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pg. 24

“Suppliers have an obligation under this Code to advise APA of any illegal or unethical practices of which they become aware. Consequences of non-compliance with the Code can include termination of contract.”

Pg. 25

“ Whistleblower reports or disclosures made are investigated by the Disclosure Officer, and where substantiated, process or control improvements implemented.”

pg. 29

“Develop supplier incident response plans – include a response strategy / plan for use if an incident of modern slavery is identified in our supply chain.”

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It is not clear if the 'Disclosure Officer' is part of "senior management" so that is insufficient.

As for the corrective action plan - the company is planning to develop incident response plans, so it does not currently have those in place, meaning it should be "in development" instead.

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Data copied from APA Group for 2021