SS&C Modern Slavery Annual Statement

Modern Slavery Act 2015: Slavery and Human Trafficking Statement

OUR APPROACH

This statement provides details on the policies and processes the above companies have in place to mitigate the risk of modern slavery and human trafficking in any part of our business or our supply chains.

We consider this an extremely important issue and we aspire to go beyond the requirements of the Modern Slavery Act 2015, embedding the responsibility to respect human rights into our culture. There is no place for modern slavery or human trafficking within our organisation.

We operate a suite of policies and practices that reflect and embed our commitment to human rights and regularly review these to ensure that we adopt those most appropriate for our business.

ORGANISATION'S STRUCTURE

We are a provider of Software and Fund Middle/Back Office Services in the Financial Services sector. We operate across North America, Europe, Asia and Australia. Our ultimate parent company, SS&C Technologies Holdings, Inc., is based in Connecticut, US.

Further details about our group can be found at ‘About Us’ on our website at the following link: https://investor.ssctech.com/investor-relations/overview/default.aspx.

Our quarterly financial reporting can be found at ‘Press Releases’ on our website at the following link:

https://investor.ssctech.com/investor-relations/press-releases/default.aspx.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

As an organisation we could be impacted by Modern Slavery in two ways; either through our Suppliers or our Employees, although as a Financial Services provider, we believe the risk of Modern Slavery with both is relatively low. Regardless, our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere.

Our Suppliers

We build in house solutions where possible to ensure control of our work environment. Where we do need to make use of Suppliers, in the main they provide services such as technology solutions, maintenance and support, premises and office management, business solutions and professional services. We build long standing relationships with Suppliers where it is possible and make clear our expectations of business behavior through our Due Diligence processes. The following processes allow us to understand that our Suppliers work ethically and have mechanisms in place to demonstrate that Modern Slavery is not an issue within their own businesses:-

• Due Diligence is completed when onboarding a new Supplier
  • o Questions concerning our Supplier’s approach to Modern Slavery are asked within the Due Diligence Questionnaires and responses are reviewed to ensure we are satisfied that their approach meets our expectations
  • o Where an unsatisfactory response is received from a Supplier on their Modern Slavery approach, further review is required with escalation to the Supplier Risk Governance Committee if appropriate where the risk would be assessed and a decision would be made to either continue to work with or not work with the Supplier
• The Due Diligence exercise is then repeated annually where applicable

Our Employees

We have mechanisms in place demonstrating that we treat our people fairly, respectfully and equally. Here are the key policies, processes and practices in place which support this:

Expectations of our Employees

• Employee Terms & Conditions – signed on joining
• Employee Handbook – reviewed/signed annually by employees
• Culture & Conduct Risk Policy
• Culture Statements
• Guiding Behaviours – Assessment against these is a key part of the annual appraisal process
• SMCR (Senior Managers Certification Regime) (where applicable)
• Induction and ongoing Training

Supporting SS&C and/or Employees

• Whistleblowing
• Grievance Policy
• Annual performance and pay reviews
• Criminal checks (on joining)
• Disciplinary Process

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

As part of our initiative to identify and mitigate risk we have in place the following:

• Suppliers are expected to have suitable anti-slavery and human trafficking policies and processes in place and confirmation is requested as part of the Due Diligence processes
• Key risk areas in our supply chains are identified through this Due Diligence where any exceptions are escalated
• Systems to encourage the reporting of concerns and the protection of whistle blowers

TRAINING

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff.

OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

We believe that slavery and human trafficking is not taking place in any part of our business or supply chains.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. It has been approved by the individual boards of directors and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2022.

Signed by Nicholas Wright
On behalf of SS&C Solutions Limited, SS&C Financial Services Limited, DSTI Holdings Limited, SS&C Financial Services International Limited, SS&C Financial Services Europe Limited, SS&C Wealth and Insurance Ireland Limited, SS&C Life and Pensions Services Limited and SS&C International Managed Services Limited
Date: 18 October 2023

Signed by Karen Geiger
On behalf of Eze Castle Software LLC
Date: 19 October 2023