mila-ai4h/AIMS.au huggingface dataset:
[2405] We have carefully considered how the pandemic may have increased the vulnerability of workers in our operations and supply chains
[2405] For example, we know the production of rubber gloves and other PPE have been linked to the use of Modern Slavery practices
[2405] Whilst we have been able to utilise work from home and other avenues in our COVID-19 response and have not required large quantities of PPE in our operations, we understand that our cleaners and other suppliers that we work with have had to increase their usage of same
[2405] We know that the sudden, unprecedented changes have likely placed great pressure on a number of businesses and that any such pressures may expose vulnerable workers to exploitation
[2405] We understand that the uncertainty and affects of the pandemic are ongoing
[2405] Actions to Assess and Address Risks
[2405] Mills Oakley is making a concerted effort to identify, prevent, mitigate and account for how it addresses Modern Slavery risks
[10579] We want our people to feel comfortable about approaching their supervisor or management team in instances where they believe violations of our policies or ethical standards have occurred
[10579] In situations where our employees may not feel comfortable about
[10579] speaking to these persons, they can turn to our whistleblowing platform which is managed by an independent third-party expert
[10579] The platform facilitates confidential and anonymous reporting of concerns via an online form or telephone hotline, both of which are available in multiple local languages
[10579] Diversity and Inclusion Connecting the world through international trade is at the heart of our business, and we believe that differences in culture, gender, ability and perspective make us stronger as a company and as a global community
[10579] We strive to attract and retain talented people whilst broadening the diversity of our company at all levels
[10579] Diversity within Hillebrand Gori is visible in our gender equality and multiculturalism, with over 55 nationalities represented
[10579] This diversity helps us better understand each other, our customers and their expectations
[12563] All of our policies and procedures can be found internally on our intranet via the Business Management System and are communicated to all employees
[12563] a u ASG expects its suppliers to maintain the highest standards of business ethics and become familiar with and comply with all laws that are relevant to the supplier relationship, including the laws that govern ASG
[12563] ASG has Supplier Code of Conduct, which identifies that suppliers have responsibilities to ensure various standards are met by the supplier, including in respect of modern slavery, human rights and labour practices, diversity and inclusion and work health and safety matters, to ensure that suppliers prevent and detect any unlawful conduct
[12563] The Supplier Code of Conduct also enables ASG to audit any of its suppliers to ensure the supplier is abiding by and appropriately managing each of the standards identified within the Supplier Code of Conduct, and to ensure the supplier is complying with all applicable laws and regulations
[12563] Each new supplier of ASG will be required to acknowledge and sign the Supplier Code of Conduct to ensure they understand the expectations and obligations owed to ASG
[12563] a u We do our utmost to act with integrity, honesty, trust, respect and fairness
[12563] If employees are aware of any violation of the law or company rules, including any modern slavery practices, we encourage employees to contact NRIs Global Whistleblowing hotline immediately
[12563] The hotline is managed by an independent firm and all reports made are anonymously, treated in the strictest of confidence and investigated as required by an appointed third party
[13978] Employees are required to attest to having read the Code of Conduct as part of this training
[13978] This module raises awareness of this important issue and covers how colleagues can confidentially raise concerns through our whistleblowing process or the usual grievance routes
[13978] Colleagues are reminded that they are fully supported to raise legitimate concerns and will never be penalised for reporting something which they genuinely believe to be wrong
[13978] In 2022 Modern Slavery training was incorporated into The Big Six mandatory training programme which all employees are required to complete annually, which covers ethical topics such as safer gambling, data privacy and anti-bribery
[13978] Recruitment and onboarding of staff Our Recruitment Policy sets out our aim to attract a diverse workforce of people who are passionate about what they do, reflect our values, and simply want to do their best
[13978] We recruit, promote and reward people on merit
[13978] We always operate in a legal and ethical manner with our recruitment practices and ensure an individuals legal right to work within the given country is checked; appropriate references are received; and suitable identity documentation is available to the candidate (ie, they have access to their passport or other similar legal document in their name and it is not held by anyone other than the employee)
[13978] For some roles (eg senior or specialist roles), identity confirmation checks are also carried out
[2405] Our desire is to take meaningful action in this space and as such we have adopted a continuous improvement approach and will ensure that the quantity of action taken does not become priority over the quality of action at any point in time
[2405] This approach is consistent with the United Nations Guiding Principles on Business and Human Rights
[2405] Our Operations Lawyers are subject to stringent rules around ethics and conduct, and furthermore, our profession is closely regulated
[2405] We also comply with all Australian workplace laws including the Fair Work Act 2009 (Cth) with the guidance of our workplace relations, employment and safety specialists and experts
[2405] All of our employees are provided with employment contracts detailing the conditions of their employment and their various rights and obligations
[2405] Policies and Procedures Mills Oakley has created a specific Modern Slavery Policy (the Policy) which will be applicable to all staff and outlines the firms commitment to detect, assess, address and report on the risks of slavery or human trafficking within the Firms operations and supply chains
[2405] We understand that staff play a key role in our due diligence
[2405] This Policy details to staff the various pieces of legislation and guiding material that the firm expects all staff to comply with including: (a) Fair Work Act 2009 (Cth); (b) Modern Slavery Act 2018 (Cth); (c) Modern Slavery Act 2018 (NSW); (d) Australian Criminal Code Act 1995 (Cth), specifically, Division 270 or 271 of the Criminal Code, extending to conduct in and outside of Australia; (e) Guiding Principles on Business and Human Rights: Implementing the United Nations Protect, Respect and Remedy Framework; (f) Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children; and
[10579] Our deeper awareness of customers needs and pain points enables us to provide excellent customer service
[10579] We promote an inclusive work environment that values the diversity of our employees as confirmed in the Deutsche Post DHL Diversity and Inclusion Statement
[10579] We are committed to equal opportunity and reject any forms of discrimination or harassment based on gender, ethnic origin, nationality, social origin, religion, age, disability, sexual orientation and identity or any other characteristics protected by applicable law
[10579] The basis for employee selection and promotion at Deutsche Post DHL Group is qualification, performance, skills and experience
[10579] Consultation Between Entities Hillebrand Gori adopted a cross-functional approach to risk analysis and business input in the preparation of this Statement
[10579] This statement was prepared jointly by the Hillebrand Gori Legal , Human Resources and Operations functions with each entity involved in reviewing the Statement and contributing to its preparation
[10579] The Area Director of Oceania then reviewed and approved the Statement
[10579] This statement was approved by the principal governing body of Hillebrand Gori Australia Pty Ltd on 14 February 2023
[12563] We are committed to ensuring that our employees can raise concerns without fear of retaliation or negative consequences
[12563] ASG also has a Grievance Procedure in place, which enables employees to raise concerns about any issues in the workplace and our operations, including in relation to modern slavery practices
[12563] ASG is committed to transparency, corporate governance and accountability
[12563] ASG has a Risk Committee who are responsible for the effective oversight of all key risk and compliance issues, the overall control environment and the review and recommendation to the board for approval of ASG Risk Management policies
[12563] NRI AU operates an internal audit team which ensures that the processes and appropriate internal controls are in place at ASG
[12563] We uphold our responsibility as being environmentally friendly as well
[12563] We view this as essential for the long-term performance and sustainability of our company
[12563] We are currently certified to the latest version of the standard ISO14001:2015, which demonstrates our commitment to being environmentally responsible by preventing pollution, reducing waste and use of energy and resources
[13978] Our Anti-Slavery Obligations All Entain colleagues, particularly those responsible for recruitment and procurement, together with anybody working for us, providing services to us or working on our behalf across Entains global operations, must
[13978] Not use forced or compulsory labour, ie any work or service that a worker performs involuntarily or under threat of penalty
[13978] Comply with the minimum age requirements prescribed by applicable laws
[13978] Compensate workers with wages and benefits that meet or exceed the legally required minimum for that country
[13978] Abide by applicable laws concerning the maximum hours of daily labour
[13978] Take reasonable steps to ensure that any sub-contractors or suppliers from whom they source goods and/or services for ultimate use by ENTAIN adhere to these requirements; and
[13978] Bring any actual or potential cases of Modern Slavery to the attention of ENTAINs global HR Director immediately for further investigation using our Speak Out (Whistleblowing) procedure
[13978] Actions Taken by Entain to Assess and Address Modern Slavery Risks In addition to our publicly available Supplier Policy, our internal processes, procedures and policies help us identify risk
[2405] (g) ILO Convention (No 182) concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour
[2405] The Policy educates our staff on the definition of Modern Slavery and highlights areas within our operations and supply chains that may be higher risk
[2405] The Policy details to staff what our risk assessment and due diligence processes are in this area
[2405] Finally, from a remedial perspective we advise staff that any staff member who breaches the Policy by engaging in or conspiring to engage in any Modern Slavery conduct may face disciplinary action, that the Firm may terminate relationships with individuals or organisations upon a breach and that referral action to proper authorities will be taken in cases involving breaches of the criminal law
[2405] We are currently in the process of finalising this policy for roll out by the cessation of our second reporting period
[2405] Mills Oakley understands that Modern Slavery includes only the most severe forms of exploitation
[2405] However, we also know that the existence of substandard workplace conditions can be a precursor of Modern Slavery
[2405] We have in place the following policies that we believe ensure our operations are aligned with our legal and ethical workplace requirements: Anti Bribery & Corruption Policy, Code of Conduct, Conflict Management Policy, Diversity Policy, Drug and Alcohol Policy, Fatigue Policy, Flexible Working Policy, Grievance Resolution Policy, Leave Policy, Parental Leave Policy, Recruitment Referral Policy, Risk Management Policy, Whistleblower Policy, Workplace Behaviour Policy and Workplace Health & Safety Policy
[10579] Further steps This Modern Slavery statement can be found on the Hillebrand Gori website and will be reviewed on an annual basis
[10579] Our customers and suppliers will be requested to confirm that they have adhered to the Modern Slavery Act 2018 and have processes and policies in place to mitigate the risk within their own Supply chain
[10579] Mads Aaboe Area Director - Hillebrand Gori Oceania Hillebrand Gori Date 14.02.2023
[10726] Modern Slavery Statement 1 July 2021 to 30 June 2022
[10726] Modern Slavery Statement FY22 Page 1 of 8
[10726] Contents 1.1 Reporting Entity
[10726] 1.2 Structure, operations, and supply chains of the Busways Group
[10726] 1.2.1 Structure
[12563] Where possible we reduce, re-use and recycling materials
[12563] OUR POLICIES AND GOVERNANCE TRAINING Training is an integral part of our compliance framework
[12563] It ensures that all employees are aware of their responsibilities
[12563] All new employees are required to complete an online induction course
[12563] During the onboarding and induction of new employees aspects covered include our values, code of conduct, key policies, health and safety, discrimination, bullying and harassment
[12563] All employees and contractors are required to complete refresher training every two years
[12563] With regards to modern day slavery and our employees, we will continue to determine what the best approach will be to create awareness of the signs of modern-day slavery for our employees moving forward
[12563] HOW ASG ASSESSES EFFECTIVENESS OF ACTIONS BEING TAKEN TO ASSESS AND ADDRESS THESE RISKS ASG is committed to assessing the effectiveness of actions being taken to assess and address the risks of modern slavery within its operations
[13978] Our Contracts Policy requires business owners to engage in due diligence in relation to potential suppliers
[13978] Such due diligence includes conducting initial risk assessments, various background searches and escalating any adverse findings to Senior Leaders
[13978] Where applicable, based on risk, size and strategic alignment, we enter into a commercial and contractual relationship ensuring we have an agreed set of terms and conditions setting out how we wish to trade, pricing, delivery timelines, data protection, security compliance, ethical standards and behaviours in accordance with relevant laws and jurisdictions
[13978] The Procurement Lifecycle Our procurement function has implemented a common set of processes, tools and policies that govern the way we source, review, assess and engage with our suppliers
[13978] We ensure we clearly capture the needs of the business
[13978] We competitively tender such need
[13978] We evaluate, clarify and negotiate
[13978] We contract manage
[2405] Training We are currently working with an external training provider to create a training module for all staff in relation to Modern Slavery
[2405] This will be in the form of an online course to help staff understand what Modern Slavery is, the impacts of Modern Slavery in present day society, what it means to have transparency in our supply chain, the MSA, and our reporting obligations
[2405] The module is due to be rolled out by May 2021
[2405] We will look to require staff to complete this training on an ongoing periodic basis
[2405] Reporting Mills Oakley acknowledges that the nature of Modern Slavery means that many victims and surrounding individuals are unable to draw attention to their circumstances for fear of negative consequences
[2405] Mills Oakley has a detailed Whistleblower Policy which clearly sets out the circumstances around protected disclosures and encourages the reporting of matters that may cause harm to individuals
[2405] This policy ensures the protection of the identity of a Whistleblower and protects Whistleblowers against detrimental conduct
[2405] This allows individuals the freedom to raise reports of Modern Slavery without fear of retribution in circumstances that meet the terms of the policy
[10726] 1.2.2 Operation
[10726] 1.2.3 Supply chains
[10726] 1.3 Risks of modern slavery practices in the operations and supply chains, and any entities the Business owns or controls
[10726] 1.3.1 Risk in our operations
[10726] 1.3.2 Supply chain risks
[10726] 1.4 Actions by Busways Group to assess and address those risks, including due diligence and remediation processes
[10726] 1.4.1 Modern Slavery Committee
[10726] 1.4.2 Internal awareness and education
[12563] At present, ASG has set up an annual review as part of its Audit & Compliance Committee agenda, which meets quarterly, in which ASGs responses to modern slavery risks and the actions taken by the business are reviewed and recommendations made on methods to improve the assessment of the effectiveness of actions being taken
[12563] Further to this, as part of the Audit & Compliance Committee agenda, the Committee conducts regular reviews of risk assessment processes to ensure if and when new operations are commenced in countries or regions, that any new risks associated with modern slavery are identified and assessed as appropriate
[12563] At a global level, ASGs parent company, Nomura Research Institute, has an internal team based in Tokyo which undertakes an assessment of various vendors through internal and external blacklists and approves relevant engagements of vendors as an additional measure to ensure the effectiveness of ongoing actions being taken by NRI Group, which includes ASG to assess and address risks of modern slavery within its operations and supply chains
[12563] ASG will need to determine moving forward what further actions and measures can be taken to ensure ASG is able to regularly assess the effectiveness of the actions being taken by the company to assess and address modern slavery risks
[12563] CONSULTATION ASG Group has consulted internally within ASG Group in respect of the preparation of this statement, including review by the Board of ASG Group prior to finalising
[12563] ASG Group has consulted with each of the Controlled Entities in preparing this modern slavery statement through internal reviews and consultation with directors of each of the Controlled Entities and final engagement with each of these directors to finalise ASGs Groups modern slavery statement prior to approval by the Board of ASG Group
[12563] This statement was approved by the Board of ASG Group on 2 December 2022
[12563] Signed, HIROYUKI KAWANAMI Director, ASG Group 5 December 2022
[13978] We exit and service transfer when such relationships come to an end Throughout our processes we have the appropriate review mechanisms to highlight and manage risk in relation to delivery of products or services, data protection, security compliance, technical compliance and our CSR standards
[13978] Regular communication and interactions with our suppliers are key in ensuring, where applicable, we see and evidence the working environment and practices they trade within
[13978] Monitoring and Assessment The Entain Code of Conduct, Modern Slavery Policy, Contracts Policy and related training materials clearly set out our expectations: that all employees and suppliers act in a proactive, legal and ethical manner at all times
[13978] Entain Australia endeavours to maintain proactive relationships with its suppliers and continually assesses their performance and corporate standing
[13978] In 2021, we commenced updating our supplier audit processes and standard contracting terms to include human rights and Modern Slavery items and will continue to implement further measures to drive visibility within our supply chain
[13978] We also endeavour to renew and update our Modern Slavery training materials each year and continue to audit employee compliance in relation to mandatory trainings
[13978] Entain Australia regularly consults Entain plc in relation to our governance practices, including our compliance with Modern Slavery laws and we will strive to frequently consult with them in relation to our monitoring and assessment of such practices
[2405] Having retribution-free reporting avenues is a key element of accurate due diligence in this area and will ensure we have greater visibility over our risks
[2405] Supply Chain Mapping Mills Oakley understands that supply chain mapping involves examining risks to people and is a key part of due diligence in this area
[2405] We understand this involves setting aside our own legal, reputational and commercial risks to enable us to focus primarily on risks to people as per the United Nations Guiding Principles on Business and Human Rights
[2405] We have collated a list of the MO Entities tier 1 suppliers and have reviewed the list in order to create a breakdown of each supplier on the basis of the geographic location of a supplier, as well as the category
[2405] of goods or services relevant to a supplier
[2405] We are conscious that our tier 1 suppliers are just one part of the picture of our supply chain, and we undertake to peer deeper into our supply chains in future reporting periods, acknowledging that our risk assessments may alter considerably as we do so
[2405] There is no automatic correlation or causal link between an entitys spend and the actual risk of Modern Slavery occurring in a particular suppliers operations and supply chains
[2405] As such, we have not focussed solely on our high spend suppliers initially, opting instead to commence mapping with known risk indicators in this area
[10726] 1.4.3 Incorporate the prevention of modern slavery into our procurement policies and procedures
[10726] 1.4.4 A continuous improvement approach to mitigate potential risks within our operation and supply chain
[10726] 1.5 How Busways Group assesses the effectiveness of such actions
[10726] 1.6 Process of consultation within Busways Group
[10726] 1.7 Future commitments
[10726] 1.7.1 Policies and procedures
[10726] 1.7.2 Training and awareness
[10726] 1.7.3 Collaboration and engagement
[13294] [Organon] Proprietary ORGANON MODERN SLAVERY STATEMENT 2022 INTRODUCTION This statement is made pursuant to the Australian Modern Slavery Act of 2018 and the UK Modern Slavery Act of 2015
[13294] It sets out the steps that Organon & Co (Organon), the reporting entities listed below, and the subsidiaries of those entities, took over the period from 1 January 2022 to 31 December 2022 to identify and address the risks of modern slavery1 occurring in their operations and supply chains
[13294] REPORTING ENTITIES This statement is submitted by the Organon reporting entities set out in the Appendix to this statement
[13294] STRUCTURE, OPERATIONS AND SUPPLY CHAINS ABOUT ORGANON Organon was formed by a spinoff from Merck & Co., Inc of Rahway, NJ, USA which took place on 3 June 2021
[13294] Organon is a global healthcare company with a focus on improving the health of women throughout their lives
[13294] Organon has a portfolio of more than 60 medicines and products across a range of therapeutic areas
[13294] Led by the womens health portfolio coupled with an expanding biosimilars business and stable franchise of established medicines, Organons products produce strong cash flows that will support investments in innovation and future growth opportunities in womens health
[13294] In addition, Organon is pursuing opportunities to collaborate with biopharmaceutical innovators looking to commercialize their products by leveraging its scale and presence in fast growing international markets
[13978] The effectiveness of the steps Entain has taken in relation to Modern Slavery is assessed through testing knowledge of staff in relation to Modern Slavery through annual training modules, and compliance with other relevant policies including the Contracts Policy
[13978] Any failure to reach required thresholds of knowledge and any non-compliance with relevant policies will lead to further training and direction for the staff member involved