Anti Slavery Statement

Anti-Slavery and Human Trafficking Statement

Effective Date: 1st June 2023

Northstar Research (“we,” “our,” or “the Company”) is committed to conducting business with integrity, transparency, and respect for human rights. We strongly oppose all forms of modern slavery, forced labor, and human trafficking, and we are dedicated to ensuring that our operations and supply chains remain free from such practices.

1. Our Business

Northstar Research provides financial research, analysis, and related services to professional and retail investors. Our business is knowledge- and technology-based, and while our supply chain exposure is limited, we recognize our responsibility to remain vigilant against the risks of forced labor and human trafficking in all industries.

2. Our Legal and Ethical Commitment

We comply with all applicable U.S. federal laws prohibiting slavery, involuntary servitude, and human trafficking, including:

The 13th Amendment to the U.S. Constitution – abolishing slavery and involuntary servitude.
 

The Trafficking Victims Protection Act (TVPA) of 2000 and its reauthorizations – establishing prevention, protection, and prosecution measures against human trafficking.
 

The Tariff Act of 1930 (19 U.S.C. § 1307) – prohibiting the importation of goods made with forced or child labor.
 

Where applicable, we also recognize international frameworks, including the UN Universal Declaration of Human Rights and the International Labour Organization (ILO) conventions.

3. Our Supply Chain

Our supply chain primarily involves professional services and technology providers (e.g., data platforms, software, and cloud services). Even though the risk of modern slavery is low in these sectors, we take proactive steps to manage it:

Partnering only with reputable vendors and service providers.
 

Expecting suppliers to comply with all labor laws and human rights standards.
 

Including ethical compliance expectations in our vendor relationships.
 

4. Policies and Practices

We have established internal policies and procedures to reinforce our stance:

Code of Conduct: setting clear standards for ethical business behavior.
 

Vendor Oversight: ensuring that suppliers act in accordance with human rights obligations.
 

Whistleblowing Mechanism: allowing employees and stakeholders to raise concerns safely and confidentially.
 

5. Training and Awareness

We promote awareness among staff regarding human rights and modern slavery risks, particularly for those involved in vendor selection, procurement, or compliance roles.

6. Monitoring and Continuous Improvement

We are committed to continuous improvement in safeguarding human rights. We will:

Monitor evolving risks in supply chains.
 

Strengthen our due diligence and oversight as our business grows.
 

Review our anti-slavery policies annually to ensure they remain effective.
 

7. Responsibility and Oversight

Oversight of this policy rests with Northstar Research’s senior leadership. All employees are expected to uphold our values and report concerns regarding unethical practices.

8. Approval

This statement has been approved by the leadership of Northstar Research and reflects our ongoing commitment to preventing modern slavery and human trafficking in all aspects of our business.

Signed,

Kevin G Williams
CEO
Northstar Research