In its Modern Slavery Statement (p. 4) the bank indicates that it has "ongoing efforts to assess the effectiveness of the actions [it is] taking to address modern slavery and human trafficking". This process includes, among other things, revising policies, carrying out trainings, establishing working groups, consulting stakeholders etc. A half a score is appropriate. For a full score, the bank should show it has a process in place to ensure that human rights impacts identified through its due diligence are being addressed effectively.