On page 10 Russell states that "We will continue embedding our Modern Slavery risk and education processes throughout our business and monitoring the effectiveness of these steps through analysis of relevant data collected both internally, and through third party providers, such as Sustainalytics". I believe this means that with the next technological provider, Sustainalytics, Russell is working towards fine-tuning their monitoring of suppliers.

Sustainalytics gives companies the power to monitor more effectively:

"Given the hidden and entrenched nature of modern slavery, companies will be encouraged to adopt a multi-dimensional strategy, covering structural and root causes, rigorous monitoring and a continuous improvement approach." - Page 9 (speaking in reference to the effectiveness of Sustainalytics).

No mention of any audit, onsite visits or compliance check.

pg. 11

“Within the Operations Supply Chain, Modern Slavery is discussed and assessed as part of our engagement with key suppliers. This is done through review of the supplier’s modern slavery statement where available, or in response to Russell Investments Australia Compliance questions. For this second reporting year, suppliers seem largely in the process of bedding down governance and procedural processes implemented in the first reporting period. We consider that our suppliers are developing appropriately at this stage.”