"During the past year, we have focused on the following key initiatives:

• Formalised our understanding and management of key risks associated with modern slavery;

• Formed a cross-functional working group to identify and mitigate modern slavery related risks and generate this Statement;

• Built awareness throughout Vanguard of the risks associated with modern slavery and the areas most at risk;

• Identified key policies and processes which Vanguard Australia Modern Slavery Statement

have significant impact on the key risks associated with modern slavery; and

• Completed our initial due diligence review on our current practices to identify areas for future and continuous improvement to help reduce the key risks associated with modern slavery" pg. 6