Modern Slavery (Anti-Slavery and Human Trafficking) Policy

Each member of the Vertical Research Partners group acknowledges that “modern slavery”, such as slavery, servitude, forced and compulsory labor and human trafficking, involve violations of human rights. The Vertical Research Partners group is committed to acting ethically and with integrity in all of our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our business or in any of our supply chains. Consistent with our disclosure obligations undertaken under various contracts, the Vertical Research Partners group takes, and will continue to take, reasonable steps to identify the risk of, and prevent the occurrence of, modern slavery offences among our contractors, suppliers and other business partners, as these modern slavery offences may be defined under various laws applicable to our customers and our contract partners.

We inform and train our employees and include in our Vertical Research Partners group compliance manual that the prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. We inform and train our employees to avoid any activity that might lead to or suggest a breach of our Modern Slavery (Anti-Slavery and Human Trafficking) Policy. Our employees are instructed to notify our compliance officer as soon as possible if they believe or suspect in good faith that a conflict with this Policy has occurred or may be about to occur. We encourage our employees to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains.