mila-ai4h/AIMS.au huggingface dataset:
[14781] Though we have already engaged with our high risk suppliers, including our uniform providers, cleaning contractors and tele-marketers, we will continue to communicate our expectations that they take appropriate actions to address modern slavery risks in their own supply chain, for example through providing them our Due Diligence Checklist this year
[14781] We understand that this engagement will increase if New Zealand adopts Modern Slavery legislation
[14781] Continue to assist our lower risk key suppliers to ensure they are aware of our modern slavery commitments as well as build our awareness of key suppliers actions on modern slavery within their business
[14781] We have prepared a Modern Slavery Due Diligence Checklist for our key suppliers, including our high risk suppliers, to complete alongside our Supplier Code of Conduct
[14781] The Checklist includes questions such as: Does a particular supplier have their own Modern Slavery Policy? Is a supplier required to publish a Modern Slavery Statement every year under the Australian or United Kingdom legislation? How aware is a supplier of the upcoming Modern Slavery proposals in New Zealand? Where responses are unsatisfactory we will engage further with that supplier
[14781] Continue to communicate our procurement expectations to our suppliers
[8960] The policy also ensures that Worldline is dealing with Business Partners who follow high ethical standards as per the applicable rules and legislations
[8960] The Policy considers specific legal and regulatory requirements for sound management of business partners
[8960] More specifically, Worldline complies with applicable laws, regulations and international standards including but not limited to
[8960] Sapin II
[8960] Loi sur le devoir de vigilance 20172
[8960] EBA Guidelines on Outsourced Arrangements
[8960] UK Modern Slavery Act 2015
[8960] Under the French Duty of care legislation , companies that are in the scope of the law must establish and effectively implement a vigilance plan
[12318] This includes a small number of direct overseas supplies and second and third tier suppliers based overseas
[12318] The potential for risk has also been identified in certain industries from which we procure services such as transport
[12318] Coventrys Ethical Sourcing and Modern Slavery Policy and its associated procedure and supplier questionnaire sets out Coventrys requirements and expectations to its suppliers, wholesalers and agents, whether national or international, to comply with relevant laws, regulations, treaties, covenants or other agreements, such as International Labour Organisation (ILO) standards
[12318] While Coventry has not identified any incidents or material risks of modern slavery in its supply chain, it takes its responsibilities and obligations seriously
[12318] Coventry will continue to refine and strengthen its supply chain policies and processes, refine and improve staff risk management training and continue to conduct its annual Supplier Assurance of Ethical Sourcing of Labour audit of suppliers depending on risk profile
[12318] Assessing effectiveness of actions
[12318] The oversight of Modern Slavery risk assessment, management and control at Coventry has been delegated by the Board to the Coventry Leadership Team
[12318] This team reports to the Board on a regular basis through the Managing Director
[14781] We have circulated our Procurement Policy around our business for internal use
[14781] The Procurement Policy prescribes the process for engaging new suppliers, conducting supplier due diligence, establishing supply arrangements, and executing supply contracts
[14781] The Procurement Policy provides that only suppliers that have demonstrated their ability to comply with the Supplier Code of Conduct will be engaged
[14781] We will include appropriate contractual clauses in supplier contracts regarding obligations to manage and notify regarding modern slavery risks
[14781] Continue to provide further tailored training on modern slavery risks to all employees of the Group
[14781] We are currently preparing an online training module for all staff on our internal management system
[14781] We are fully committed to understanding, preparing for, and promoting awareness of, the current New Zealand Modern Slavery legislative proposals, most recently outlined by the Minister for Workplace Relations and Safety in July 2023
[14781] Consultation
[8960] The plan should allow for risk identification and the prevention of severe violations of Human rights and harm to the environment resulting from three kind of activities: (i) the activities of the company itself, (ii) the activities of companies under its control and (iii) the activities of the subcontractors or suppliers with whom it maintains an established commercial relationship
[8960] Australia Modern Slavery Act 2018
[8960] Foreign Corrupt Practices Act of 1977 (FCPA)
[8960] UK Bribery Act 2010
[8960] Transparency in Supply Chains Act 2012
[8960] Supply chain standards
[8960] Business Partners Commitment to integrity charter Worldline shares its values and commitments with its suppliers and partners through a bespoke document, the Business Partners Commitment to Integrity Charter, which forms part of and is appended to all supplier contracts and is available on Worldlines website
[8960] This charter summarises the principles with which all Worldline partners and suppliers should comply, and the actions that our suppliers are required to take, in order to be able to work with Worldline
[12318] Coventry has a supplier audit system in place to oversee its international suppliers (predominantly in North America and Asia) which includes strong relationship management, annual site visits (completed virtually during 2021-2022 due to COVID risk and lockdowns) and training
[12318] During 2022, Coventry conducted ethical sourcing audits of their top 15 suppliers from each of its businesses for its local suppliers, which equates to 90% of its total spend of locally based companies
[12318] Coventry is aware that some of these companies source their products from international suppliers and mitigates these risks through an understanding of each suppliers visibility of their own supply chain, whether it be high, moderate or developing
[12318] Approval
[12318] This Modern Slavery Statement was approved by the Board of Coventry Group Ltd on 24 February, 2023
[12318] Yours faithfully
[12318] Robert Bulluss CEO and Managing Director Coventry Group Ltd
[14781] The Group has consulted with all subsidiary entities described above in the preparation of this statement including by discussing modern slavery risks with the Group Leadership Team
[14781] This statement applies to the financial year ended 31 March 2023
[14781] This statement was approved by the Groups Board of Directors on 27 September 2023
[14781] Grant Baker Chairman
[8960] It also encourages suppliers to follow the principles of the United Nations Global Compact in the areas of human rights, labour, environmental preservation and anti-corruption
[8960] The charter explicitly refers to Modern Slavery: Modern slavery is a crime and a violation of fundamental human rights
[8960] It can take various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of individuals liberty in order to exploit them for personal or commercial gain
[8960] Worldline expects its Business Partners to act ethically and with integrity in all their business dealings and relationships and to implement and enforce effective controls to ensure modern slavery is not practiced in their businesses and supply chains
[8960] Responsible Sourcing of Minerals We have assessed that there is a risk that some of the hardware suppliers (for terminals and data centre components for instance) could source minerals for components manufactured from conflict regions
[8960] Worldline is committed to ensuring that the smelters from which our suppliers buy the minerals are not likely to source from mines in conflict regions (in compliance with the Responsible Minerals Initiative RMI)
[8960] In this respect, the Company supports the efforts of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas
[8960] Worldline also commits to the Responsible Minerals Initiative and, to this end, an open letter addressed to Worldline suppliers has been signed by Worldline SAs Corporate Social Responsibility Officer and is published on the Worldline website in 2020
[8960] The letter requires suppliers to ensure that their supply chain is conflict-free
[8960] In addition, Worldline requests all its suppliers to report on the origin of their conflict minerals
[8960] Worldlines CSR programme includes a KPI, demonstrating the percentage of concerned suppliers (sourcing minerals) that report on the origin of the source of their conflict minerals (3TG)
[8960] In 2021 it concerns 97% of the suppliers
[8960] If the suppliers are sourcing from a non- compliant smelter (RMI classification), they are required to set up an action plan to correct this
[8960] Corporate Social Responsibility clause In 2021, Worldline introduced a Procurement Contract Policy that provides clauses to be used by buyers during contract negotiation covering CSR, security, audit rights, data protection, and EBA guidelines
[8960] The CSR clause, to be systematically added in all contracts, compels the partner to align with the Business partners commitment to integrity charter and Worldlines Code of Ethics, and may require a minimum of extra-financial ratings to be provided within the first year of contract with Worldline
[8960] The clause also stipulates that the Company reserves the right to conduct a CSR-related audit at its suppliers
[8960] Worldline General Purchasing Terms and Conditions also includes this same CSR clause
[8960] For the particular case of components suppliers, CSR topics are already included within the scope of audits conducted by the Worldline Quality teams
[8960] Due Diligence and Audits in our Supply Chain Risk classification
[8960] In order to manage the supplier database more efficiently and enable us to take appropriate actions, we assess our tier 1 suppliers and classify them into three different operational categories
[8960] Strategic: long-term supplier matching at least one of the following criteria: high spend, non-substitutability, specific technology involved, specific risks related to services
[8960] Monitored: supplier that is not strategic but can represent a risk for Worldline (supplier entity risk related to compliance/CSR or engagement risk related to security, etc.)
[8960] Standard: other suppliers not falling within the scope of other categories
[8960] This classification is set by the buyer responsible for the supplier during the on-boarding and is reviewed annually
[8960] It enables the procurement team to follow different steps depending on the status of the supplier
[8960] It is the basis of the sustainable procurement initiative which targets primarily strategic and critical suppliers for Worldline
[8960] Supply chain due diligence describes the efforts taken to investigate a potential supplier and regularly assess existing suppliers
[8960] Its objective is to discover any corruption / ethical / human rights abuse / extra-financial risks associated with the potential or existing supplier in order to ensure integrity within the supply chain
[8960] Due diligence on suppliers is initiated from the on-boarding phase with a thorough screening (financial and non-financial) and checking that assesses supplier risks
[8960] Follow-ups are organised according to the level of risk identified
[8960] EcoVadis assessment is triggered for strategic suppliers in order to more closely monitor their CSR performance
[8960] For more information regarding the supplier risk assessment and due diligence, please refer to Worldline Universal Registration Document, section D.4.6 In order to assess the CSR practices and mitigate the risks of our key suppliers (Strategic and Monitored), we have implemented our own EcoVadis supply chain platform, inviting our key suppliers (tier 1) to be assessed by EcoVadis and share their scorecard in our platform
[8960] In 2021, 84 different suppliers (at parent company level) were assessed by EcoVadis in the Worldline platform, representing 74% of the Strategic suppliers and 86% of the total spending of these Strategic suppliers
[8960] The average score of Worldline suppliers assessed was 61.7/100, above the average score of all companies assessed by EcoVadis globally
[8960] % of Worldlines suppliers evaluated by EcoVadis with a score below 45 (7 suppliers) had an action plan to solve critical findings identified
[8960] Training and Awareness As ethics is one of the foundations of its business model, Worldline has established a mandatory annual training programme for all Worldline employees, addressing topics such as the Code of Ethics
[8960] Following the acquisition of Ingenico, a specific deployment took place to train the extended workforce
[8960] This eLearning is updated regularly to reflect any significant changes to the Code
[8960] In 2021, 94.7 % employees have been trained to the Code of Ethics in a E-learning format
[8960] Closing Statement Worldline is globally recognised as a sector leader for its Corporate Social Responsibility programme
[8960] We understand that slavery and human trafficking risks may pose a threat to international firms and are constantly evolving in the current global environment
[8960] For this reason, each of the measures and policies described in this statement shall continue to be applied on an ongoing basis
[8960] This statement constitutes our Group's slavery and human trafficking statement for the period between the 1st of January 2021 up to and including the 31st of December 2021 pursuant to the United Kingdom Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018
[8960] This statement is made by Worldline SA on its own behalf and on behalf of its subsidiaries to whom the Modern Slavery Acts apply and whose boards have approved this statement being Worldline IT Services UK Limited, Worldline SA, Worldline S.A./N.V., equensWorldline SE, Worldline Sweden AB, Worldline Retail Enterprise (UK) Limited, Ingenico (UK) Limited and Ingenico International (Pacific) Pty Limited
[8960] Management of the above-mentioned entities have been consulted in the preparation of the present statement
[8960] The statement has been validated by all the above-mentioned entities The Board of Worldline SA has approved this statement on June 9, 2022
[8960] Signed
[8960] __________________ Gilles Grapinet CEO June 2022