Modern Slavery Act Statement

SITUSAMC TRANSPARENCY STATEMENT ON THE UK MODERN SLAVERY ACT 2015

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and sets out the steps that SitusAMC has taken and continues  to take to ensure that modern slavery or human trafficking is not taking place within its business or supply chain.

“Modern Slavery” encompasses slavery, servitude, human trafficking and forced labour. 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 chain.

This Statement will be reviewed annually and updated where necessary to reflect changes in circumstances and actual practice. The Statement will be made publicly available on the SitusAMC website.

OUR BUSINESS

SitusAMC is the premier global provider of strategic business solutions for the finance and real estate industries, trusted to evaluate, optimize, and manage critical assets and securities, from commercial and residential real estate, to small and medium enterprise and consumer lending. Since 1985, SitusAMC has set the standard in financial services for service, quality and execution. SitusAMC has offices across the US, Europe and India, and has been involved in more than $1.275 trillion of real estate debt and equity deals. A rated servicer with Moody’s, Fitch and Morningstar, SitusAMC has more than $175 billion of assets under management and is ranked a top 20 servicer in multiple categories by the Mortgage Bankers Association.

SitusAMC employs over 5600 team members worldwide who work from our 41 offices across the U.S., EMEA and APAC, including:

US -  Amherst and New York, NY; Atlanta; GA, Auburn, AL; Boca Raton, Jacksonville, St. Petersburg, FL; Burlingame, Roseville, San Ramon, Torrance, and San Francisco CA; Chicago, IL; Denver, CO; Franklin, TN; Houston, TX; Hudson, WI; Leawood, KS; Parsippany, NJ; Plymouth Meeting, PA; Robbins, NC; Seattle, WA; Southfield, MI; Washington, DC; Waverly and West Des Moines, IA; 

EMEA - London, United Kingdom; Frankfurt, Germany; Dublin, Ireland; and

APAC – Chandigarh, Chennai, Chittoor, Gurgaon, Mumbai and Noida, India.

We are part of SitusAMC, comprising 50 subsidiaries across the jurisdictions identified above, and our ultimate parent company is SitusAMC Holdings Corp. SitusAMC Holdings Corp has its head office in the United States.

SitusAMC’s suppliers include lawyers, accountants, brokers and other advisers and consultants, as well as suppliers of IT and other professional services.  We have minimal contact with countries and sectors that are generally regarded as being the most likely to be a risk for Modern Slavery. SitusAMC utilizes its skill set to assist in completing the financial analysis associated with loan originations, underwriting, closing, securitization, servicing, and asset management.

POLICY ON SLAVERY FOR SITUSAMC

SitusAMC considers the risk of Modern Slavery within its business to be low.  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. 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 in our supply chains.

To that end, we operate a number of 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 for all employees and contractors to safeguard against human trafficking or individuals being forced to work against their will.  SitusAMC staff are protected by relevant laws and regulations, which are fully reflected in the firm’s policies and procedures. Contractors and consultants who are employed or 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 chain, without fear of reprisals.

3.            Supply Chain Compliance. SitusAMC has set up a Vendor Management program to identify and assess potential risks and ensure that proper diligence of suppliers is conducted. SitusAMC has agreements in place with its vendors, and all vendors are reviewed on an ongoing basis to ensure that all those in our supply chain, and contractors comply with our values.

4.            Our Teams. Each of these practices are handled and enforced by dedicated teams in our Human Resources, Compliance, 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.

APPROVAL

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

Michael Franco

Chief Executive Officer