"Measurement

Our progress against our key performance indicators, set in 2017 prior to the merger, is as follows:

1. Modern slavery questionnaires issued to our top 400 suppliers and follow up action taken as appropriate.

We have completed our initial survey and taken follow up action with a small number of suppliers to understand more about the approach they are taking. Informed by discussion with independent experts, we are reviewing our approach to strengthen and focus our risk assessment going forward.

2. Sampling of questionnaire responses and modern slavery statements to identify both gaps and opportunities to re-inforce the actions we take in response to the UK Modern Slavery Act 2015.

We have reviewed questionnaire responses and modern slavery statements from a large number of companies across a range of industries. We have also engaged with experts and peer organisations to identify best practices. This has helped to validate our work to date and is informing our approach going forward.

3. Modern slavery training delivered to all our people in 2017.

Modern Slavery training was delivered to all employees of Standard Life group (Standard Life plc and its subsidiaries) prior to the merger. An additional phase, extending coverage across the combined business will be delivered in 2018."