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Pg 9 & 10 shows what the company will do to measure performance effectiveness of its actions to combat slavery and trafficking.
"A working group has been formed with representatives of Legal, Compliance, Risk, Procurement, Human Resources, and Sustainability, Inclusion and Social Impact. This group develops and tracks the effectiveness of our actions to manage the risk of modern slavery in our operations and supply chains. Starting in mid-2022, the modern slavery program will be overseen by the Head of Sustainability, Inclusion and Social Impact, with the continued support of the working group.We will seek to assess the effectiveness of our modern slavery framework, including by tracking our performance against the following goals, in the coming financial year. We will report on progress internally to a steering group, our Board of Directors and the Boards of Directors and governing bodies of the Reporting Entities, and externally in our next Modern Slavery Statement:
1. We plan to roll-out the Modern Slavery Questionnaire to a broader supplier universe.
2. As we gather data on suppliers via the Modern Slavery Questionnaire, potential instances of non-compliance with the Supplier Code, or any protracted failure by suppliers to respond to Modern Slavery Questionnaires, will be identified for further review and engagement. Appropriate remediation steps will be taken or requested as appropriate, and the relevant information will be recorded.
3. We will amend our Third Party Management Practice Standard to make it clear that it is the responsibility of the Vendor Manager for each supplier to assess whether the vendor is compliant with our Supplier Code, as part of managing a supplier relationship.
4. The modern slavery questions in the sub-custodian Due Diligence Questionnaire will be expanded to align with the Modern Slavery Questionnaire and ensure consistency in our supplier due diligence assessment process.
5. We will review our client and transaction screening processes to consider whether the sensitivity of our processes may be enhanced to ensure modern slavery risks are appropriately captured and given due consideration.
6. As the enhanced modern slavery training is rolled out to our employee population, we will track training completion statistics."
[[Sophie Donnelly]].....2023-04-12 21:55:06 UTC
Pg 9 & 10 shows what the company will do to measure performance effectiveness of its actions to combat slavery and trafficking.
"A working group has been formed with representatives of Legal, Compliance, Risk, Procurement, Human Resources, and Sustainability, Inclusion and Social Impact. This group develops and tracks the effectiveness of our actions to manage the risk of modern slavery in our operations and supply chains. Starting in mid-2022, the modern slavery program will be overseen by the Head of Sustainability, Inclusion and Social Impact, with the continued support of the working group.We will seek to assess the effectiveness of our modern slavery framework, including by tracking our performance against the following goals, in the coming financial year. We will report on progress internally to a steering group, our Board of Directors and the Boards of Directors and governing bodies of the Reporting Entities, and externally in our next Modern Slavery Statement:
1. We plan to roll-out the Modern Slavery Questionnaire to a broader supplier universe.
2. As we gather data on suppliers via the Modern Slavery Questionnaire, potential instances of non-compliance with the Supplier Code, or any protracted failure by suppliers to respond to Modern Slavery Questionnaires, will be identified for further review and engagement. Appropriate remediation steps will be taken or requested as appropriate, and the relevant information will be recorded.
3. We will amend our Third Party Management Practice Standard to make it clear that it is the responsibility of the Vendor Manager for each supplier to assess whether the vendor is compliant with our Supplier Code, as part of managing a supplier relationship.
4. The modern slavery questions in the sub-custodian Due Diligence Questionnaire will be expanded to align with the Modern Slavery Questionnaire and ensure consistency in our supplier due diligence assessment process.
5. We will review our client and transaction screening processes to consider whether the sensitivity of our processes may be enhanced to ensure modern slavery risks are appropriately captured and given due consideration.
6. As the enhanced modern slavery training is rolled out to our employee population, we will track training completion statistics."
[[Sophie Donnelly]].....2023-04-12 21:55:06 UTC