mila-ai4h/AIMS.au huggingface dataset:
[13459] HLR Aus will also put into place further processes to capture information on new business partners at the beginning of the relationship
[13459] During the course of this next financial year, HLR Aus will look to implement a third party monitoring tool into its supplier due diligence processes and procedures
[13459] To assess the effectiveness of HLR Auss actions, we will review our existing systems and processes when updating the supplier due diligence processes over the next reporting period
[14094] This statement provides information about Adapt IT Proprietary Limited and its group companies (together, Adapt IT), and sets out the plans and actions of Adapt IT to identify and mitigate modern slavery risks in its business and supply chain
[14094] Adapt IT Proprietary Limited is a private company registered in South Africa and a wholly owned subsidiary of Adapt IT Holdings Proprietary Limited, the South African holding company for the Adapt IT group which is itself a subsidiary of the Constellation Software Inc (Constellation Software) group of companies
[14094] CSI is a Canadian public company listed on the Toronto Stock Exchange under the symbol CSU
[14094] This statement is made pursuant to the Modern Slavery Act 2018 (Act) and relates to the financial year 1 January 2022 to 31 December 2022 (Reporting Period)
[14094] Section 54 of the Australian Modern Slavery Act requires organisations registered or carrying on business in Australia, and with a consolidated revenue of at least AUD$100 million, to report annually in a modern slavery statement on how they are addressing the risks of modern slavery in their supply chain and operations
[14094] Adapt IT Proprietary Limited is a reporting entity as defined in the Act
[14094] DocuSign Envelope ID: 63EE6DFA-E119-47B0-B3A5-D47CF6AD66A6
[4651] Promote and facilitate open communication
[4651] and raising of concerns
[4651] Providing our employees with a healthy
[4651] and safe work environment that complies
[4651] with all applicable occupational safety and
[4651] health laws and standards
[4651] Promoting a competitive marketplace
[4651] and complying with applicable antitrust
[11012] CONSULTATION AND APPROVAL This Modern Slavery Statement is made pursuant to the Modern Slavery Act 2018 (Cth) and has been reviewed and approved by the principal governing bodies of the following reporting entities: CBP Lawyers Holdings Limited on 19 December 2022 Colin Biggers & Paisley Limited on 19 December 2022 Denizo Pty Ltd on 19 December 2022 CBP Consulting Pty Ltd on 19 December 2022 Quick Convey Pty Limited on 19 December 2022 This statement is signed by Nick Crennan, a responsible member of each of the reporting entities, and Managing Partner of Colin Biggers & Paisley Lawyers
[11012] NICK CRENNAN Managing Partner Colin Biggers & Paisley ANNEXURE A MANDATORY CRITERIA SECTION 16 MANDATORY CRITERIA REPORT PAGE NUMBER/S Identify the reporting entity
[11012] Describe the reporting entitys structure, operations and supply chains
[11012] Describe the risks of modern slavery practices in the operations and supply chains of the reporting entity and any entities it owns or controls
[11012] Describe the actions taken by the reporting entity and any entities it owns or controls to assess and address these risks, including due diligence and remediation processes
[11012] Describe how the reporting entity assesses the effectiveness of these actions
[11012] Describe the process of consultation on the development of the statement with any entities the reporting entity owns or controls (a joint statement must also describe consultation with the entity covered by the statement)
[11012] BRISBANE Level 35, Waterfront Place 1 Eagle Street Brisbane QLD 4000 Australia +61 7 3002 8700 MELBOURNE Level 23 181 William Street Melbourne VIC 3000 Australia +61 3 8624 2000 SYDNEY Level 42 2 Park Street Sydney NSW 2000 Australia +61 2 8281 4555
[13459] CONSULTATION AND APPROVAL 20 For the purposes of consultation, HLR Aus has no entities which it owns or controls
[13459] This statement is made in accordance with the Modern Slavery Act 2018 (Cth) and constitutes HLR Auss Modern Slavery Statement for the financial year commencing 1 January 2022 to 31 December 2022
[13459] This statement was approved on 22 June 2023 by the Board of HLR Aus
[13459] Gerd Obertopp Managing Director Date: 23 June 2023
[13523] Modern Slavery Statement Financial Year 2022
[13523] Introduction The Modern Slavery Act 2018 (Cth) ( the Act) requires entities based or operating in Australia, which have annual consolidated revenue of more than $100 million to report on the risks of modern slavery in their operations and supply chains, and actions to address those risks
[13523] The Act had an effective date from 1 January 2019 and required reporting entities to prepare an annual modern slavery statement
[13523] This statement is prepared for the reporting period 1 January 2022 to 31 December 2022 (reporting period)
[14094] age | 2
[14094] Adapt IT Operations
[14094] Adapt IT Proprietary Limited has its headquarters in South Africa and a financial year-end of 31 December
[14094] The operations of Adapt IT are decentralized however certain processes and reporting obligations are managed centrally
[14094] The Governance, Compliance and Regulatory Risk (GCRR) function is part of Shared Services and was responsible for coordinating and compiling this statement
[14094] A consultation process with senior management within the divisions of Adapt IT was undertaken to draft this statement
[14094] Policies and processes that are substantially similar have been identified in this statement
[14094] Adapt IT group companies sell software and services to several industries, both in the public and private sectors
[4651] and competition laws that are designed to
[4651] foster fair and open competition
[4651] Holding our suppliers to the same high
[4651] standards we set for ourselves and
[4651] conducting thorough due diligence
[4651] to monitor our suppliers adherence to
[4651] those standards; and
[4651] Conduct our business legally and ethically
[11119] Document Classification: Confidential Modern Slavery Statement (Australia) SG Fleet Group Limited ABN 40 167 554 574 December 2022
[11119] Modern Slavery Statement (Australia)
[11119] Page 2 of 8 Document Classification: Confidential Modern Slavery Statement
[11119] Reporting entity
[11119] This statement is made pursuant to the Modern Slavery Act 2018 (Cth) by SG Fleet Group Limited (ABN 40 167 554 574) and its related entities (together, SG Fleet or the Company) for the financial year ending 30 June 2022
[11119] It outlines the approach and initiatives taken by the Company and its related entities to identify and address the risks of modern slavery in its operations and supply chain
[11119] The Company has consulted its related entities during the preparation of this statement
[11119] The statement relates to SG Fleet for the full 2022 financial year and to the acquired LeasePlan Australia Limited business (ABN 57 006 923 011 - see below) for the second half of the 2022 financial year
[13523] This is the first modern slavery statement for Victorian Correctional Infrastructure Partnership Pty Ltd (ACN 107 247 067) (the Company) as it met the consolidated revenue threshold during the reporting period
[13523] This statement outlines the commitment and approach of the Company towards tackling modern slavery throughout its supply chains and ensuring there is transparency in the business that it operates
[13523] Mandatory Criteria One & Two: Identify the reporting entity and describe its structure, operations and supply chains The Victorian Correctional Infrastructure Partnership is 100% held by BBGI Holding Limited, which is a UK incorporated company
[13523] In 2003, the Victorian Correctional Infrastructure Partnership Pty and the Victorian Government entered into the project agreement to design, construct and finance the development of remand and correctional facilities in Victoria and then to operate and maintain the facilities over a 25 year concession with the Victorian Department of Justice (the State)
[13523] The Company has the right to use land owned by the State for the construction of the remand and correctional facilities and then for the subsequent operating and maintenance of the facilities for the operating and maintenance period
[13523] Upon termination of the service concession agreement, the Company has the obligation to return to the State the Company's right to use the land it had previously been granted the right to use
[13523] In 2021 the Company and the State entered into an Augmentation Order to design and manufacture modular cells for the increased capacity at the remand and correctional facilities in Victoria
[13523] Whilst the Company itself does not have any employees, the Company procures goods and services from various suppliers to meet the delivery of services specified in the Project Deed
[14094] Adapt IT group companies have operations in Australia, including through Adapt IT Australasia (Pty) Ltd, a company registered in Australia
[14094] Adapt IT group companies deliver their software and services by grant of license, rights to use a service or through arrangements with third parties
[14094] Adapt IT group companies often rely on manufacturing partners to produce hardware-related components and hardware products
[14094] Supply chains DocuSign Envelope ID: 63EE6DFA-E119-47B0-B3A5-D47CF6AD66A6
[14094] age | 3
[14094] Adapt IT group companies each manage their own supply chain relevant to delivery of their software, hardware and related services
[14094] The operations of Adapt IT group companies require suppliers such as professional service providers, maintenance service providers, software developers, goods manufacturers and other software and technology providers
[4651] Avis Budget Group maintains a Workplace Health & Safety Policy and Global Safety Policy Statement which outlines the requirements for the management of workplace hazards and risks to as low as reasonably practicable to eliminate or reduce the incidence of personal injury, property damage and/or loss
[4651] Avis Budget Group maintains a Human Rights Policy & Statement which demonstrates our respect for fundamental human rights and supports global efforts to protect them
[4651] We strive to conduct our business in a manner consistent with the United Nations Guiding Principles on Business and Human Rights and the International Labour Organisations Fundamental Conventions
[4651] The Human Rights Policy upholds Avis Budget Groups Due Diligence Standard Operating Procedure and sets out Avis Budget Groups commitment to, among other things: (a) the prohibition of all forced labour; (b) the prohibition of all forms of child labour not
[4651] part of a government authorised job training; (c) compliance with all applicable wage and
[4651] hour laws and regulation, in particular those
[4651] relating to minimum wages, overtime
[4651] maximum hours and piece rates; (d) safe working environments for all employees
[11119] LeasePlan Australia Limited submitted a modern slavery statement relating to the 2021 calendar year on 30 May 2022
[11119] The statement has been approved by the Board of Directors of SG Fleet on 28 November 2022
[11119] Andrew Reitzer Chairman SG Fleet Group Limited
[11119] Structure, operations and supply chains of SG Fleet
[11119] Business Overview
[11119] SG Fleet is a leading provider of integrated mobility solutions, including fleet management, vehicle leasing and salary packaging services, with a presence across Australia, as well as in New Zealand and the United Kingdom
[11119] At the end of the 2022 financial year, the Company employed approximately 1,100 staff worldwide and had approximately 270,000 vehicles under management
[11119] During the reported period, SG Fleet operated under multiple brands across corporate and consumer business segments: sgfleet (operating in Australia, UK and New Zealand), nlc (Australia) and, for part of the reported period, LeasePlan (Australia and New Zealand)
[13523] The Companys most significant expenditure relate to construction costs, facilities management (FM) services; and other professionals services such as legal, tax, audit and technical consultancy
[13523] Mandatory Criteria Three: Describe the risks of modern slavery practices in the operations, supply chains of the reporting entity and any entities the reporting entity owns or controls The Company has reviewed the UN Guiding Principles on Business and Human Rights, which underpins the Act and conducted a review of its suppliers to assess (i) the sectors in which the suppliers operate (ii) the nature of the products and services provided by the suppliers (iii) geographic regions in which the suppliers operate and (iv) entity risks specific to the suppliers
[13523] The major risks of modern slavery within the Companys supply chain is sector specific, as its key suppliers are within the construction and facility management sectors, where the risks of modern slavery ensue from the sourcing of labour and materials
[13523] There has been longstanding demand for migrant, low skilled manual labour within the construction industry, thus making the industry more exposed to risks of debt bondage, coercion, and compulsory labour
[13523] Similarly, for FM services such as security and cleaning, price competition in the market often results in low skilled, migrant workers being employed for viability, which in turn could create pre-conditions for modern slavery-like practices
[13523] The FM and construction services procured by the Company are provided by Cushman & Wakefield (C&W) and Built Pty Ltd (Built) respectively
[13523] Both C&W and Built are large, reputable, multinational companies, which are also reporting entities under the Act
[13523] C&W has contracts with Australian companies for certain soft services, including the provision of security services, cleaning services and associated consumables
[14094] While some may be sourced from Australia, Adapt IT group companies have global supply chains
[14094] Adapt IT group companies work with vendors to understand and evaluate their supply chain
[14094] Management of Adapt IT group companies implement centralised and individual policies and procedures for oversight of these supply chains
[14094] Major supply chains include both local and international provision of
[14094] Cloud infrastructure and hosting services; ii
[14094] Third party software and components; iii
[14094] Software development services; iv
[14094] Manufacture and delivery of hardware
[4651] of a supplier or partner; and (e) encouraging partners and suppliers to
[4651] conduct self-evaluations to ensure that they
[4651] are along with their subcontractors
[4651] complying with our human rights standards
[4651] Modern Slavery Statement 2021 GOVERNANCE APPROACH The Third Party Standards of Conduct represent Avis Budget Groups commitment to foster sustainable relationships with our business partners, agents, consultants, suppliers and other third parties
[4651] These Standards ensure that all Third Parties uphold ethical standards and adhere to social and environmental responsibilities for the good of the communities that we serve and the promotion of human rights
[4651] Avis Budget Group expects that Third Parties, in all their activities, will comply with all applicable laws, rules and regulations of the countries and localities in which they operate, whether or not specifically referenced in these Standards
[4651] Avis Budget Groups expectations are set out as part of the vetting process when new suppliers are engaged
[11119] During the 2022 financial year, SG Fleet acquired the Australian and New Zealand businesses of international fleet management and leasing company LeasePlan Corporation NV
[11119] Under the acquisition agreement, use of the LeasePlan brand will be phased out over time
[11119] Use of the nlc brand will also be phased out during the 2023 financial year
[11119] Page 3 of 8 Document Classification: Confidential
[11119] The acquisition of the LeasePlan businesses did not materially alter the nature of SG Fleets business activities or its geographical footprint
[11119] SG Fleets services and activities for each jurisdiction are summarised in the table below
[11119] Australia United Kingdom New Zealand Provider of
[13523] These services are delivered in a market that is highly price competitive and largely dependent on low-skilled migrant labour engaged at award rates to be cost effective
[13523] This can contribute to an environment of vulnerable workers exposed to modern slavery risks
[13523] It is noted that post- COVID conditions are seeing a lack of migrant worker availability, with the scarcity of staff pushing wages up
[13523] C&W continues to closely observe the impact this has on the risk profile of this industry
[13523] Builts operations where labour is directly engaged are limited to Australia, New Zealand and UK businesses
[13523] As Builts labour engagement and management policies and practices are structured strictly in accordance with the relevant laws, the risk of Built directly causing modern slavery is considered low
[13523] Built acknowledges that given the diversity and depth of parts of its supply chain, it is links of this nature that are considered Builts most significant risk of exposure to modern slavery
[13523] In particular, the risks of modern slavery are most likely to arise from: 1) materials sourced from overseas regions at risk of modern slavery; and 2) local trades where unskilled or semi-skilled labour is sourced
[14094] Business process outsourcing; DocuSign Envelope ID: 63EE6DFA-E119-47B0-B3A5-D47CF6AD66A6
[14094] age | 4
[14094] vi
[14094] Consulting and professional advisory services; and vii
[14094] Call centre support
[14094] Risk mitigations
[14094] Adapt IT believes that all business affairs of the company must be conducted in compliance with all applicable laws, rules and regulations and in accordance with the highest standards of honesty, integrity and ethical behaviour in all jurisdictions in which the company operates
[4651] Avis Budget Groups Third Party Standards of Conduct form part of its agreements with suppliers
[4651] The Standards require Third Partys commitment to, among other things: (a) comply with all applicable local, national
[4651] and international laws, regulations
[4651] treaties and industry standards, including
[4651] without limitation, those pertaining to the
[4651] manufacture, pricing, sale and distribution
[4651] and safety of the relevant products and/or
[4651] services
[11119] passenger and commercial vehicle operating leases, finance leases and fleet management services for corporate and government customers
[11119] passenger vehicle novated leases and consumer finance for individuals
[11119] insurance products relating to leased and managed vehicles for corporate and government customers and for novated leases
[11119] disposal of passenger and commercial vehicles
[11119] other mobility solutions, including car share and subscription services
[11119] other vehicle- related services, such as mobility and EV consulting, Provider of
[11119] contract hire, finance lease, daily rental and fleet management services for passenger and commercial vehicles for corporate and government clients
[11119] vehicle salary sacrifice services for individuals
[13523] The residual services are rendered by professionals and are specialist in nature
[13523] Therefore, these services are of higher value in payments and constitute lower risks of modern slavery
[13523] Mandatory Criteria Four: Describe the actions taken by the reporting entity and any entities that the reporting entity owns or controls to assess and address these risks, including due diligence and remediation processes The Company has undertaken a risk-based approach in conducting its due diligence on the Companys key partners and suppliers to identify modern slavery risks
[13523] The Company has written to each identified higher risk supplier and requested copies of their relevant policies and the completion of the Annual Modern Slavery Questionnaire
[13523] C&W C&W developed and tested a Self-Assessment Questionnaire as a tool to review their suppliers policies and practices to identify, assess and mitigate modern slavery risks in their supply chains and operations
[13523] All new suppliers are required to agree to the Global Vendor/Supplier Integrity Policy as part of the supplier onboarding process, allowing C&Ws internal auditors to monitor, test and audit the suppliers' compliance with their contractual and modern slavery obligations
[13523] No deficiencies in respect of modern slavery practices were reported as a result of these audits and/or spot checks during the reporting period
[13523] A central part of C&Ws governance structure is the Modern Slavery Risk Committee which is responsible for further investigating potential or actual incidents of modern slavery within the Australian businesses, operations and supply chains
[14094] Adapt IT is committed to treating workers with respect and dignity by ensuring safe working conditions, sourcing responsibly and conducting transparent and ethical operations
[14094] To mitigate the risk of modern slavery in its operations and supply chain, Adapt IT has put the following measures in place
[14094] Governance framework: The Governance, Compliance and Regulatory Risk (GCRR) Department ensures high levels of good governance are maintained across the group
[14094] In the reporting period, the Compliance Due Diligence Policy has been updated to include provisions dealing with Modern Slavery risks
[14094] The company has developed other policies that support this policy, namely, the Anti-Bribery and Corruption Policy, the Code of Ethics and Conduct Policy and other related policies
[14094] ii
[14094] Supplier agreements: Adapt IT template agreements have been updated to include provisions dealing with modern slavery risks
[4651] (b) not use child labour unless it is part
[4651] of a government-authorized job training
[4651] or apprenticeship program and then only
[4651] in strict compliance with all applicable laws
[4651] and regulations
[4651] (c) comply with all applicable wage and hour
[4651] laws and regulations, including those
[11119] personal vehicle contract hire for individuals and sole traders
[11119] insurance products relating to salary sacrifice leases for individuals
[11119] other vehicle-related services, such as mobility and EV consulting Provider of
[11119] passenger and commercial vehicle operating and finance leases and fleet management services for corporate and government clients
[11119] other vehicle-related services, such as mobility and EV consulting
[13523] C&W is collaborating with Informed365 and The Property Council of Australia to strengthen its modern slavery platform
[13523] Built In this reporting period, Built engaged an independent specialist consultant to update the Modern Slavery Hot Spot Risk Analysis to ensure it is working with the latest data and information from global databases
[13523] Built identified its largest suppliers and contractors and issued them with Supplier Surveys which ask detailed questions on due diligence processes around supply chain slavery identification and redress
[13523] Key project tenders (>$25m) are evaluated for risk of modern slavery exposure
[13523] Built subscribed to the Equifax Ethical Supplier Screening platform to screen their top 200 suppliers by value spend, representing approximately 50% of its FY22 supply chain spend, with 2 supplier alerts relating specifically to activities relating to modern slavery
[13523] Builts supplier risk assessment includes Equifaxs vendor risk software which continuously monitors the suppliers for any new risks or issues that may arise, with automatic alerts
[13523] If there are areas for concern, the respondents are followed up directly for further detail and action
[13523] Mandatory Criteria Five: Describe how the reporting entity assesses the effectiveness of actions being taken to assess and address modern slavery risks The Companys higher risk suppliers are large, reputable, multinational suppliers who are reporting entities under the Act
[14094] age | 5
[14094] iii