Modern Slavery and Human Trafficking Statement

This statement is made on behalf of Principal Global Investors, LLC pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ended 31 December 2024.

Structural Organization and Supply Chain

Principal Global Investors, LLC (PGI) is the global investment management business of Principal Financial Group (Principal), a leading global financial institution which can trace its roots back to 1879. Marketed under the brand name Principal Asset Management, PGI offers a range of diverse investment capabilities through a network of specialized investment teams and affiliates.

Headquartered in Iowa, USA, PGI's near 2,000 employees span North America, EMEA, Asia and Latin America, managing over US$500 billion of assets on behalf of our global clients.

Appendix A – List of Parent and Subsidiary Entities provides a list of PGI's various entities in scope during the one-year period ended December 31, 2024.

Our supply chain predominantly includes the sourcing of services principally from business and professional organizations. We therefore believe that there is limited risk of slavery and human trafficking taking place in our supply chains. Notwithstanding this, we are committed to ensuring that modern slavery or human trafficking is not taking place in our supply chain or in any part of our business.

Principal has a zero-tolerance approach to slavery and human trafficking. We are committed to implementing and enforcing systems and controls to ensure human trafficking is not taking place in our business or our supply chains. We expect our suppliers to share our commitment. Our Supplier Code of Conduct requires that suppliers should not engage in slavery or trafficking of persons. Our Supplier Code of Conduct is communicated to third party vendors, suppliers, etc. that we do business with at the time of contract negotiation. We expect our suppliers to meet the requirements of the Supplier Code of Conduct. Moreover, contracts are reviewed as part of every engagement and provisions may be revised and/or tailored to address parties who are in a high-risk country and/or a high-risk sector.

We hold our tier 1 suppliers contractually accountable for their own supply chains. In most instances, we do not have clear visibility beyond our tier 1 suppliers. As a financial services company, we don't assemble products. We don't have an extensive supply chain to map. Our main categories for procurement are software, data, and professional services.

We've revised and updated our Supplier Code of Conduct to more clearly reflect our commitment to legal and ethical standards. The Code includes key obligations for suppliers including legal and regulatory compliance, data security and privacy, reciprocity, and human rights and fair labor.

Our Policies on Slavery and Human Trafficking

Our Global Code of Conduct, Anti-Slavery and Human Trafficking Policy, Human Rights Statement, and Supplier Code of Conduct reflect our commitment to acting ethically and with integrity in our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our business or our supply chains.

In March 2022, Principal Financial Group released a new human rights statement. Our human rights statement reaffirms our commitment to operating in the most ethical way possible, including a dedication to fairness, integrity, and trust. Our commitments are aligned with the principles of the Universal Declaration of Human Rights (UDHR), the International Labor Organization’s Declaration on Fundamental Principal and Rights at Work (“ILO Declaration”), the United Nations Global Compact, and the United Nations Guiding Principles on Business and Human Rights.

The following policies are publicly available on www.principal.com:

Due Diligence Processes

PGI and Principal Financial Group use NAVEX to search for global incidents including litigation, regulatory actions and fines, and legal authority actions. If items of concern are identified, the Supplier Manager will engage Principal Asset Management compliance staff and a corporate criminal attorney to advise on actions needed which may result in termination of the supplier relationship.

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

  • Identify and assess potential risk areas in our supply chains based on high and medium risk countries and regions. A process exists to assess the risks of suppliers located in countries with comprehensive, targeted or limited sanctions. A list of high and medium risk countries is maintained by appropriate professional staff and reviewed semi-annually, or as new sanctions are applied. Risk assessments for pending engagements with suppliers located in identified countries are done and provide a recommendation as to whether the supplier engagement can proceed or not.
  • Monitor potential risk areas in our supply chains. We have deployed standard due diligence tools and processes to vet existing and new suppliers for negative news, litigation, regulatory enforcement actions, and other adverse conduct. That process addresses the vetting of suppliers for any reported incidents of engaging in slavery and human trafficking. The tool used for vetting the suppliers daily provides reports that, based on the severity of the issue identified, are shared with the Supplier Manager for discussion with the supplier, or with Sr. Legal Counsel to determine if legal action is necessary.

In addition, Principal has systems in place to encourage our employees to report any concerns as well as policies in relation to whistle blowing. All employees are expected to promptly report suspected unethical, illegal, or fraudulent activity by anyone working for or on behalf of Principal through the Ethics Hotline or other internal reporting channels. Employees may report suspected unethical or fraudulent activity by calling the Ethics Hotline or submitting an online report, both of which allow anonymous reporting. These reports are made through a third party not affiliated with Principal which collects information, creates a report and sends it promptly to Principal for investigation. All reported issues are appropriately investigated and kept confidential, and access to related information is restricted and secured. We have an internal Whistleblower Policy that prohibits retaliation for reports made in good faith.

Risk Assessment and Management

We conduct risk assessments for third-party relationships to identify potential key risks. Risk assessment outcomes inform ongoing monitoring and due diligence activities. These assessments evolve over time with industry trends or emerging risks.

Depending on the risks present with the product/service purchased from the third party, risk domain SMEs (subject matter experts) are appropriately engaged. This could include the following departments or functional areas:

  • Information Security
  • Privacy
  • Compliance
  • Ethical and Responsible Artificial Intelligence
  • Business Continuity
  • Disaster Recovery
  • Geopolitical
  • Financial Reporting
  • Financial Health
  • Brand and Reputation
  • Sustainability/ESG

Risk Assessment and Management

Key Performance Indicators

We do the following on an ongoing basis to ensure that slavery and human trafficking are not taking place in any part of our business or supply chains:

  • Communicate with companies in our supply chain to ensure understanding of, and compliance with our expectations.
  • Monitor our supply chains for incidents or allegations that conflict with our Supplier Code of Conduct.
Training

We provide training to employees to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business. A human rights topic is in our Global Code of Conduct that includes references to slavery and human trafficking. This topic is also in our all-employee Global Code of Conduct training rotation and is highlighted every three years. It will be included in our 2025 course. The annual Global Code of Conduct training includes an acknowledgement all employees are required to complete.

This statement has been approved by the Board of Directors of Principal Global Investors, LLC and will be reviewed annually and updated as required.

Kamal Bhatia, Director

 

Appendix A – UK List of Parent and Subsidiary Entities within scope of the disclosure requirement during the one-year period ended December 31, 2024

  1. Principal Global Investors (Europe) Limited
  2. Principal Real Estate Europe Limited
  3. Principal Real Estate Limited
  4. Origin Asset Management LLP
  5. PGI Finisterre Holding Company Limited*(***)
  6. PGI Origin Holding Company Limited*
  7. Principal Financial Services Asia (UK) Limited*
  8. Principal Financial Services I (UK) LLP*
  9. Principal Financial Services II (UK) Limited*
  10. Principal Financial Services III (UK) Limited*
  11. Principal Financial Services Latin America Limited*
  12. Principal Financial Services V (UK) Limited*
  13. Principal Financial Services VI (UK) Limited*
  14. Principal Global Financial Services (Europe) Limited*
  15. Principal Global Financial Services (Europe) II Limited*
  16. Principal Global Investors Asia (UK) Limited*
  17. Principal International Latin America Ltd*
  18. Principal International South America I Limited *
  19. Principal International South America II Limited*
  20. Principal Corporate Secretarial Services Limited**

*Holding Company
**Dormant Company
*** In liquidation

Footnotes

As of 31 March 2025.