I don't think that this counts as continuous monitoring because the company is just doing due diligence at intervals during the engagement.

"At the outset of any supplier engagement and at periodic intervals during the contractual period, we require appropriate due diligence (driven by an initial materiality assessment of the third party) to be completed." (pg 2)

"As well as performing due diligence at the initial stage of contracting, our third parties will undergo refreshes at intervals proportionate to the risks they pose. This provides us with continued assurance of their capabilities to meet our regulatory and legislative obligations and a signed attestation in relation to the fitness and propriety of their key personnel. We seek assurance that effective processes are in operation, their employees are of good repute, suitably qualified and experienced, as well as supported in their ongoing development to manage our account." (pg 3)

There is no explicit mention of audit or site visits. But the company mentions that it periodically conducts additional checks in high-risk areas to confirm compliance with the law. So it is considered.

pg. 4

“At the outset of any supplier engagement and at periodic intervals during the contractual period, we require appropriate due diligence (driven by an initial materiality assessment of the third party) to be completed.”

“Where we identify any links to countries with an increased risk of modern day slavery we will apply additional scrutiny and challenge to the responses and evidence provided in addition to the standard due diligence requirements which requires our third parties to confirm and, where appropriate to do so, evidence compliance with all local legislation.”