Modern Slavery Act Statement

SITUSAMC TRANSPARENCY STATEMENT ON THE UK MODERN SLAVERY ACT 2015 AND CANADA’S FIGHTING AGAINST FORCED LABOUR AND CHILD LABOUR IN SUPPLY CHAINS ACT 2023

This statement covers the financial year ending 31 December 2025 and is published for 2026. It is made pursuant to Section 54(1) of the United Kingdom’s Modern Slavery Act 2015 and Section 11 of Canada’s Fighting Against Forced Labour and Child Labour in Supply Chains Act (S.C. 2023, c. 9) (the “Canadian Act”), and sets out the steps that SitusAMC has taken and continues to take to ensure that Modern Slavery, forced labor, child labor or human trafficking are not taking place within its business or supply chains.

“Modern Slavery” includes slavery, servitude, forced or compulsory labor, and human trafficking. SitusAMC has a zero-tolerance approach to any form of Modern Slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of Modern Slavery taking place within the business or our supply chains.

This Statement will be reviewed annually and updated as necessary to reflect changes in circumstances and actual practice. The Statement will be made publicly available on the SitusAMC website (www.situsamc.com). 

OUR BUSINESS

SitusAMC is a leading independent provider of advisory, strategic outsourcing, talent, and technology solutions to the commercial and residential real estate finance industries. The company helps clients identify and capture opportunities in their real estate businesses through industry-leading services and innovative technologies that drive operational efficiency, increase business effectiveness, and improve market agility across the entire lifecycle of their global real estate activity.

SitusAMC employs approximately 4,500 team members worldwide, working through 45 subsidiaries across 26 office locations in the U.S., Europe (Germany, Ireland and United Kingdom) and India. Its ultimate parent, SitusAMC Holdings Corporation, has its corporate headquarters in the United States.

OUR SUPPLY CHAIN

SitusAMC engages a broad array of suppliers including lawyers, accountants, brokers and other advisors and consultants, as well as suppliers of IT and other professional services. The products and services purchased by SitusAMC are primarily procured from suppliers located in the jurisdictions in which we operate. We have minimal to no contact with suppliers operating in countries and sectors that are likely to present a risk for Modern Slavery. 

RISKS OF SLAVERY, CHILD LABOR, OR HUMAN TRAFFICKING 

SitusAMC considers the overall risk of Modern Slavery within its business and supply chains to be low, reflecting the professional and skilled nature of our workforce, the sectors from which we procure products and services, and the effective risk management policies in place to prevent this exposure. Nevertheless, we are committed to ensuring that there is no Modern Slavery or human trafficking in our supply chains or any part of our business. 

POLICY ON SLAVERY FOR SITUSAMC 

Our Modern 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 Modern Slavery is not taking place anywhere in our supply chains. To that end, we employ several internal policies and practices to ensure that we are conducting business in an ethical and transparent manner, including:

1. Recruitment. We operate a robust recruitment policy, including conducting eligibility-to-work checks and onboarding checks for all employees and contractors to safeguard against human trafficking, child labor or individuals being forced to work against their will. SitusAMC staff members are protected by relevant laws and regulations, which are fully reflected in the firm’s policies and procedures. Contractors and consultants engaged by SitusAMC carry out highly skilled activities and are therefore deemed low risk.

2. Whistleblowing. SitusAMC maintains a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chains, without fear of reprisals.

3. Supply Chain Compliance and Due Diligence. SitusAMC has established Procurement and Vendor Management due diligence programs aimed at identifying, assessing and mitigating the potential compliance and information security risks associated with engaging third-party suppliers for products and services. Our due diligence measures include: risk-based screening and re-screening of vendors; the inclusion of anti-slavery and anti-human-trafficking obligations in our vendor agreements; and the application of a supplier code of conduct, all of which are in place to ensure that our suppliers and contractors comply with our values and our zero-tolerance approach to Modern Slavery. 

4. Our Teams. Each of these practices is managed and enforced by dedicated teams in our Human Resources, Compliance, Procurement, and Vendor Management departments.

TRAINING

To ensure a high level of understanding of the risks of Modern Slavery in our supply chains and our business, we include specific training, detailing what constitutes Modern Slavery and SitusAMC’s zero-tolerance approach, in the annual compliance training of all our employees.

REMEDIATION MEASURES

SitusAMC has not identified any instances of child labor or forced labor in our activities or supply chains. Accordingly, no remediation or corrective measures have been required, including remediation measures with respect to loss of income.

ASSESSING EFFECTIVENESS AGAINST PERFORMANCE INDICATORS

We assess our capabilities at preventing forced labor or child labor through the oversight of our Human Resources, Compliance, Vendor Management, and Procurement teams, in addition to ongoing supplier review, as well as reports made via our whistleblowing channels.

Although SitusAMC considers the risk in relation to Modern Slavery to be low, we will continue to monitor and improve the systems in place to ensure that our business and supply chains are free from Modern Slavery. To quantify progress in this area, we track the following indicators:

• the number and nature of concerns raised through our whistleblowing channels;
• the proportion of employees completing annual modern slavery and human trafficking training;
• monitoring responses from vendors that are subject to due diligence screening, in areas relating to right-to-work status, background verification screening, and working conditions for employees.

APPROVAL

SitusAMC’s Executive Leadership Team has endorsed this statement and affirms SitusAMC’s commitment to combat Modern Slavery. 

Michael Franco
Chief Executive Officer

For additional questions, please email connect@situsamc.com