Supplier Partnerships has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our direction or control are in compliance.

The Senior Vice President of Supplier Partnerships has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.  We continually monitor and review work product to ensure no violations of this policy occur and if they do, are promptly reported to the appropriate authorities.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and receive any required training.