modern slavery act.pdf
MODERN SLAVERY ACT 2015 STATEMENT
FINANCIAL YEAR ENDING 30 September 2025
This statement is made by Benefit Street Partners Limited (“BSP” or “we”) as an entity subject to the requirements of section 54 of the UK Modern Slavery Act 2015 (the “Act”) in respect of the financial year ended 30 September 2025.
This statement sets out the steps taken to mitigate the risk of modern slavery and human trafficking taking place within any part of our business and our supply chains.
Our business
Benefit Street Partners Limited is a limited liability company incorporated under the laws of England and Wales, which is authorized and regulated by the Financial Conduct Authority of the United Kingdom (the “FCA”). Benefit Street Partners Limited is an asset management business with its registered office at 78 Cannon Place, London, EC4N 6HL.
Franklin Resources, Inc., a global investment management organisation operating as Franklin Templeton Investments (“Franklin Templeton”), is one of the world’s largest investment managers. Through distinct specialist investment managers, Franklin Templeton offers boutique specialisation on a global scale, bringing extensive capabilities in fixed income, equity, alternatives and multi-asset solutions. Benefit Street Partners Limited operates within Franklin Templeton’s alternative credit platform, which offers a broad range of complementary credit strategies, including private/opportunistic debt, structured credit, high yield, special situations, long-short liquid credit and commercial real estate debt.
We acknowledge our responsibilities in respect of the Act and the prevention of modern slavery and human trafficking. In addition, we take steps to seek to ensure transparency within our organisation and with our suppliers of goods and services in relation to the prevention of modern slavery and human trafficking.
Supply chains and business relationships
We contract with a number of direct and indirect suppliers of goods and services, including suppliers of IT, office equipment and cleaning services, as well as professional services from lawyers, accountants and other advisers and consultants. We also contract for services required to support staff in our various offices and have agreements in place with third party payroll providers, pension fund managers, providers of private healthcare, employee benefits and other associated services required to support our employees. In addition, Benefit Street Partners Limited contracts with a number of financial services firms in relation to the investment management, administration and distribution of products and the provision of its services.
Due to the nature of the goods and services supplied, the majority of suppliers in our supply chain are not located in countries or sectors that are considered to be at high risk of exposure to human trafficking or slavery. Many of our business relationships are with financial and professional services firms that are also subject to modern slavery regulation and have low risk of exposure to human trafficking and modern slavery.
Location and industry types are important factors when assessing new and existing business relationships, as some countries and industries are more susceptible to human rights violations, modern slavery and human trafficking risks than others. Franklin’s business lines use a country risk assessment program and apply enhanced due diligence measures and controls when onboarding business relationships with operations in high-risk countries and high risk industries.
Policies in relation to modern slavery, human trafficking and human rights
Franklin Templeton is committed to upholding and respecting human rights of our employees and all those involved in our business interactions. In our own operations, our policies are consistent with the Ten Principles of the United Nations Global Compact and the commitments within the International Labour Organisation Declaration on Fundamental Rights at Work in all jurisdictions in which we do business. Franklin is a signatory of the Principles for Responsible Investment (“PRI”), which works to understand the investment implications of environmental, social and governance (“ESG”) factors.
Franklin is also subject to modern slavery regulation in jurisdictions in which it operates, specifically the UK Modern Slavery Act 2015, the Australian Modern Slavery Act 2018 and the Canada Fighting Against Forced Labour and Child Labour in Supply Chains Act. Where there are differences between the applicable policy and the laws or rules of any such local jurisdiction, the stricter of the two will apply.
We are committed to ensuring that none of our members of staff and none of the vendors they contract with have any involvement in human trafficking and modern slavery. This is consistent with the principles of our Anti-Bribery Policy, which outlines the steps followed to achieve zero-tolerance against bribery and corruption, as well as our Code of Ethics, which requires staff to uphold the highest level of ethical conduct in their day-to-day business. Additionally, our employee policies further reflect our commitment to acting ethically and with integrity in all our business relationships. Our Global Human Rights Policy also sets out our zero-tolerance approach to modern slavery and human trafficking if identified within any part of our business.
Unmanaged human rights issues can expose companies to significant legal, regulatory, operational and reputational risks, while violation of modern slavery regulation may have serious consequences for both Franklin and the individuals involved. Any Covered Person who violates the Global Human Rights Policy may be subject to disciplinary action by Franklin, including termination if permitted by local law.
We also have whistleblowing procedures in place to encourage the reporting of unethical or illegal conduct to internal teams, as well as a confidential Compliance and Ethics Hotline run by external trained specialists, and these procedures offer the protection of whistle-blowers.
Modern slavery and human trafficking
The terms “modern slavery” and “human trafficking” are often used interchangeably. Modern slavery is a term that refers to the severe exploitation of other people for personal or commercial gain. It can include forced labour, debt bondage, slavery and human trafficking. Human trafficking means the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, for the purpose of exploitation.
Modern slavery and human trafficking red flags can include exposure to high-risk countries; industries that are deemed higher risk, such as cleaning, maintenance services, construction and transportation/freight; cash-based businesses; unusual, complex structures; unclear source of wealth and beneficial ownership; forged documents; adverse media; limited or unclear company information; and vulnerable populations, such as low skilled, migrant workers or minorities.
Due diligence
Employees
Recruitment at Benefit Street Partners Limited is conducted through an online application system either directly by the candidate or via a third-party supplier such as a contracted recruitment company. Applications for all roles (permanent, temporary and contract) are reviewed and appropriately experienced candidates are invited for interview. Reference and background checks are carried out on all prospective employees, using a third-party specialist company, and proof of the right to work in the UK is mandatory.
Benefit Street Partners Limited base salary levels and benefit provision are set with reference to appropriate market benchmarking data (third party industry surveys), which are regularly reviewed. We also take into account any mandated minimum pay levels, fair pay and any other relevant legislation when setting base salary levels and benefit provisions. All salary payments are made directly to each employee’s personal bank account.
Human rights-related risks can include a hostile, unsafe or discriminatory workplace that could lead to a high turnover of staff, poor retention rates and adversely impact productivity and innovation; poor working conditions, inadequate wages and use of modern slavery and trafficking by a company or its vendors in their supply chains; and failure to adhere to applicable privacy laws that could lead to regulatory penalties and loss of trust from stakeholders.
Suppliers and other third parties
As an FCA regulated business, Benefit Street Partners Limited is under an obligation to carry out initial and ongoing screening on vendors with which we enter arrangements for the provision of services. We believe that this due diligence provides us with an understanding of third parties with whom we enter into arrangements for the provision of services and supplies.
The Franklin Templeton supplier risk management team, which supports the broader enterprise vendor management programme, is responsible for the identification, assessment and management of potential threats introduced by suppliers. The global necessity to evaluate supplier risks at the onset, and throughout the life of the relationship, is paramount in protecting Franklin Templeton and ensuring regulatory compliance.
There is a global due diligence procedure for the suppliers in the FT accounting system that are identified as higher risk of modern slavery and human trafficking and they are screened for negative media on a monthly basis in addition to KYC and sanctions screening.
Franklin takes a risk-based approach when applying due diligence measures for relationships with clients, suppliers, distributors, separate accounts, vendors and other third parties. The Franklin Enterprise Vendor Management Department uses a centralised tool called COUPA to manage onboarding and ongoing vendor relationships, including sanctions screening of names, attestations and enhanced due diligence where required.
Many of the service providers with which we work are financial and professional services organisations which are themselves subject to strict regulation.
Supplier adherence to our values
We have a zero-tolerance approach to modern slavery and human trafficking. We endeavour to include appropriate terms in our contracts to ensure vendor compliance with applicable legislation regarding prevention of modern slavery and human trafficking. All key staff involved in recruitment and vendor sourcing are made aware of our policy. Given the nature of our business and the services that we receive, we consider that the risk of modern slavery or human trafficking in our business and supply chains is low.
Please factor human rights and human slavery risks when initiating business relationships on behalf of the Company.
Reporting concerns and questions
If you suspect or identify any unethical practices or concerns in relation to modern slavery or human trafficking, please immediately contact the Financial Crime Compliance Team at ComplianceFinancialCrime@franklintempleton.com.
Human rights issues are often complex. The Global Human Rights Policy is designed to provide guidance, but it cannot anticipate all situations that may arise during the Company’s business. If you are ever in doubt, seek advice. Contact Human Resources, Legal or Compliance before taking any further action.
You can also contact the Financial Crime Compliance Team at ComplianceFinancialCrime@franklintempleton.com; the HR Global Policy & Risk Team at HRGlobalPolicy&RiskTeam@FranklinTempleton.com; the Compliance and Ethics Hotline at 1-800-636-6592 (US) or by calling collect at 1-704-556-7046 (non-US); Franklin’s Ombudsman, Thomas Merchant, via email at thomas.merchant@franklintempleton.com, interoffice mail (USA-BAL100-Baltimore) or telephone at 1-410- 454-4415; or the Western Asset hotline at https://secure.ethicspoint.com/domain/media/en/gui/82240/index.html.
The Compliance and Ethics Hotline, which is operated by a third party, allows individuals to report concerns confidentially. Franklin will not tolerate any form of retaliation against anyone reporting a potential violation in good faith or for participating in an investigation of a report.
Training
To seek to ensure the risks of slavery and human trafficking in our supply chains and our business are understood, appropriate training, including in respect of anti-money laundering and anti-corruption, is provided to relevant members of staff.
All Franklin employees complete Financial Crime Compliance training which references modern slavery and human trafficking as a predicate crime associated with anti-money laundering. In addition, based on their role in the Company, Franklin employees will also complete Respect in the Workplace training which includes respecting the human rights of other individuals.
Exceptions and policy ownership
Covered Persons must submit any proposed exceptions to the Global Human Rights Policy with a documented rationale to Compliance or Human Resources for review and approval. Franklin’s Financial Crime Compliance team and Human Resources are responsible for the operation and coordination of the Global Human Rights Policy.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 30 September 2025.