5. Assessing the Effectiveness of
our Actions

5. Assessing the Effectiveness of our Actions

Northern Trust’s Head of Corporate Sustainability, Inclusion and Social Impact is the executive responsible for the design and implementation of our Modern Slavery risk management program, with the support of the Modern Slavery Executive Steering Group, that was recast as the Societal and Human Rights Committee in December 2023.

The new committee will provide enhanced governance, oversight and strategic direction for human rights issues (including Modern Slavery) and social responsibility matters into our operations, policies and practices.

Our Modern Slavery Working Group comprising of representatives from Corporate Sustainability, Inclusion and Social Impact; Procurement; Human Resources; Legal; Compliance; and Risk continued to meet periodically during 2023. The Working Group develops and tracks the effectiveness of our actions to manage the risk of Modern Slavery in our operations and supply chains.

Where a concern arises within Northern Trust in relation to a Modern Slavery risk, it is referred to the Working Group for consideration. The Modern Slavery Working Group provides recommendations to senior management in relation to how the issue should be addressed and, if necessary, escalated to the Executive Steering Group or from 2024 to the Societal and Human Rights Committee. The Corporate Governance Committee of our board of directors is regularly briefed on the program and reviews our goals and progress.

In our 2022 Modern Slavery Statement, we set out the following goals that we planned to achieve during 2023, to demonstrate our progress in addressing Modern Slavery risks in our operations and supply chains:

	Goals Set in 2023	Actions Taken in 2023	Status
1.	Conduct a Living Wage project to assess our pay practices globally against living wage benchmarks provided by Fair Wage Network.	Assessment completed. Refer to Section 4.	Complete
2.	Our commitment to addressing Modern Slavery in our investments will continue in 2023 as we assess various opportunities to strengthen our resources and expertise through participation in industry initiatives dedicated to addressing human rights issues from an asset management perspective. Participate in at least one collaboration in the metals, mining and renewables sector during 2023.	We continued to monitor the companies alignment to the United Nations Global Compact principles. All seven of the companies we engaged with in 2023 acknowledged the concerns we identified with respect to the supply chain risks of forced labor in the supply chain and are now in various stages of remediation.	Ongoing
3.	Issue the Modern Slavery Questionnaire to more than 500 suppliers in 2023.	Complete. Refer to section 4B.	Complete
4.	Liaise with suppliers identified as high risk for Modern Slavery in 2022 or who were identified as requiring further review following the Modern Slavery Questionnaire. Agree action plans with at least 50% of these high risk suppliers, including all cleaners/facilities management suppliers.	Complete. Refer to section 4B.	Complete
5.	Where available, will replace beverage supplies with Fair Trade, Rainforest Alliance or similar products in our office locations globally. At least two-thirds of all Northern Trust office locations will have replaced existing beverage supplies with Fair Trade or similar products by the end of 2023.	Complete. Refer to section 4A.	Complete

In the coming financial year, we will seek to assess the effectiveness of our Modern Slavery program, including by tracking our performance against the following goals. We will internally report on progress to our new Societal and Human Rights Committee, the Disclosure Committee and the Corporate Governance Committee of our board of directors and externally within our next Modern Slavery Statement.

	Goals Set for 2024	Actions Planned for 2024
1.	Evaluate the findings from our 2023 Living Wage project and embed a review (at least annually) of our pay practices globally against living wage benchmarks as provided by Fair Wage	Findings to be reported to the Societal and Human Rights Committee, and if applicable, adjustments to pay to be implemented
2.	Issue the Modern Slavery Questionnaire to a broader population of suppliers	Issue the Modern Slavery Questionnaire to more than 500 suppliers in 2024.
3.	Liaise with suppliers identified as high risk for Modern Slavery in 2023 or who were identified as requiring further review following the Modern Slavery Questionnaire.	Agree action plans with at least 50% of these high-risk suppliers.
4.	Our commitment to addressing Modern Slavery in our investments will continue in 2024 as we assess various opportunities to strengthen our resources and expertise through participation in industry initiatives dedicated to addressing human rights issues.	Participate in at least one collaboration under the PRI Advance initiative during 2024.
5.	Continue to monitor investments identified as high risk for Modern Slavery and support shareholder requests for additional disclosures regarding Modern Slavery risk where appropriate.	Expand the list of companies NTAM engages with from 20 to 25 during 2024.
6.	Participate in the 2024 UN Global Compact’s Business & Human Rights Accelerator Program	Continue to build out Northern Trust’s Modern Slavery program to identify salient human rights impacts, review our ongoing due diligence processes and develop an actionable plan.