Effective Operational Stewards

We have a centralized sourcing function for Wellington’s vendor contract processes. The contract managers collaborate with our Third-Party Risk Management (TPRM) Team, which initiates due diligence for new suppliers and conducts periodic reviews for certain existing suppliers. To identify and mitigate modern slavery and human trafficking risk, we have taken a risk-based approach to our evaluation. Where applicable, we may incorporate modern slavery-related provisions into our contractual agreements. We may also ask a supplier to provide information about its necessary actions to prevent or remediate modern slavery in its business or its supply chain. We identify and review third-party service providers for potential modern slavery risks during onboarding, based on risk factors such as the party’s industry and country of operation. Should we find any supplier using modern slavery in any part of its supply chain and/or its business, we will initiate remediation discussions and potentially terminate the contract. The nature of our business, along with the high standards we have for ourselves and our suppliers, has helped ensure that the risk of slavery and human trafficking in our supply chain is low. Regardless, Wellington takes a risk-based, case-by-case approach to supplier evaluations. Each evaluation takes into account the supplier’s geographic location(s) and the sector(s) in which it operates, with particularly careful consideration when a supplier operates in a region and/or industry that has been determined to be more susceptible to slavery and human trafficking.

At Wellington, we are unwavering in our belief in the power of differences and inclusivity. We are building a supply base that promotes fair access, competition, and resilience among providers of goods and services to our firm. We manage and assess a variety of vendor and supplier relationships solely based on merit, performance, risk management, and value, consistent with our fiduciary duty to clients. In support of best execution and operational resilience, we partner with a broad range of brokerage firms and local small businesses and seek to reduce unnecessary barriers to supplier participation across our procurement and trading activities. We continue to raise internal awareness of opportunities to expand our supplier ecosystem while maintaining objective, non‑discriminatory vendor selection and oversight processes. We will continue to manage and assess our vendor and supplier relationships in the best interests of our clients.