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"V. Training

We acknowledge that educating our staff is fundamental to ensuring potential human rights and modern slavery risks are identified and managed. BNY Mellon’s current onboarding and refresher training for staff includes BNY Mellon’s Code of Conduct, with specific focus on:

conducting business in full compliance with all applicable laws and regulations, and in accordance with the highest ethical standards;

and being willing to take a stand to correct or prevent any improper activity.

In addition, we trained our global procurement team and select members of our legal, risk and compliance team on modern slavery and human trafficking, and on our role in identifying and managing the risk of such activities."