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Building and maintaining Building trust: Regular audits of trust and transparency • Appointing an investigations advisory panel ethical standards and increasing the representation of affected groups among conduct investigators. In fiscal 2020, our CEO, Julie Sweet, and our • Launching a retaliation monitoring system. We continually assess the effectiveness of CLIENT SPOTLIGHT Global Management Committee reaffirmed • Increasing support for those involved in a compliance-related processes across corporate our unwavering commitment to equality for all, conduct investigation. functions through audits and risk assessments. Insights for law enforcement: with zero tolerance for discrimination, bigotry One example: We have adopted a three-year or hate of any kind. Following this commitment, • Introducing specialized training for cycle of ongoing risk assessments for each of our Identifying human our people made clear that they felt there were investigators, supervisors and managers. global compliance programs on a rotating basis. trafficking networks to bring not enough opportunities to speak up about • Further understanding how microaggressions This is in line with the seven elements of an perpetrators to justice discrimination and racism or to report race- and microinequities impact our people. effective compliance program outlined by the related incidents. We took a hard look at our • Updating our Conduct Counts policies U.S. Department of Justice: Artemis is the world’s first human trafficking business and practices—and we enlisted experts stand to help. We held anonymous focus groups and to reflect our commitment to • Year one consists of a “deep dive” assessment content classifier, developed by the Global . against racism of an individual compliance program in Emancipation Network and Accenture. It feedback sessions, which allowed us to identify analyzes public records, finds common two critical areas where we can do better: collaboration with outside counsel and building trust and increasing transparency. Increasing transparency: external consultants. trafficking terminology and identifies • Year two consists of program enhancements, potential illegal activity, sending alerts to law From there, we developed an action plan, which For many years, we have communicated enforcement agencies so they can further frequently and effectively with our people including designing/implementing investigate. Insights garnered from Artemis is well under way. We are: about how to raise a concern. In fiscal 2021, enhancements, program reviews and desk reviews. have led to prosecutions in California’s we increased transparency with our people Ventura and San Luis Obispo Counties. about how they can find support once they • Year three consists of a program review raise a concern, how the investigation process (e.g., targeted “health check” of select works, and where to find aggregated internal program criteria and framing of next global Learn more data about the types of conduct matters we risk assessment). investigate and their outcomes. United Nations Global Compact: Communication on Progress 2020 | 55

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