Slavery and Human Trafficking Statement

As of end of 2025

Important Information : Following the acquisition of AXA Investment Managers on 1 July 2025 by
BNP Paribas , we are working to align our approach to the Modern Slavery Act with that of BNP
Paribas . This statement therefore applies to the AXA IM entities in the UK which remained broadly
aligned with AXA Group policies on ethics, human rights, and anti – slavery during the reporting
period. The next annual update of the document will incorporate the joint approaches and policies
developed.

Statement Section
This statement is made by AXA Investment Managers UK Limited, AXA Investment Managers GS
Limited and BNP PARIBAS ASSET MANAGEMENT Services Limited (previously AXA Investment
Managers Limited) (each the “Company”) pursuant to Section 54 of the UK Modern Slavery Act
2015 (the “MSA”). It sets out the steps that the Company has in place or taken during the financial
year ending 31 Decemb er 2025 to combat and prevent all forms of modern slavery and human
trafficking in its business and supply chains. This statem ent covers the Company’s direct
operations and supply chains.

The Company has a long history of adhering to and promoting strong professional ethics and is
committed to conducting its business according to the highest standards of honesty and fairness.
This commitment to observing such ethical standards is designed not only to ensure compliance
with applicable laws and regulations where the Company operates, but also to earn and keep the
continued trust of its clients, shareholders, personnel, and business partners. The Company
believes that its success and reputation is not only depen dant on the quality of its products and
the services provided to its clients, but also on the way it does business. This includes a strong
commitment to human rights, and it welcomes the transparency promoted by the MSA.

1. Company’s structure and business

Each Company is incorporated in the UK and has been owned since 1 July 2025 by the BNP Paribas
Group, a leader in banking and financial services in Europe, with the parent company having its
head office in Paris, France.

Now working as part of the BNP Paribas Group, our team of over 2,800 people around the world
combines a range of specialist skills and experience to best serve the needs of our clients.

Our investment philosophy and the way we run our business combine responsibility with an
active, long – term view that underpins our client relationships and our people’s drive.
During 2025 , the business was composed of four key strategic business units:

• AXA IM Alts, bringing together our Real Assets and Structured Finance platforms.
• AXA IM Core, offering a wide range of investment strategies from Fixed Income and Equity to Multi- Asset.
• AXA IM Prime, sourcing and managing diversified portfolios across private market assets, and hedge funds via primary and secondary funds, co – investments and direct strategies.
• AXA IM Prime, sourcing and managing diversified portfolios across private market assets, and hedge funds via primary and secondary funds, co-investments and direct strategies.
• AXA IM Select, a specialist investment manager combining products from global fund managers to create diversified investment solutions

All business units benefit from dedicated sales teams and are supported by Global Transversal Functions.

Further information about the Company is available on our corporate website

2. Company’s supply chains 

The Company continues to be an important purchaser of products and services for the purpose
of its internal operations and client servicing. Suppliers include IT, Market Data, Operations,
Premises, Office Supplies & Document Services, Marketing, Communications, Travel, HR and
Consulting Services. As a financial services company, most of the Company’s impacts on society
are linked to our choice of suppliers, with a limited impact from our internal processes. The
Company integrates both social and environment al dimensions into its Procurement selection
process. The Company’ s Sustainable Procurement strategy for suppliers is based on well – defined
pillars: to behave responsibly and improve relationships when dealing with suppliers and
understand the Sustainability related risks of our suppliers and influence them to
improve/miti gate the risk. Suppliers are sourced according to their commitment to sustainability,
and this is embedded in our decision – making process. The process is composed of segmentation
of risks and assessment of those risks. The Company performs risk segmentation to classify
suppliers into three categories (high, medium, or low stake) using a Sustainability Stakes Matrix .
A rating of the supplier by an external third party is mandatory for all medium and high – stake
suppliers

3. Engagements and policies in relation to modern slavery and human trafficking 

The Company is committed to respecting internationally recognised human rights principles as
defined by the core standards of the International Labour Organisation and the Guiding Principles
for the implementation of the United Nations “Protect, Respect and Remedy” Framework (Ruggie
Principles). The Company also adheres to the UN Global Compact (“UN GC”) and its ten guiding
principles, including those on human rights (such as avoiding complicity in human rights abuses
and supporting and respecting the protection of int ernationally proclaimed human rights) and
labour standards (such as supporting the elimination of all forms of forced and compulsory
labour and the effective abolition of child labour).

IIn addition, there are policies in place to support the Company’s commitment to ethical business
practices across the organisation. These include:

• The AXA Group Human Rights Policy, which aims to ensure that (i) the Company does not cause or contribute to adverse human rights impacts and (ii) such impacts are addressed when they occur. The policy also sets out the Company’s commitment to identify, prevent and/or mitigate adverse indirect human rights impacts that are linked to its operations or services, through its business relationships or projects it has invested in or insured.
• The AXA Group Compliance and Ethics Guide (the ‘Guide’), which establishes guiding principles and Group-wide policies designed to ensure the Company and their personnel have a common vision of the Group’s ethical standards (including the UN GC principles on human rights, labour standards, environment and anti-corruption) and operate in accordance with those standards. All employees are encouraged to report promptly any practices, actions or conduct that they believe are inappropriate or inconsistent with any of the policies set out in the Guide through their local whistleblowing procedures. Senior officers are asked to submit an annual certification to confirm that they comply with all the provisions set out in the Guide.

In addition, the Company has the following policies in place relating to MSA principles:

• AXA IM Code of Conduct and Ethics
• AXA IM UK Whistleblowing Policy
• AXA IM Procurement Policy
• AXA IM Equal Opportunities Policy
• AXA IM Global Standard on Harassment

4. Management of the modern slavery and human trafficking risk in the Company’s operations

The Company acknowledges its responsibility to respect human rights in its operations and conducts its business in compliance with applicable employment regulations in the jurisdictions in which it operates. The Company’s Compliance and Ethics Guide sets out protections for employees and their rights, in particular, it emphasises that:

• The Company is committed to upholding the right of freedom of association and collective bargaining, as well as maintaining constructive labour management relations in every country in which it does business, and to doing so with due respect for different national approaches to social dialogue.
• The Company respects the rights of its employees to enjoy just and favourable conditions of work, including health and safety protections, and is committed to providing adequate information and training on health and safety and wellbeing issues.

In addition, the Company promotes diversity and inclusion by prohibiting any form of discrimination between current, past or prospective staff on diversity dimensions including age, disability, gender identity, ethnicity or race, sexual orientation, marital status or religion through its Diversity and Equal Opportunities Policy.

The AXA IM Equal Opportunities policy applies to employees and workers to ensure compliance
with the law and to prohibit discrimination based on age, race, nationality, ethnic origin, gender,
gender expression, identity, sexual orientation, religion, marit al status or disability. Within the
Company, the diversity and inclusion efforts are driven by our executive leadership teams. Our
HR department, including the Inclusion, Diversity & Engagement teams, provide thought
leadership and act as a centre of exper tise, liaising across all the businesses.

5. Assessment of the Company’s largest suppliers and due diligence process in relation to the Company’s supply chains 

The Company ensures that it works with suppliers that meet its standards with respect to ethics and sustainability through a clearly documented process for supplier selection and contracting.
In accordance with such process, the Company’s standard contractual terms with suppliers include specific reference to the Company’s sustainability requirements, and suppliers are required to provide a formal commitment to uphold the core standards of the UN GC by signing the Company’s “Sustainability clause”.

In addition to the applicable local social regulations (including the UK Modern Slavery Act 2015),
supplier s undertake to observe the principles of the conventions of the International Labour
Organization, in particular with regard to the minimum age and child labour, freedom of
association, the right of organisation and of collective bargaining, forced or compulsory labour,
equal pay for men and women, job discrimination, working hours and the minimum wage.
Suppliers undertake to apply their social policy in all countries in which they operate and to make every effort to ensure its application by their own suppliers, subcontractors and distributors.

The Company aims to uphold ethical standards throughout its supply chain. As part of this goal, the Company has established a modern slavery and human rights due diligence process for its suppliers which is based on the assessment of the business sector and country of provision of services/goods, or of incorporation of the third party, and the completion of a questionnaire (if required by the results of the due diligence).

The Company aims to uphold ethical standards throughout its supply chain. As part of this goal, the Company has established a modern slavery and human rights due diligence process for its suppliers which is based on the assessment of the business sector and country of provision of services/goods, or of incorporation of the third party, and the completion of a questionnaire (if required by the results of the due diligence).

6. Training and information available to staff 

A Modern Slavery training is accessible to all employees on the Company’s internal learning platform. The objectives of this training are to give a high-level overview of modern slavery, to discuss how to spot the signs of slavery, and to present a process to help ensure the business’ supply chain is free of slave labour. Additionally, the Company provided additional compulsory modern slavery training for employees in targeted teams and functions in 2025.

Further steps 

The Company will continue to review its current practices to detect and prevent modern slavery and human trafficking within its operations and supply chains and will endeavour to enhance any procedures, policies, or practices, that it deems appropriate.

Following the acquisition by BNP Paribas, the Company is committed to aligning and harmonising its approach in 2026 and ensuring consistency with BNP Paribas’ policies, procedures and standards relating to modern slavery and human rights.

The Board of Directors of each Company approved this statement, which constitutes each Company’s slavery and human trafficking statement made pursuant to section 54(1) of the Modern Slavery Act 2015 for the financial year ending 31 December 2025, on 18 June 2026 and 22 June 2026.

Modern Slavery Statement 2025

Modern Slavery Statement 2023

Modern Slavery Statement 2021

Modern Slavery Statement 2024

Modern Slavery Statement 2022

Read our Modern Slavery and Human Trafficking Statement:

Modern Slavery Statement