mila-ai4h/AIMS.au huggingface dataset:
[2405] In relation to our supply chain, Mills Oakley has been able to function productively throughout the pandemic and as such we have not needed to alter our agreements and arrangements with suppliers in any great way that would place new or unprecedented pressures on those suppliers
[2405] Assessing the Effectiveness of our Actions
[2405] Mills Oakley knows that risks in this area are fluid and can change over time as we obtain greater visibility over our supply chain, as our suppliers and supply chain changes, and as the world and the occurrence of Modern Slavery alters and shifts
[2405] Furthermore, we need to be sure that the steps we are taking in this area are actually creating positive change
[2405] As such, we are in the midst of establishing a process through which to regularly review our policies and processes in this area
[2405] We have undertaken to continue to further our supply chain mapping as we work through our focus group suppliers and are certain there will be learnings that come out of our engagement with that cohort, that inform future approaches to such examinations
[10726] Based on the Commonwealth Modern Slavery Act 2018 guidance, we have assessed and identified a small number of high-risk industries in our supply chain
[10726] Please refer to the risk assessment and mitigation plans as detailed in Table 1
[10726] Table 1 Risk assessment and mitigation plans Risk Sector Geographical risk and industry sector risk Industry sector risk Industry
[10726] Rubber products
[10726] Textile and uniform
[10726] ICT and electronics
[10726] Cleaning service
[10726] Catering service
[13294] Accountability - Maintaining accountability
[13294] All employees are responsible for: 1) adhering to our companys Code of Conduct; 2) complying with all relevant polices; and 3) raising concerns
[13294] Substantiated violations may result in disciplinary action up to and including termination of employment
[13294] IN OUR SUPPLY CHAINS To help manage and address potential risks of modern slavery (as well as other risk areas associated with third-party business relationships), our Global Procurement Supplier Management (GPSM) has an established third-party risk management program
[13294] Modern slavery risks are considered as part of our third-party risk management activities and is included in a self-assessment questionnaire provided to suppliers in scope
[13294] We recognise that potential risks of modern slavery may also exist in the pharmaceutical supply chain including the suppliers who supply our primary suppliers
[13294] The Pharmaceutical Supply Chain Initiative (PSCI) Human Rights & Labour Sub-Committee has identified several materials2 commonly used within our industry that warrant further examination
[13294] We plan to continue efforts (in collaboration with PSCI) to ensure that the suppliers we work with are appropriately assessed and audited and that the materials we use are sourced responsibly
[14039] We manage approximately 2,500 suppliers to support our operations
[14039] All materials procured for production are sourced from approved suppliers who are required to provide all required documentation to support product and materials traceability in accordance with companys procurement requirements
[14039] Modern slavery is unacceptable within our business and our wider supply chain, therefore, in 2022, we further improved our supplier assurance program to strengthen compliance with ethical trading principles in line with SEDEX standards
[14039] SEDEX is an internationally recognised supply chain transparency platform used to manage and monitor the sustainability of a supply chain
[14039] This is inclusive of monitoring and managing labour standards, health and safety, environment and business ethics practices
[14039] We have embedded these principles across our operations and are working to achieve the same outcomes with our suppliers
[14039] RISKS OF MODERN SLAVERY PRACTICES IN HILTON FOOD AUSTRALIAS OPERATIONS AND SUPPLY CHAINS
[14039] To inform the actions to manage any potential modern slavery risks, several mitigation strategies have been implemented following on the actions identified in the 2020 Modern Slavery Statement
[2405] As stated, we conduct regular reviews with our suppliers already and we will have modern-slavery related discussions as part of these reviews in the future
[2405] We are ensuring that staff are aware of avenues through which they can direct questions and feedback regarding Modern Slavery, and also how to report suspicions of Modern Slavery, as detailed above
[2405] The contents of both will be reviewed by our in-house Modern Slavery experts
[2405] Consultation
[2405] As above, this statement is provided on behalf of Mills Oakley Lawyers, which owns MO Investments and MO Pty Ltd
[2405] The MO entities share the same Board, executive teams, and employees
[2405] The MO entities adopt the same policies and processes and as above share the same supply chain
[2405] This statement was created through collaboration with the following key areas of our business: Human Resources, Information and Technology, Finance and Modern Slavery Specialists
[10726] Construction service Risk profile Above industries have presented high geographic and industry risks according to the Modern Slavery Act
[10726] Often industry employs low-skilled workers and offers poor labour conditions
[10726] Slavery practices are often present in the production side of operation
[10726] In high-risk countries or regions, human rights have been poorly protected, and laws are inadequately enforced
[10726] For instance, forced labour is an issue in many high-risk countries and regions where individuals are held in debt bondage
[10726] Further, the potential for child labour exists in areas of high poverty
[10726] Above industries tend to employ unskilled and often vulnerable workers such as migrants, backpackers or refugees who may not be aware of their rights under Australian law
[10726] The work often occurs outside regular business hours or workers do not receive the legal award rate of pay, superannuation or leave entitlements
[13294] During 2022, we have continually worked to detect and address the risks of modern slavery in our supply chain through: Supplier Selection - Striving to select suppliers that are socially responsible and who share our companys commitments to ethics and legally compliant business practices
[13294] Our goal is to obtain services, goods, active ingredients, components, finished goods or other products in a way that is lawful, fair and aligns with the principles outlined in our BPCC
[13294] Expectations - Setting and communicating our expectations of suppliers, including those related to child labour, forced labour and human trafficking
[13294] We use our BPCC to communicate our expectations
[13294] It has been translated in most countries in which Organon operates
[13294] Supply Chain Mapping - Identifying which of our suppliers operate in countries that are known to present significant risks of modern slavery
[13294] We use this information to help us decide upon the level of due diligence and auditing that may be necessary
[13294] Due Diligence - Conducting appropriate supplier due diligence helps to determine the level of risk presented by suppliers, including both prospective and existing direct material suppliers and contract manufacturing partners
[14039] These include
[14039] Revised procurement frameworks and standard purchasing agreements which explicitly reference the requirements to identify and manage any modern slavery risks
[14039] All suppliers working with Hilton Foods Australia are required to acknowledge and comply with these requirements
[14039] In 2022, our Supplier Social Responsibility Code of Conduct was introduced and it is now part of our global supplier onboarding process and a condition to supply to our business
[14039] In addition, our Supplier Social Responsibility Compliance Requirements outlines the criteria that suppliers must meet to comply with the code
[14039] Our relationship with labour hire suppliers has been further strengthened which allows us to identify and eliminate the possibility of deceptive recruitment for labour practices, forced labour, debt bondage or child labour
[14039] Furthermore, the processes implemented to work with our labour hire partners reflects our own recruitment processes and policies to ensure the suitability of workers for their role and the provision of a safe work environment
[14039] This is inclusive of working rights and visa requirements assessments when applicable
[2405] Consultation occurred with the following senior personnel: our Chief Human Resources Officer, our Chief Financial Officer, our Chief Information Officer, our Modern Slavery Partner, our Learning and Development Team Leader and our National Practice Manager
[2405] From our Governing Body
[2405] Mills Oakley Lawyers makes this Statement in accordance with section 13 of the Modern Slavery Act 2018 (Cth)
[2405] Mills Oakley Lawyers considers that its Governing Board is its principal governing body for
[2405] the purpose of the Modern Slavery Act 2018 (Cth)
[2405] This Modern Slavery Statement was considered and approved of by the Governing Board of Mills Oakley Lawyers on 26 March 2021
[2405] John Nerurker Chief Executive Officer Responsible Member of Mills Oakley Lawyers Principal Governing Body
[3547] CleanCo Queensland Limited Modern Slavery Statement Page 1
[10726] They may also be more susceptible to work-related injuries due to poor working conditions that are not adequately regulated by occupational health and safety standards
[10726] Remedial Action To encourage our suppliers to undertake their own due diligence on their supply chains and manage risks, a Supplier Code of Conduct is issued as part of the supplier onboarding process to ensure that Busways expectation and suppliers' obligations are properly addressed and followed
[10726] In order to maintain a commercial relationship with Busways, all existing and any potential new suppliers are required to complete a comprehensive questionnaire relating to their workforce practices and supply chain
[10726] It enables Busways to better assess risks of modern slavery within the supply chain and network
[10726] Busways works closely with our suppliers once we have assessed their responses to improve the policies and procedures, as necessary
[10726] As more than 75% of Busways' suppliers are small to medium entities, many of them are not required to submit a Modern Slavery Statement themselves, and many of them are unaware of the Modern Slavery Act 2018
[10726] Busways intends to publish an information package and guidelines by the end of 2023
[10726] Actions by Busways Group to assess and address those risks, including due diligence and remediation processes During the FY22 reporting period, Busways Group has progressed further with its commitment to raising awareness and identifying and mitigating the risks of modern slavery across our business
[13294] Our due diligence process for Labour & Human Rights (LHR) targets direct materials suppliers, including external manufacturing suppliers and contract manufacturing organisations, regardless of their geographic location
[13294] A self-assessment questionnaire is used to gather information on LHR matters, including assessing freely chosen employment and that forced labour is never used including disclosures about slavery and trafficking, child labour and young workers, employment practices, employee disclosures, fair treatment, wages, benefits, working hours and freedom of association
[13294] Rubber, Corn, Palm oil, Aluminum, Shellac, Glass, Sugar, Talc; Fish oil; Castor seed/oil; Soy; Cellulose; Ethanol; Carnabawax
[13294] [Organon] Proprietary The information gathered as part of due diligence is used to determine the acceptability of suppliers local practices
[13294] Any red flags identified during due diligence are reviewed and analysed and used to inform our supplier selection and risk management process
[13294] Contracts - Seeking written commitments from suppliers to respect the principles set forth in our BPCC through our contracts/agreements
[13294] Our standard contract templates also contain clauses on compliance with laws, ethical business practice, right to audit/inspect, as well as contract termination
[13294] Auditing LHR audits will be conducted using a risk-based approach at select supplier facilities to verify their conformance with our companys expectations (as stated in our BPCC) and by working with them to address identified non-conformities
[14039] The processes to manage labour hire suppliers was audited as part of the SMETA assessments
[14039] Targeted training and education programs were rolled out to provide training and education tailored to meet the needs of specific groups of employees
[14039] All our senior managers have received training detailing the legal framework of the Modern Slavery Act
[14039] We have continued to utilise Foods Connected to manage records and communications with suppliers
[14039] Foods Connected allows us to share revised policies with all our suppliers, monitor acknowledgement and acceptance of policies and to conduct desktop assessments of suppliers as part of our due diligence practices
[14039] The onboarding of our suppliers to Foods Connected has also increased
[14039] We have continued collaborating and sharing knowledge and processes with ethical trading experts based in the United Kingdom to support the implementation of best practice across our operations and supply chains
[14039] At Hilton Foods Australia we keep abreast of emerging modern slavery risks and consider how emerging modern slavery risks may be relevant to our operations and supply chain
[3547] Modern Slavery Statement for the year ended 30 June 2020
[3547] CleanCo Queensland Limited Modern Slavery Statement Page 2
[3547] Our Values
[3547] At CleanCo we are
[3547] GENUINE
[3547] We care about each others safety, health and wellbeing We are trustworthy we do what we say we will We are trusting we believe the best in each other We greet each other on the floor
[3547] COLLABORATIVE
[3547] No one person has all the answers our first instinct is to collaborate We actively share our knowledge with others We are better with diverse thinking We understand and design for our customers needs
[10726] The key achievements for FY22 are as follows: 1.4.1 Modern Slavery Committee The Modern Slavery Committee was established in 2022, with key members from the finance, IT, HR, risk and compliance, procurement, and operations teams
[10726] The Modern Slavery Committee holds regular scheduled and documented meetings to share, discuss and develop plans to mitigate modern slavery risks across our operations and supply chain
[10726] The committee is in the process of
[10726] Modern Slavery Statement FY22 Page 5 of 8
[10726] developing an action plan to be rolled out over the following three years
[10726] Busways Group understands combatting modern slavery is an ongoing process
[10726] We will utilise the Modern Slavery Committee forum to continue reviewing and monitoring areas of concern, which will lead to updates of risk assessments within our operations and supply chain
[10726] Internal awareness and education To raise awareness of modern slavery and understand its present impacts on our society, Busways Group has developed educational materials and training sessions for internal key stakeholders
[13294] Such audits are intended to involve independent third-party audit firms to perform announced LHR audits at suppliers facilities
[13294] When preparing our audit schedule, we consider the industry risk, the category of materials supplied, the country in which the supplier operates and the results of past due diligence
[13294] Remedial Actions - Tracking and reporting (to senior management) on the closure of remedial actions taken by suppliers to address identified non-conformities (gaps/concerns) revealed by supplier LHR auditing
[13294] Monitoring - Assigning relationship managers from within GPSM to oversee and monitor the performance of key suppliers
[13294] We continue to hold suppliers accountable for meeting their contractual obligations
[13294] Governance - Third-party risk and compliance is embedded in and sponsored by GPSM
[13294] It collaborates with compliance offices and facilitates supplier due diligence and provides independent and objective oversight, monitoring and reporting in relation to the risks presented by third parties
[13294] Engagement - Engaging and seeking input from relevant stakeholders including about modern slavery risks and issues, including GPSM, Office of Ethics & Compliance, Legal, Global Safety & Environment and the Office of Corporate Responsibility
[14039] In particular, we continue to manage the ongoing impact the COVID-19 pandemic has had on the livelihood of our personnel, which can increase the vulnerability of workers in our operations and supply chain to modern slavery risks
[14039] Consequently, we have implemented a number of initiatives to support employees and suppliers during the COVID-19 pandemic and successfully managed to maintain the continuity of food supply to supermarkets
[14039] We have a robust Employee Assistance Program (EAP) to provide support to our employees on a 24/7 basis
[14039] THE ACTIONS TAKEN TO ASSESS AND ADDRESS RISKS OF MODERN SLAVERY
[14039] At Hilton Foods Australia we are committed to maintaining best practice in the identification and management of the risks associated with modern slavery in our operations and in our supply chain
[14039] We are committed to acting ethically and with integrity in all of our direct and indirect business relationships
[14039] The actions to assess and address the risks of modern slavery throughout our operations and supply chains incorporate administrative and operational controls as detailed in this section
[14039] We recognise and acknowledge the potential modern slavery risks associated with the supply chain we manage and the industry sector in which we operate
[3547] CURIOUS
[3547] In a changing world, we get to the bottom of things
[3547] We respectfully question inherited wisdom and the status quo We always seek to learn When something goes wrong, we uncover why without blaming
[3547] COURAGEOUS
[3547] We focus on doing (only) what makes a difference We are happy to be the first We ask If not us, who? And if not now, when
[3547] CleanCo Queensland Limited Modern Slavery Statement Page 3
[3547] Modern Slavery Statement 2020 About this Statement CleanCo Queensland Limited (CleanCo) is opposed to any form of human exploitation in our supply chain or elsewhere
[3547] We are committed to consistently identifying risks of such exploitation and unethical sourcing practices and putting processes in place to prevent this
[10726] These training documents outline and summarise information that will equip key staff to
[10726] Recognise common forms of exploitation identified in the Modern Slavery Act 2018
[10726] Understand the facts and impacts of modern slavery
[10726] Identify signs of modern slavery, both in our operations and our supply chain
[10726] Understand what actions to take if confronted by suspected modern slavery
[10726] Identify our high-level requirements and obligations pertaining to the Modern Slavery Act 2018
[10726] Online training sessions have been taken by members of the Modern Slavery Committee and are in the process of being rolled out to all head office staff
[10726] Further training will be given to employees in all remaining departments over the course of the coming year, with priority given to departments specifically working in procurement, supplies, external services and accounts payable
[13294] Training: Training GPSM professionals with responsibility for supplier selection, oversight and monitoring
[13294] Collaboration: By working with PSCI Labour & Human Rights Sub-Committee to develop training materials on modern slavery and by sharing knowledge across our industry and with our suppliers
[13294] POLICIES Organon prides itself on acting ethically, fairly and with integrity, including by recognising and respecting human rights
[13294] We embody that attitude in our company Code of Conduct and in our Public Policy Statement on Human Rights
[13294] We expect our suppliers to adhere to our BPCC, which is based on our Code of Conduct, as well as the PSCI's Principles for Responsible Supply Chain Management and the 10 Principles of the United Nations Global Compact
[13294] Our BPCC requires our suppliers to treat their workforces with dignity and respect and specifically to not: (i) use any form of forced or involuntary labour, including bonded labour, prison labour or indentured labour; or (ii) engage in or support any form of modern slavery or human trafficking
[13294] VERIFICATION Since June 2021, Organon has required all new direct suppliers (as well as selected indirect and research suppliers in certain geographies based on scoping criteria in place) to complete and return a Supplier Self-Assessment Questionnaire for Ethics & Compliance prior to entering into a contract or arrangement with us
[13294] INTERNAL ACCOUNTABILITY
[14039] In response to these risks, we have proactively developed a suitable policy framework to underpin our
[14039] compliance with internationally recognised standards and codes including
[14039] The UN Universal Declaration of Human Rights
[14039] The International Labour Organisation (ILO) Declaration on Fundamental Principles and Rights at Work
[14039] The UN Guiding Principles on Business and Human Rights
[14039] The UN Global Compact 10 Principles
[14039] The Base Code of the Ethical Trading Initiative (ETI Base Code)
[14039] The United Nations Convention on the Rights of the Child
[3547] We recognise that we are beginning our journey as an organisation
[3547] This statement is our first Modern Slavery Statement under the Modern Slavery Act 2018 (Cth)
[3547] In it we build a baseline from which we can compare and consistently improve on our progress year-on-year as CleanCo matures
[3547] We have the privilege and opportunity to set up a new organisation with the purpose of helping Queensland grasp the opportunities inherent in delivering affordable clean energy for all Queenslanders
[3547] With this comes the responsibility to shape our organisation and our practices to meet our values of being genuine, collaborative, curious and courageous to achieve our purpose
[3547] As our Courageous value states
[3547] We focus on doing (only) what makes a difference
[3547] We are happy to be the first
[10726] Incorporate the prevention of modern slavery into our procurement policies and procedures To raise awareness and create collaboration with companies in our supply chain, Busways Group has incorporated prevention of modern slavery principles into our procurement related policies and procedures
[10726] For instance, within the FY22 reporting period, modern slavery related clauses have been included in our Supplier Code of Conduct and Supplier Onboarding Process
[10726] Our standards and expectations in relation to reducing and eliminating modern slavery from our supply chain have been clearly articulated in these policies
[10726] Furthermore, we are actively searching for an onboarding solution for new suppliers that will allow us to better monitor and manage the standards of all our suppliers, with the aim of ensuring they, and by default we, meet modern slavery prevention requirements
[10726] As part of the FY23 risk mitigation plan set by the Modern Slavery Committee, Busways Group will continue to identify and assess our current policies and procedures to ensure modern slavery related clauses are properly addressed and included in all our policies and procedures, as appropriate
[10726] A continuous improvement approach to mitigate potential risks within our operation and supply chain During the current reporting period, the Modern Slavery Committee has engaged with all key stakeholders within the organisation and identified potential high-risk areas within our supply chain
[10726] Risk segments are in the process of being analysed and once completed, further controls will be defined, and mitigation actions put in place
[10726] Please refer to Table 1