Modern Slavery Act Statement

SITUSAMC TRANSPARENCY STATEMENT ON THE UK MODERN SLAVERY ACT 2015 AND CANADA’S BILL S-211

This statement is made pursuant to Section 54(1) of the United Kingdom’s Modern Slavery Act 2015 and Section 11 of Canada’s Bill S-211, An Act to enact the Fighting Against Forced Labour and Child Labour in Supply Chains Act and to amend the Customs Tariff and sets out the steps that SitusAMC has taken and continues to take to ensure that modern slavery, child labour or human trafficking is not taking place within its business or supply chains.

“Modern Slavery” encompasses slavery, servitude, human trafficking, child labour 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 chains.

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 (www.situsamc.com). The UK government has proposed an amendment to the Modern Slavery Act 2015 to require that this statement include information on six areas. In the spirit of this proposed change, we have provided information on each of these areas.

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 utilizes its skill set to assist in completing the financial analysis associated with loan originations, underwriting, closing, securitization, servicing, and asset management.

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 Fitch, 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 5400 team members worldwide who work from our 27 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; Roseville, San Jose and San Francisco CA; Chicago, IL; Denver, CO; Franklin, TN; Houston, TX; Hudson, WI; Overland Park, KS; Parsippany, NJ; Plymouth Meeting, PA; Southfield, MI; West Des Moines, IA;  EMEA - London, United Kingdom; Frankfurt, Germany; Dublin, Ireland; and APAC – Bengaluru, Chennai, Gurgaon, Hyderabad, Pune and Mumbai, India.

SitusAMC comprises 56 subsidiaries across the jurisdictions identified above and our ultimate parent company is SitusAMC Holdings Corporation. SitusAMC Holdings Corporation has its head office in the United States.

OUR SUPPLY CHAIN

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.

RISKS OF SLAVERY, CHILD LABOUR OR HUMAN TRAFFICKING

As a result of SitusAMC’s activities and effective policies addressing Modern Slavery, the risk of Modern Slavery is low across SitusAMC’s supply chains and business. 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.

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 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 and onboarding checks for all employees and contractors to safeguard against human trafficking, child labour 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 chains, without fear of reprisals.

3.            Supply Chain Compliance and Due Diligence. SitusAMC has set up a Vendor Management program to identify and assess potential risks and ensure that proper due 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 chains and contractors comply with our values and our zero-tolerance approach to Modern Slavery.

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.

NEXT STEPS: MEASURING EFFECTIVENESS AGAINST PERFORMANCE INDICATORS

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 date we have not identified key performance indicators (KPIs) that we can use to report progress. However, SitusAMC will review the possibility of developing KPIs for use in future reporting.

APPROVAL

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

Michael Franco

Chief Executive Officer