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page 13:"We are still developing our approach to measure the effectiveness of how we assess and manage modern slavery-related issues. Currently we monitor compliance with our policies through our audit teams; complaints raised through our whistleblowing channel; training attendance and supplier screening. We look into potential environmental, social and governance allegations – including modern slavery-related issues – across our customers and suppliers, and engage with them to understand how they are responding.
Effectiveness measures we have include:
• A goal to train 100% of our procurement staff on modern slavery.
• Fostering a ‘speak up’ culture within ANZ that helps to ensure issues such as modern slavery are appropriately escalated. This would be tracked through increased whistleblowing rates to show uptake of the Whistleblower hotline.
• Our assurance team conduct testing on customer and supplier information to test our financial crime controls."