Monitoring

We believe that regular review and assessment

of the effectiveness of our policies, codes,

standards, and procedures as part of our Risk

Management Framework, combined with the

Modern Slavery Working Group and associated

oversight and reporting will ensure that

Vanguard is able to proactively and assertively

address regulatory and ethical obligations

pertaining to modern slavery risk management (p.5)

And reports actions taken but does not identify KPIs nor does it mention assessing effectiveness.