mila-ai4h/AIMS.au huggingface dataset:
[12563] In the 2022 financial year, ASG engaged directly with around 400 suppliers from six countries, including Denmark, the United Kingdom, Philippines, Singapore and the United States of America
[12563] The supply chain of products and services that contribute to our operations include assembling products from overseas factories and importation of certain products
[12563] Some of our existing suppliers do have clauses in their contracts, which addresses some aspects of modern-day slavery requirements
[12563] The percentage of this is unknown without conducting due diligence with our existing suppliers
[12563] An assessment will be carried out to determine which suppliers are compliant and those who are non-compliant, we will work with them to ensure they meet the standards needed
[12563] When new suppliers are on-boarded the newly on-boarded supplier is provided with the ASG Supplier Code of Conduct, the Code of Conduct relates to a number of Government standards/statements, we ask that the Supplier review the Code of Conduct, by signing, the Supplier acknowledges they understand and adhere to Australian Government requirements Modern Slavery, Bribery & Corruption, etc
[13978] It was last updated in September 2022
[13978] iv
[13978] Global Procurement Policy The objective of the Procurement Policy is to offer an efficient, informative and standardised approach to how the Group manages suppliers across the procurement lifecycle - from how we seek out new suppliers to tendering, selecting, contracting and managing the associated third- party risk(s) through to exit
[13978] The Policy ensures common minimum standards are applied through the lifecycle of an agreement with a supplier, as suppliers are required to adhere to our key policies, including the Supplier Code of Conduct (see below) and the Entain Code of Conduct
[13978] The Policy specifies that appropriate due diligence and risk management is conducted, amongst other requirements
[13978] The Policy is reviewed annually and was last updated in January 2023
[13978] Failure to pay supplier invoices on time can lead to increased pressure on suppliers leading to
[13978] a higher risk of modern slavery in our supplier chains
[2405] MO Investments holds only a small number of investments in Australian start-up companies
[2405] There are approximately 22 suppliers in our tier 1 list that we are still in the process of confirming the geographic location for
[2405] Of the remaining suppliers, all are located in Australia
[2405] For our major suppliers we have a scheduled service delivery meeting ordinarily on an annual basis
[2405] Risks of Modern Slavery
[2405] Mills Oakley is aware that because of the prevalence of Modern Slavery, in particular in the Asia-Pacific region, every entity has risks of Modern Slavery in its operations and supply chains
[2405] Mills Oakley acknowledges that understanding where the risks of Modern Slavery are in our operations and supply chains is a crucial step towards taking effective and accurate action in response to those risks
[2405] We have carefully considered the United Nations Guiding Principles on Business and Human Rights so as to gain a deeper appreciation of how an entity like ours can cause, contribute to, or become directly linked to Modern Slavery
[10579] Risks of Modern Slavery within Hillebrand Gori Operations and Supply Chains As Hillebrand Gori operates within the global logistics industry there is a real risk that we unnoticed and unknowingly may cause, contribute to, or be directly linked to potential modern slavery practices within our operations and supply chain
[10579] Hillebrand Goris analysis of its extended supply chain is in its early stages
[10579] However potential risk areas in the extended supply chain include but are not limited to
[10579] Electronics and IT hardware: the electronics industry is recognised as a high-risk industry for modern slavery and similar mistreatment
[10579] Manufacturing often occurs in locations with minimal regulation and oversight
[10579] There is also a risk that products are manufactured from raw materials, where production involved workers being subjected to modern slavery
[10579] Uniforms and apparel: apparel is often manufactured in high risk countries, and there have been reports of forced labour in the apparel industry in South East Asia
[10579] Our supply chain Our supply chain
[12563] The signed Code of Conduct is then attached within our Supplier/Vendor Database and noted as received
[12563] OUR SUPPLY CHAIN
[12563] RISK OF MODERN SLAVERY PRACTICES IN ASGS OPERATIONS AND SUPPLY CHAINS 5 w w w
[12563] a u As ASG is a services based business, we do not manufacture any products, however occasionally ASG does directly procure products for its clients including IT hardware (such as laptops and monitors etc.), however these products are sourced through the suppliers Australian operations
[12563] ASGs IT hardware is procured from Tier one industry providers
[12563] This significantly lessons the risk of purchasing from countries where slavery may be taking place as worldwide Tier one supplier MUST adhere to modern slavery laws
[12563] As discussed above, ASGs supply chain is made up of approximately 400 contracted suppliers across six countries
[12563] Our supply chain includes suppliers of the following goods and services: IT equipment, hardware, software, cleaning contractors for offices and office supplies etc
[13978] We therefore strive to ensure the timely payment of suppliers in line with the terms of the Procurement Policy
[13978] Global No PO, No Pay Policy We operate a No PO (Purchase Order), No Pay Policy that is referenced in our Procurement Policy and widely communicated across the Group
[13978] This ensures all suppliers are vetted, which ensures that the right due diligence is being undertaken to mitigate, amongst other things, risks related to Modern Slavery
[13978] The Policy is reviewed annually and was last updated in February 2023
[13978] vi
[13978] Global Supplier Code of Conduct The Supplier Code of Conduct sets out the social, ethical and environmental standards that Entain expects from everyone who does business with us as a supplier or business partner anywhere in the world
[13978] Any new supplier must read and agree to the Supplier Code of Conduct prior to their onboarding with Entain
[13978] It includes the 10 guiding principles set out in the Entain Code of Conduct and requires suppliers to comply with all applicable laws, regulations and codes of practice, including human rights and employment laws
[2405] Mills Oakley Lawyers MO Investments MO Pty Ltd
[2405] Our operations primarily involve the provision of legal services and therefore we consider them to be lower risk
[2405] Lawyers are subject to stringent rules around ethics and conduct and furthermore our industry is closely regulated
[2405] We consider that this lowers the risk of Modern Slavery practices within our operations
[2405] We have only 5 premises on which our employees work and all employees are contracted to work regular business hours
[2405] This allows greater visibility over our workforce and the safety of our employees
[2405] Amongst other practice areas, Mills Oakley provides expert advice in the areas of workplace relations, employment, safety and Modern Slavery and are acutely aware of the laws, regulations and best practices in this area
[2405] We apply the same expertise that our clients receive to our own operations and in dealings with our own employees
[10579] We are reliant upon third party organisations in two key areas of our operations
[10579] Transportation of beverages from source (normally outside Australia) to Australia and onward delivery of these goods to our customer-base nationwide
[10579] With these third-party organisations, we have, or plan to have, systems and protocols in place to identify and mitigate risk
[10579] These include
[10579] Ensuring that our critical suppliers adhere to our Code of Conduct which includes statements from them confirming that they abide by the Modern Slavery Act
[10579] Methodically working through our existing supply-base to
[10579] Identify and engage higher risk and higher volume suppliers to convey our Anti-Slavery policy to gain written assurance from them that they abide by our Code of Conduct
[10579] Our commitment is to have these undertakings in place by the end of 2023
[12563] As discussed above, ASG also has an office located in Manila in the Philippines
[12563] The Philippines is identified as a higher-risk country under the OECD Guidelines for Multinational Enterprises and the Modern Slavery Index published by the Walk Free Foundation
[12563] In managing our Manila office, ASG seeks to comply with all laws and regulations of the Philippines
[12563] As discussed above, ASG also has an office located in Gurugram in India
[12563] India is also identified as a higher-risk country under the OECD Guidelines for Multinational Enterprises and the Modern Slavery Index published by the Walk Free Foundation
[12563] In managing our Indian office, ASG seeks to comply with all laws and regulations of India
[12563] ASG has supplier relationships with companies in the United States, Denmark, UK, Hong Kong, Philippines and Singapore
[12563] ASGs suppliers are larger organisations, and for this reason, ASG considers that the risks of modern slavery are likely beyond the first tier of ASGs supply chains, where ASGs suppliers may outsource some tasks and work, including for example, manufacturing and development of the products/services may be outsourced by ASGs suppliers to high risk countries overseas, which may increase the risk of exploited labour
[13978] Any potential breaches must be notified to Entain promptly and suppliers are able to use a confidential whistleblowing email address to raise concerns
[13978] The Code sets out the minimum labour standards Entain expects from all our suppliers
[13978] It explicitly states that suppliers must
[13978] not use child labour either directly or in their supply chain and ensure they have adequate procedures and measures in place to prevent this
[13978] not use forced labour
[13978] ensure workers have the freedom to terminate their employment contract without unlawful penalty
[13978] pay their workers at least the legal national minimum wage and provide workers with clear payroll statements
[13978] provide benefits to workers that meet legal minimum standards and not unfairly deduct any benefits from their wages
[2405] We consider the application of this knowledge to our own operations to further decrease the risks of Modern Slavery occurring within same
[2405] Given our structure as a national partnership, we operate in a decentralised procurement model which means that processes, relationships and timeframes involved in procurements can vary
[2405] We understand this dispersal of oversight may increase the risk of Modern Slavery
[2405] However, while oversight is decentralised, we do conduct scheduled service delivery meetings with our contracted suppliers and carefully monitor performance and any issues arising from these relationships
[2405] Most of our contracts are longer-term stable contracts and due to the lengths of the contracts and the nature of our operations we dont often place particularly short delivery timeframes on our suppliers
[2405] Tier 1 of the MO Entities supply chain is made up of approximately 200 suppliers which for entities of our size we consider to be a relatively small cohort
[2405] As such, our visibility over these suppliers is increased and the risk of Modern Slavery is reduced somewhat
[2405] We note also that the contents of our tier 1 supply chain are not overly diverse
[10579] b) Work through the remaining suppliers, whether low risk or low volume, to ensure that by the end of 2023 all suppliers have been confirmed as confirming to our Code of Conduct
[10579] c) Protecting any whistle-blowers internal or external to our company
[10579] d) Putting in to place a rolling programme of review and spot-checking of all suppliers
[10579] Actions taken by Hillebrand Gori to assess and address risks We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business
[10579] In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free we have reviewed our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues
[10579] Our workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains
[10579] As part of our initiative to identify and mitigate risks, we have in place systems to
[10579] Identify and assess potential risk areas in our supply chains
[12563] That said, ASG procures products from Tier one industry providers, it is not likely that these Tier one providers outsource manufacturing to countries where there is a risk of exploited labour
[12563] ACTIONS ASG TAKES TO ASSESS AND ADDRESS THESE RISKS 6 w w w
[12563] a u We are committed to a process of upholding practices against modern slavery or human trafficking in our supply chains or in any part of our business
[12563] We commit to acting ethically and with integrity in all of our business relationships
[12563] Our commitment is also supported by policies and procedures which ensures responsibility and accountability for improving business practices and eliminating modern slavery in supply chains at all levels of our business
[12563] OUR CODE OF CONDUCT AND POLICY FRAMEWORK The board has the responsibility for establishing policies and ensuring that these are implemented
[12563] The board delegates this responsibility to the leadership and management teams within ASG
[12563] With regards to modern day slavery and our employees, we will need to determine what the best approach will be to create awareness of the signs of modern-day slavery for our employees
[13978] ensure workers do not exceed the maximum number of hours worked as set by local law
[13978] not unreasonably restrict workers freedom of movement
[13978] value diversity and protect the health, safety and wellbeing of their workers; and
[13978] respect the rights of workers to exercise free association
[13978] The Supplier Code of Conduct is reviewed annually and was last updated in October 2022
[13978] vii
[13978] Global Speak Out Policy (Whistleblowing) The Speak Out Policy encourages people to speak out about any behaviour that might be illegal, unethical or that breaches our Code of Conduct
[13978] The Policy specifically lists Modern Slavery issues (including paying fees to obtain jobs at Entain, poor labour practices or poor working conditions) as an example of the sort of issues that can be reported
[2405] Many of our 200 direct suppliers provide the exact same types of goods and services to Mills Oakley being solely those items necessary for the provision of professional services
[2405] Though we understand the risk with each supplier is unique, we believe having a smaller range of goods and services is helpful in increasing our visibility over potential risks to an extent
[2405] We have identified the following suppliers as posing a higher risk of Modern Slavery, due to the particular category of goods or services that they supply: information and technology, office fit-outs, recruitment, stationary, cab services, milk suppliers, coffee suppliers, catering services, security services and maintenance services
[2405] We acknowledge that lack of visibility is a high risk itself
[2405] As such, until such time as we can conclusively confirm the location of these 22 suppliers, we will consider them to be higher risk
[2405] Of the remaining suppliers, all are located in Australia aside and as such all considered to be low risk
[2405] Of the 22 suppliers that we are yet to place, 5 of them supply higher risk goods or services
[10579] Through a due diligence process where our supplier's information and processes are checked on a yearly basis mitigate the risk of slavery and human trafficking occurring in our supply chains, through working with ethical suppliers and sub-contractors
[10579] Protect whistle-blowers
[10579] Employee Code of Conduct Deutsche Post DHLs Code of Conduct reflects Hillebrand Goris corporate values Respect & Results
[10579] The rules and standards outlined in the Code serve as an ethical compass that guides all employees worldwide in their day-to-day work
[10579] There is no alternative to conducting our business in a responsible, fair and ethically irreproachable way
[10579] The Group Board of Management endorses the values outlined in the Deutsche Post DHLs Code of Conduct and expects all employees, executives and managers to be role models in their daily work and to contribute to a corporate culture characterized by respect Code of Conduct and Supplier Code of Conduct training is provided to employees on a bi-annual
[10579] The Code of Conduct is binding for all regions and business units of the Hillebrand Gori group
[10579] Freedom of Association and Collective Bargaining We respect our employees right to join or not to join a trade union or employee representation of their choice, free from threat or intimidation
[12563] ASGs Code of Conduct and Policy Framework set the behavioural standards for ASG employees, board members, contractors and consultants
[12563] The Code of Conduct and policy framework helps set a consistent global approach for all ASG employees
[12563] At ASG, our values underpin our everyday actions and we use them as a guiding principle in our conduct and working relationships
[12563] ASGs values are initiative, accountability and grit
[12563] Policies and Procedures are reviewed every year to ensure they align and comply with all the relevant regulatory requirements
[12563] a u At ASG, we have several policies and procedures which support a zero-tolerance approach to modern day slavery in our business, including primarily ASGs Code of Conduct which sets out our expectations of all employees of ASG and expectations in respect of dealings with clients, suppliers and contractors
[12563] All employees are expected to act in a manner consistent with the principles of: (a) integrity and fairness; (b) acting honestly, co-operatively and being trustworthy; (c) taking responsibility for our own actions and being
[12563] accountable for the consequences; (d) respect for others; and (e) compliance with the law and regulatory bodies guidelines
[13978] It confirms that reports can be made in relation to third-party suppliers
[13978] Concerns can be raised to a line manager or HR, Entains secure, confidential mailbox or our independent Speak Out hotline (which is also available to suppliers and is included in the Supplier
[13978] Code of Conduct)
[13978] Reports can be made to the hotline confidentially (and anonymously if desired) 24 hours a day, seven days a week
[13978] The Speak Out Policy is reviewed annually and approved by the Audit Committee
[13978] It was last updated in July 2022
[13978] Accessing and communicating Entain policies Our policies are available through the Group intranet platform which all Australian employees have access to
[13978] Our Code of Conduct and other key policies (including our Anti-Bribery and Corruption Policy) are part of our induction programmes, with all new employees receiving access to these policies before they start working at Entain
[2405] We consider this focus group to be our focus group as a result of our risk assessment
[2405] We also understand that our risk assessment may drastically change as we peer deeper into our supply chains
[2405] We undertake to further understand the subsequent layers of our supply chains in future reporting periods
[2405] Mills Oakley is not aware of any actual incidents of Modern Slavery cases that it has caused, contributed to or been directly linked to
[2405] We are aware that fully understanding our position in this regard is a complex
[2405] and challenging exercise and we endeavour to continue to search for more risks and information to further assure ourselves of this position
[2405] We are fully aware that absence of evidence is not always evidence of absence
[10579] We recognize and respect the right to collective bargaining in accordance with applicable local law
[10579] Employees who act as representatives are neither disadvantaged nor favoured in any way
[10579] Working Conditions Remuneration and benefits We compensate our employees relative to local industry and labour market and minimum wage legislation and in accordance with terms of applicable collective bargaining agreements, where they exist
[10579] We pay workers in a timely manner and clearly convey the basis on which workers are being paid
[10579] Working hours We comply with all applicable local laws regarding working hours including overtime, rest breaks and paid vacation
[10579] Health & Safety The safety, health and well-being of our employees is of utmost importance
[10579] In adherence to the Deutsche Post DHL Occupational Health and Safety policy, statutory regulations and industry standards, we provide a work environment that is safe and conducive to good health, in order to preserve the health of employees, safeguard third parties and prevent accidents, injuries and work- related illnesses
[10579] Compliance and conduct At Hillebrand, we are committed to having an environment where open, honest communication is a principle, not an exception
[12563] We see ourselves as being modern day advocates in our Industry and understand the role we play in setting an example
[12563] While the globalisation of supply chains and opportunities created in the workforce for women have increased, women remain at risk of human rights abuses
[12563] At ASG, we were proud to have implemented a domestic violence policy in support of women in our organisation
[12563] We strongly encourage and support diversity across all levels of our business to improve business performance, encourage innovation, attract and retain the best talent and provide excellent customer outcomes
[12563] Our Diversity Policy sets out our fundamental principles and diversity initiatives across the organisation
[12563] We have a recruitment policy to ensure all recruitment decisions are in line with our values and are consistently and fairly applied
[12563] All staff members are responsible for being aware of the policies whether they are ethical, legal or policy and need to ensure they apply it to their jobs
[12563] Our Managers and Executives are responsible for creating and promoting environments in which we comply and ensure ethical business is conducted
[13978] This ensures they are aware of our required standards before they start working at Entain
[13978] Updates to key policies are also supported by communications across a variety of channels to raise awareness
[13978] Entain takes breaches of our Code of Conduct, policies and procedures very seriously and will investigate and take action against colleagues as appropriate
[13978] Failure to adhere to our Code of Conduct may result in colleagues being disciplined which could lead to sanctions, up to and including dismissal
[13978] Supplier or partner contracts may be terminated in the event of a breach of the Supplier Code of Conduct; however, we will always try to resolve issues collaboratively in the first instance
[13978] We recognise that suppliers who have failed to meet our required standards will often have done so inadvertently, so we make every effort to ensure a safe environment for suppliers and their workers to speak up about any concerns
[13978] Training The Code of Conduct and key policies are also supported through an effective training programme
[13978] As part of this, employees are required to complete our Code of Conduct training which includes sections on Modern Slavery, on induction for new employees and as a refresher each year
[2405] Mills Oakley acknowledges the impact that the COVID-19 Pandemic has had on Modern Slavery risks