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Slavery and Human Trafficking Statement

As of end of 2024

This statement is made by AXA Investment Managers UK Limited, AXA Investment Managers GS Limited and AXA Investment Managers Limited (each the “Company” and part of the AXA Group) 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 December 2024 to combat and prevent all forms of modern slavery and human trafficking in its business and supply chains. This statement covers the Company’s direct operations and supply chains.

The AXA Group 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 in the various jurisdictions where the AXA Group operates, but also to earn and keep the continued trust of its clients, shareholders, personnel, and business partners. The AXA Group believes that its success and reputation is not only dependant 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 fully owned and backed by the AXA Group, a world leader in financial protection and wealth management, with the parent company having its head office in Paris, France.

Our purpose, to act for human progress by investing for what matters, is central to every action we take as a business. As a responsible asset manager, we actively invest for the long-term to help our clients, our people, and the world to prosper. Our conviction-led approach enables us to uncover what we believe to be the best global investment opportunities across alternative and traditional asset classes.

Working as part of the AXA 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.

AXA Investment Managers (“AXA IM”) is 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 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 environmental dimensions into its Procurement selection process. AXA Group’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/mitigate 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. Based on the AXA Group’s Procurement Sustainability Stakes Matrix, the Company performs risk segmentation to classify suppliers into three categories (high, medium, or low stake). A rating of the supplier by an external third party is mandatory for all medium and high-stake suppliers. This evaluation includes a section on ‘Labour’.

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

The AXA Group is committed to respecting internationally recognized human rights principles as defined by the United Nations Universal Declaration of Human Rights, 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 AXA Group is also committed to applying international general and sector-specific standards such as the UN Principles for Responsible Investment, the UN Principles for Sustainable Insurance and the UN Global Compact (“UN GC”). Since 2003, AXA adheres to the UN GC and has formally committed to promoting its ten guiding principles, including those on human rights (such as avoiding complicity in human rights abuses and supporting and respecting the protection of internationally 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).

In addition, the AXA Group has put in place policies to support its commitment to ethical business practices across the organisation. These include:

  • The AXA Group Human Rights Policy, which aims to ensure that (i) the Group does not cause or contribute to adverse human rights impacts and (ii) such impacts are addressed when they occur. The policy also sets out AXA’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 that all AXA Group companies 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 AXA 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 of AXA entities are asked to submit an annual certification to confirm that they comply with all the provisions set out in the Guide.

The AXA Group Human Rights Policy, the Guide and the principles and standards mentioned above all apply to the to the Company.

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 

AXA 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 AXA Group Compliance and Ethics Guide sets out protections for AXA’s employees and their rights, in particular, it emphasises that:

  • AXA 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.
  • AXA 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, AXA 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, marital 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 expertise, liaising across all the businesses. They are informed and driven by the AXA Group strategy and their own local priorities to create more inclusive workplaces. More details on our commitment to diversity and inclusion can be found in AXA IM’s global diversity and inclusion policy.

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 AXA Group’s sustainability requirements, and suppliers are required to provide a formal commitment to uphold the core standards of the UN GC by signing the AXA Group’s “Sustainability clause”. Notably, the suppliers agree to refrain from using, or accepting that their own suppliers and sub-contractors make use of, child labour (under 15 years old) or forced labour.

In addition, the Company’s procurement team seeks to prevent or mitigate adverse human rights’ impacts of its direct suppliers by the frequent use of a third-party tool to monitor and assess several sustainability topics (including child and forced labour).

Furthermore, AXA IM 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).

This initiative is aimed at ensuring that the products and services provided to AXA IM do not promote any form of modern slavery and that human rights are respected throughout the supply chain. By implementing this process, AXA IM seeks to promote a responsible and sustainable approach to its business operations while also contributing to the protection of human rights globally.

6. Training and information available to staff 

The Company has rolled out an AXA Group awareness training programme for procurement professionals to give them a detailed knowledge of the AXA Group’s corporate responsibility principles, covering MSA obligations. This training programme highlights the instrumental role of procurement professionals to ensure that the Company engages with responsible suppliers.

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.

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.

The Company is currently looking at providing additional compulsory modern slavery training for employees in targeted teams in certain functions in 2025.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 2024, on 16 June 2025 and 19 June 2025.

    Risk Warning

    The value of investments, and the income from them, can fall as well as rise and investors may not get back the amount originally invested.