Modern Slavery Statement

Alter Domus Modern Slavery Statement

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (UK), which requires large companies operating in the UK to publish a modern slavery and human trafficking statement. This in respect of Alter Domus and its subsidiaries (“Alter Domus or AD”). Alter Domus is committed to combating the risk of modern slavery or human trafficking within its business and supply chains.

We do not tolerate forced labor either within our business itself or within our supply chain. We expect vendors and providers across our supply chain (whether direct suppliers or those that directly or indirectly supply our direct suppliers) to share the same values.

About Alter Domus

Alter Domus is a leading global provider of end-to-end tech-enabled fund services across three sectors: private equity, real assets and private debt. Established in 2003 and headquartered in Luxembourg, Alter Domus is one of the largest fund administrators globally, with $3.9tn assets under administration (AuA), 38,000 client structures managed and 6,500 staff in 23 jurisdictions.

Driven by a deep understanding of what it takes to succeed in private markets, Alter Domus has developed an unmatched offering to meet and anticipate the ever-changing needs of investment managers and asset owners worldwide.

Our Policies & Standards

our operations and supply chain by applying risk-based due diligence, clear supplier standards, staff training, and proportionate remediation where concerns are found.

To date, no instances of modern slavery have been identified in our operations or supply chain.

We operate the following policies and standards:

Code of Conduct
The Alter Domus Code of Conduct sets clear behavioral and ethical standards for all staff, including respect for human rights, fair treatment, speaking-up (without retaliation) and compliance with law and policy. The Code of Conduct provides the ethical framework on which we base our decisions, as individuals and members of our global organization.

Human Rights Policy
Alter Domus is committed to sustaining a culture which protects the rights and interests of its employees and which supports local regulations which similarly support and protect human rights.

This policy aims to outline Alter Domus’s commitment and the practices it utilizes across the organization to ensure employees are treated with dignity and respect. It also acts as a basis for publicly affirming the company’s values and embedding its responsibilities into its operations and how it conducts its day-to-day business.

Environmental, Social & Governance (ESG) Policy
Environmental, Social and Governance (ESG) practices are part of our culture and commercial philosophy. We believe that responsibility, transparency, partnership, and accountability are fundamental to delivering sustainable success.

Procurement Policy
This policy document sets out the policies and procedures under which Alter Domus carries out their Procurement operations. The Procurement Policy outlines the approval and threshold requirements and identifies where procurement support and contracts are required.

Third Party Risk Management Policy
The purpose of the Policy is to establish requirements for managing risks associated with third parties, their sub-contractors and the supply chain to safeguard our organization and the people and workers involved in our supply chain.

Furthermore, this policy documents the structure for identifying, assessing, controlling, monitoring and reporting on risks related to AD’s use of third parties per applicable laws, safe and sound business practices and related supervisory guidance.

Responsible Procurement

As a financial services company Alter Domus has a limited supply chain and operates in an industry with a lower risk of modern slavery. Nevertheless, Alter Domus recognizes that the risk of slavery or human trafficking may exist in any supply chain. Therefore, Alter Domus has committed to take adequate actions and put in place mitigants to reduce such risk.

As part of new supplier due diligence, Alter Domus obtains confirmation through the due diligence process that the supplier has adequate anti-slavery and human trafficking statement and/or policy in place, which is expected to extend to the supplier’s sub-contractors.

Risk assessment

We acknowledge that there are elevated risks in parts of our supply chain including, for example, the labour-hire cycle, country-specific risks and higher risk industries. To identify and manage risk, we:

• map suppliers to whom we pay £100,000 and above by services provided, location, size and industry to identify potential risk areas
• adopt our Code of Conduct to ensure clear standards and expectations of supplier

Due Diligence

Our supplier due diligence is proportionate to our risk and includes:

• Pre-engagement of new suppliers
• Screening of all suppliers
• Conducting ongoing monitoring through our due diligence cycle

Employment Practices
Alter Domus insures fair and inclusive employment practices, including, robust and ethical recruitment processes, including right-to-work checks performed in line with UK law, contracts of employment and checks to ensure everyone employed is aged 16 and above, market-driven pay and rewards, reviewed at least annually, a wellbeing strategy and initiatives to support colleagues’ physical and mental health and lifestyle choices.

Training
Alter Domus is committed to ensuring awareness of modern slavery and human trafficking considerations across the organization and provides appropriate training to all staff.

Reporting concerns
Alter Domus is committed to fostering an inclusive, equitable and fair culture and provides its clients, colleagues, contractors, suppliers, and the public with channels through which any concerns can be raised. All concerns reported are subject to careful and impartial review and, where appropriate, investigated with the highest discretion.

Integrity concerns (including Whistleblowing) may be communicated anonymously 24 hours a day, seven days a week globally via an independent third-party web portal specializing in the discreet reporting of concerns and secure processing of personal data.

All concerns reported are taken seriously and treated confidentially. Alter Domus strictly prohibits any retaliation for reporting a possible violation of law, ethics or firm policy, no matter whom the report concerns.

June 6th, 2026