Riverstone Modern Slavery and Human Trafficking Statement

November 2021

Introduction

Modern Slavery is a crime in a number of countries, including in the United Kingdom (“UK”), and a violation of fundamental human rights. It can take various forms including slavery, servitude, forced and compulsory labour, child slavery and human trafficking, all of which have in common the deprivation of a person's liberty and freedom by another in order to exploit them for personal or commercial gain.

Riverstone has a zero-tolerance approach to modern slavery. We believe in acting ethically and with integrity in all our business dealings and relationships, running our business responsibly, and respecting human rights. We are committed to implementing and maintaining effective systems and controls to ensure modern slavery is not taking place anywhere in our own business and to combat the risk of modern slavery taking place in our supply chains. We are also committed to ensuring that there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains. We expect the same high standards from all of our contractors, suppliers and other business partners.

This statement is made on behalf of Riverstone Living Holdings Limited, a company incorporated in England and Wales with company number 11081627 (“RLHL”), and its subsidiaries (the “Group”). It sets out steps taken by the Group to assist in the prevention of modern slavery and human trafficking in any part of the Group’s business and supply chain.

Our organisation

RLHL was established in 2017 to provide best in class retirement living in London: outstanding apartments where residents can live the life they want, surrounded by a choice of incredible amenities, with well-being and bespoke care services available if required. All our apartments will be sold on a 150-year lease or the time left on the lease for resales. Our residences have been designed with our residents’ enjoyment, health and well-being in mind and will offer a range of high quality amenities and bespoke care services.

To realise our ambition, two of our subsidiary companies were established in 2018 to develop and run our two inaugural residences.

• Fulham Riverside Property Limited (company number 11331383) was established in April 2018 to be the owner and operator of our Riverstone Fulham residence.
• Kensington Row Property Limited (company number 11579917) was established in September 2018 to be the owner and operator of our Riverstone Kensington residence.

Our business

We currently employ under 50 colleagues who are based in our head office and information suites in London. The total number of Riverstone colleagues and Riverstone contractors will increase materially when our two residences open. Our business operations and direct supply chain relationships are based in the UK.

Our business covers the construction sector and will, once our residences open, also cover the care and hospitality sectors. We recognise that these sectors are associated with a higher risk of instances of modern slavery occurring.

Our extensive suite of human resources policies reflects the importance we place on ensuring our colleagues and contractors work in a safe, fair and transparent environment.

• The Group has a robust hiring process. Additionally, we only use reputable recruitment agencies and avoid the use of casual labour to minimise risks to our internal operations.
• Our Anti-Slavery and Human Trafficking Policy was launched through an internal communication and a statement from our CEO. It will also be communicated with our suppliers. As part of our induction process, new colleagues are provided with a copy of our Anti-Slavery and Human Trafficking Policy, required to acknowledge receipt of it, confirm that they have read it and complete the Riverstone anti-modern slavery training.
• Our Equal Pay Policy and Equality & Diversity Policy enshrines our commitment to equality, diversity and equal pay within our business. We are committed to paying our colleagues and contractors throughout our organisation at least the London living wage.
• We have a Health & Safety Policy in place which ensures colleagues are working in a safe environment, and aims to develop a culture that is committed to the prevention of ill health and injuries to our colleagues and others who may be affected by our business.
• Our Whistleblowing Policy and our Complaints and Grievance Policy & Procedure provide appropriate and effective channels of communication for colleagues who have concerns.
• We require that our contractors confirm that they have read, understood and agree to abide by our Supplier Principles, which include provisions relating to anti-modern slavery.

Our supply chain

We recognise the importance of identifying all potential modern slavery and human trafficking risks related to our supply chain. The Group manages the selection, performance and relationships with its partners and professional service providers with great care, including conducting robust due diligence and risk profiling on all our suppliers.

During the selection and management of our supplier relationships, we place particular emphasis on anti-modern slavery. All our suppliers must comply with all relevant legislative and regulatory criteria, including the Modern Slavery Act 2015, and operate safely and ethically. Our primary suppliers must also maintain anti-modern slavery policies and procedures, applicable to their circumstances and proportionate to the risks they face and, at all times, act in a manner consistent with the Group’s own Anti-Modern Slavery and Human Trafficking Policy.

We include anti-modern slavery clauses in our development and construction contracts, as well as in higher value commercial agreements.

We will not engage suppliers who knowingly participate in the crime of modern slavery.

Our Whistleblowing Policy provides a channel of communication for colleagues who have concerns and our Anti-Modern Slavery and Human Trafficking Policy details the escalation point for contractors, suppliers and other business partners.

Our effectiveness at managing modern slavery risks

In this next year, we will use the following key performance indicators to measure our effectiveness.

• Introducing training on anti-modern slavery for all colleagues. This will include obtaining confirmation from colleagues and contractors that they have read and understood our Anti-Slavery and Human Trafficking Policy.
• Consolidating our colleagues’ and contractors’ understanding of modern slavery risks within our business and our risk management approach to the same, including through an internal communications initiative.
• Raising awareness of our existing reporting mechanisms as part of our internal communications initiative.
• Implementing a supplier code of conduct and obtaining formal acknowledgement of our approach from suppliers.
• Including appropriate modern slavery and ethical clauses in all our supplier contracts.
• Verifying suppliers’ compliance with our anti-modern slavery policies and procedures expectations on an annual basis. Riverstone will also assess the viability for an external annual audit of suppliers’ compliance with Anti-Slavery and Human Trafficking law and regulation.
• Mapping at high level our supply chains across jurisdictions to further inform our risk-based approach to mitigating modern slavery in our supply chains.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement. This statement has been approved by Riverstone’s Board of Directors and Audit and Risk Committee, who will review and update it annually.

Jason Leek

Chief Executive Officer of Riverstone Living Holdings Limited

12^th November 2021