting Policy for Non-U.S. Based Employees and Contractors
– Policy on Identifying, Investigating and Reporting Suspicious Activity for U.S.-Based Employees and Contractors

Conduct incidents are generally received through various Reporting Channels that route concerns to appropriate groups for investigation and further escalation when necessary.

In 2025, there were no confirmed cases of modern slavery or human trafficking reported through our internal or external reporting lines.

Our HRMS Council, oversees Anti-Modern Slavery mitigation and progress, and its members are involved assessing practices across our organization and supply chain. The underlying processes taken to identify and mitigate modern slavery risks with our employees, supply chain and clients are owned by their individual functions and reported to the HRMS Council. The HRMS Council meets twice a year to assess effectiveness and identify opportunities to improve Modern Slavery identification and mitigation, leveraging our United Nations Global Compact ("UNGC") membership and its Principles.

Performance Indicators & Assessment
We aim to assess the effectiveness of our Modern Slavery programming with the tracking and consideration of the following performance indicators:

• Number of confirmed cases of Modern Slavery reported through our internal and external reporting lines:
  • Number of confirmed cases with Our Employees
  • Number of confirmed cases with Our Supply Chain
  • Number of confirmed cases with Our Clients
• Number of employees who completed the Modern Slavery Training
  

All BNY suppliers are expected to act in accordance with the Supplier Code of Conduct, by aligning their own guidelines, policies and practices with the Supplier Code of Conduct, and by communicating and enforcing its provisions throughout their organizations and supply chains. A supplier's violation of the Supplier Code of Conduct may lead to review or further action, including and up to termination of the relationship with that supplier.

We reinforce these with annual employee training covering topics such as ethics, anti-bribery and corruption, protecting client assets, business continuity, anti-money laundering and other financial crimes compliance and information risk. Training on additional issues including safety and security in the workplace, workplace bullying and harassment is provided to all employees, reflecting the importance of maintaining a safe and welcoming culture.

On April 14, 2026, the Statement was approved by the board of The Bank of New York Mellon Corporation for the purposes of the Modern Slavery Act 2015, as well as by the board of The Bank of New York Mellon for the purposes of the Modern Slavery Act 2018 (Cth) in their capacity as principal governing body of The Bank of New York Mellon and as the parent entity of BNY Holdings (Australia) Pty Ltd.

The Statement is signed by Joseph J. Echevarria in his role as director of The Bank of New York Mellon and The Bank of New York Mellon Corporation on April 14, 2026.

Joseph J. Echevarria
Director

References in the statement to "BNY," "we" and "our" are references to The Bank of New York Mellon Corporation and its owned and controlled entities, including The Bank of New York Mellon. Owned and controlled reporting entities in the UK and Australia include but are not limited to:

1. UK
The Bank of New York Mellon, London Branch, U.K. CRNs FC005522 and BR025038
BNY Mellon Fund Managers Ltd, CRN 01998251
BNY Mellon Investment Management EMEA Limited, CRN 01118580
The Bank of New York Mellon (International) Limited, CRN 03236121
Insight Investment Management (Global) Limited, CRN 00827982
Newton Investment Management Limited, CRN 01371973
Pershing Limited, CRN 02072264
Pershing Securities Limited, CRN 02474912
Walter Scott & Partners Limited, CRN SC093685

2. AUSTRALIA
The Bank of New York Mellon, Australia Branch, ARBN 084 066 419
BNY Holdings (Australia) Pty Ltd,⁵ ACN 114 463 937