7. Consultation, Approval and Attestation

Working together with the Head of Corporate Sustainability, Inclusion and Social Impact, and the Modern Slavery Working Group, various business lines and functions within the Bank were consulted in the drafting of this Statement, including: Corporate Sustainability, Inclusion and Social Impact; Procurement; Human Resources; Legal; Compliance; Risk and applicable Business Units. These business lines and functions have global mandates, which include the entities to which this Statement applies (as Reporting Entities or because they are owned or controlled by Reporting Entities). Accordingly, the consulted internal stakeholders provided input in relation to the Reporting Entities globally and their owned or controlled entities.

This Statement was reviewed by the Societal and Human Rights Committee in accordance with its new chartered responsibilities and has been approved pursuant to section 11(4)(b)(ii) of the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act by the principal governing body of the Bank as defined by the Modern Slavery Act 2018 (Cth), the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act and the Modern Slavery Act 2015 (U.K.) on February 20, 2024.

In accordance with the requirements of the Canadian Forced Labour and Child Labour in Supply Chains Act, in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the Bank. Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act, for the reporting year listed above. I make this attestation for and on behalf of the Bank in my capacity as a director and Chief Executive Officer of The Northern Trust Company. I have the authority to bind, or direct or cause others to bind, each of the reporting entities pursuant to the Australian Modern Slavery Act 2018 (Cth), the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Canadian Act) and the United Kingdom (U.K.) Modern Slavery Act 2015.

Michael G. O’Grady
Chairman and Chief Executive Officer
The Northern Trust Company

Approved by the Boards of Directors of the Reporting Entities as follows:

The Northern Trust Company	February 20, 2024
Northern Trust Investor Services Limited	March 12, 2024
Northern Trust Global Services SE	March 20, 2024
Northern Trust Global Investments Limited	March 21, 2024
Northern Trust Management Services Limited	March 22, 2024
Northern Trust Securities LLP	March 27, 2024

End Notes

Australian, Canadian and U.K. operating entities are listed in Annexure A with a short description of each of their operations
As defined in the Canadian Act to include labor or services provided or offered to be provided by a person under the age of 18 years and that: (a) are provided or offered to be provided in Canada under circumstances that are contrary to the laws applicable in Canadian; (b) are provided or offered to be provided under circumstances that are mentally, physically, socially or morally dangerous to them; (c) interferes with the person’s schooling by depriving them of the opportunity to attend school, obliging them to leave school prematurely or requiring them to attempt to combine school attendance with excessively long and heavy work; or (d) constitutes the worst forms of child labor as defined in article 3 of the Worst Forms of Child Labour Convention, 1999.
https://www.northerntrust.com/united-states/about-us/corporate-social-responsibility/corporate-philanthropy/impact-report
Where goods or services were provided by multiple subsidiaries within the same corporate group, the company at group level was counted once.
See heading “Supplier Due Diligence via the Modern Slavery Questionnaire” for a description of the suppliers that have received the Modern Slavery questionnaire and are represented in Figure 2.
https://cdn.northerntrust.com/pws/nt/documents/governance/code-of-business-conduct-ethics.pdf?1010
https://www.northerntrust.com/content/dam/northerntrust/pws/nt/documents/about-us/policy/human-rights-statement.pdf
https://www.northerntrust.com/content/dam/northerntrust/pws/nt/documents/investment-management/sustainable-investing-philosophy.pdf
https://unglobalcompact.org/what-is-gc/mission/principles/principle-4
https://www.northerntrust.com/united-kingdom/what-we-do/investment-management/stewardship
PRI | Advance (unpri.org)