Pg. 10 (Conducting desk research)

“Drawing on guidance from a range of external sources, we used three lenses to assess risk: (1) high-risk geographies, (2) high-risk sectors, and (3) companies with high-risk business practices. Because no single indicator will paint a holistic picture, we triangulated our assessment across multiple indicators using data from different external providers.”

pg. 15 (Tool)

“To try to understand probabilistically which commodities are most likely to be associated with modern slavery, we looked at data from Verisk Maplecroft, which aggregates evidence of modern slavery in commodity production. Because the financial futures we trade are not tied to specific producers or regions, we assessed risk based on the average evidence of modern slavery for all regions of production for each commodity.”

Pg. 20 (In development)

“Looking ahead Moving forward, we plan to improve our risk identification capabilities for our operations and supply chains by:

• Partnering with third-party experts to triangulate changes to our analytical methodology;

• Expanding the scope of engagement through our modern slavery questionnaire to include existing vendors that have not yet been through the screening process; and

• Aggregating the modern-slavery specific data we have begun collecting through a new vendor platform to improve the accuracy of our risk assessment in future reporting periods.”

Pg. 24 (Questionnaire)

“Depending on the nature of the engagement, review components may include questionnaires, open-source information searches, independent company assessments, and litigation and sanctions screening, among others.”