mila-ai4h/AIMS.au huggingface dataset:
[13978] Effectiveness is also assessed by regular assessment of employee and contractor processes and quality assurance of contracting processes
[13978] Governance In late 2021/early 2022, the Group conducted an internal audit reviewing the risk of Modern Slavery in Entain and our supply chains to provide an independent, objective review of our risk mitigation framework
[13978] The audit focused on (1) the adequacy of recruitment, employment management and payroll processes; (2) the adequacy and completeness of due diligence processes for third parties; (3) the inclusion of Modern Slavery in the risk management process; (4) the existence and effectiveness of key performance indicators (KPIs) measuring performance in tackling Modern Slavery; and (5) efficiency and usage of training programmes about Modern Slavery
[13978] The full output of the internal audit was reported to the Group Board and Audit Committee in February 2022 and shared with our external auditors
[13978] Following the audit, key improvements to the Modern Slavery framework have been made, including
[2405] Utilising existing resources such as the Global Slavery Index, the 2016 US Department of Labour report, the 2018 US Department of Labour report and the Commonwealth Modern Slavery Act Guidance for reporting entities amongst others, we have identified higher risk suppliers on the basis of geographic location and category of goods or services
[2405] The suppliers identified as potentially posing a higher risk of Modern Slavery include those in the areas of information and technology, office fit-outs, recruitment, stationary, cab services, milk suppliers, coffee suppliers, catering services, security services and maintenance services
[2405] We then examined the geographic location of our suppliers
[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 which is considered to be a low risk location
[2405] We then produced a list of 5 suppliers that ranked as potentially higher risk in both categories (the focus group)
[10726] Modern Slavery Statement FY22 Page 2 of 8
[10726] Reporting Entity This Joint Modern Slavery Statement (Statement) is made pursuant to sections 14 and 16 of the Modern Slavery Act 2018 (Cth) (the Act)
[10726] The Statement covers the reporting period from 1 July 2021 to 30 June 2022 and addresses the mandatory reporting criteria, as required by section 16 of the Act
[10726] The entities covered by this Statement are: (a) Bhaajayu Pty Ltd (ACN 084 980 263) (b) Busways Australia Pty Ltd (ACN 643 586 225) (c) Busways Blacktown Pty Ltd (ACN 000 173 437) (d) Busways Camden Pty Ltd (ACN 003 081 230) (e) Busways Campbelltown Pty Ltd (ACN 000 572 145) (f) Busways Gosford Pty Ltd (ACN 055 471 782) (g) Busways North West Pty Ltd (ACN 643 586 770) (h) Busways Pacific Pty Ltd (ACN 106 202 340) (i) Busways South Australia Pty Ltd (ACN 613 309 185) (j) Busways Wyong Pty Ltd (ACN 000 044 726) (k) Galbrock Pty Ltd (ACN 078 310 657)
[10726] (When referring to all entities, they will be referred to as Busways Group)
[10726] Busways Group acknowledges it has both a legal and a moral responsibility to promote transparency in its operations
[10726] Therefore, we implement procedures specifically focused on reducing the possibility of modern slavery practices existing within our business and our supply chain
[10726] The entities forming part of Busways Group have an annual consolidated revenue of over $100 million in the financial year from 1 July to 30 June 2022
[13294] Organon has a global footprint with significant scale and geographic reach, world-class commercial capabilities, and approximately 9,300 employees
[13294] Organons headquarters are located in Jersey City, New Jersey, USA and a list of our worldwide locations is available at Organon Global Locations
[13294] For more information, visit http://www.organon.com
[13294] OUR SUPPLY CHAINS We manufacture, package and distribute products to more than 135 countries and territories around the world
[13294] We have established business relationships with over 7,500 suppliers and partners
[13294] Our network is comprised of approximately 300 direct suppliers (including external manufacturing partners), 250 capital expenditure suppliers, 7,000 indirect partners, and 150 research providers
[13294] We have established a footprint in 62 countries and collaborations in more than 80 countries
[13294] Our direct suppliers provide us with goods and services such as packaging, components and ingredients
[13978] making completion of the Code of Conduct training module (including Modern Slavery) mandatory
[13978] revising the risk scoring assigned to Modern Slavery to align it with the Group risk management process
[13978] including appropriate Modern Slavery clauses in terms and conditions with affiliates, recruitment agencies and suppliers
[13978] requiring new suppliers to provide details of any investigations relating to possible bribery or corruption; Modern Slavery will continue to form an ongoing part of the audit cycle of the Group to ensure that the controls continue to work effectively and are assessed for opportunities to improve regularly
[13978] This statement was approved by the boards of each of the reporting entities covered by this statement on 28 June 2023 and will be reviewed annually
[13978] Dean Shannon CEO and Director, Entain Group Pty Ltd Director, LB Australia Holdings Pty Ltd
[13978] Lachlan Fitt CFO and Director, Entain Group Pty Ltd Director, LB Australia Holdings Pty Ltd
[14039] ____________________________________________________________________________________________________
[2405] At this stage, we needed to consider what action to take in relation to this focus group, and how to triage the list
[2405] Mills Oakley understands that the greater the spend on a particular supplier, the greater our leverage to create positive change with that supplier
[2405] On that basis, we have decided to approach the focus group on a spend basis when considering which risks to respond to first
[2405] In relation to the focus group we have also considered whether we have any indication of how each risk would manifest if it was found to be an actual incident of Modern Slavery
[2405] Our focus would then be on the human rights impacts that would have the gravest impact, affect the greatest number of people, or a delayed response may affect remediability
[2405] At the moment, given we are only aware of risks rather than any actual incidents, we are unable to prioritise on this basis
[2405] We have every intention of factoring in severity and irremediability into our due diligence once we have the requisite information to allow this to be done
[2405] We understand that those suppliers that are not within the focus group cannot be placed aside permanently
[10726] Structure, operations, and supply chains of the Busways Group 1.2.1 Structure Busways Group is a wholly Australian owned operation
[10726] It is beneficially owned by the Rowe family, who are supported by a leadership team that oversees operations, finance, HR and administration for all entities within Busways Group
[10726] Operation Busways Group is a wholly Australian owned operation
[10726] The core business of Busways Group is to provide and operate bus passenger transportation services
[10726] Modern Slavery Statement FY22 Page 3 of 8
[10726] Busways Group is currently contracted by the state governments in New South Wales and South Australia to deliver bus operations
[10726] Busways Group has over 1,300 buses operating in 14 contract regions
[10726] We delivered services to 60 million passengers in FY22
[13294] Capital expenditure suppliers provide goods and services such as engineering and construction
[13294] Our indirect suppliers include those that provide services such as logistics, travel and meetings, facility management and marketing
[13294] Our research providers include those that provide laboratory supplies and other services
[13294] RISKS OF MODERN SLAVERY PRACTICES IN OUR OPERATIONS We believe there is minimal risk of Organon causing, contributing to or being linked to instances of modern slavery within our own operations
[13294] We do not engage in business activities that involve low-
[13294] The term "modern slavery" describes situations in which coercion, threats or deception are used to exploit victims and undermine their freedom
[13294] Modern slavery takes many forms including slavery, servitude, forced labour, debt bondage, deceptive recruiting for labour or services, the worst forms of child labour (where children are exploited through slavery like practices or exposed to hazardous work) and forced marriage
[13294] [Organon] Proprietary skilled, labour-intensive production or foreign migrant workers
[14039] Hilton Food Australia Pty Ltd, 267 Dohertys Road, Truganina, VIC 3029, Australia Tel: +61 (3) 8855 7450 www.hiltonfoods.com ABN: 60 613 035 500
[14039] June 2023 MODERN SLAVERY STATEMENT FOR THE FINANCIAL YEAR ENDING 31 DECEMBER 2022
[14039] This statement is made in accordance with the Modern Slavery Act 2018 (Cth) by Hilton Foods Australia Pty Limited ACN 613 035 500 (Hilton Foods Australia)
[14039] Hilton Foods Australia operates meat processing and packaging facilities in Australia
[14039] It is wholly-owned by Hilton Food Group plc (HFG plc), a company headquartered in Huntingdon, United Kingdom and listed on the London Stock Exchange (LON code: HFG)
[14039] This is Hilton Foods Australias third Modern Slavery Statement and outlines the actions and progress made during the financial year ending on 31 December 2022 to both identify and address modern slavery risks in our operations and supply chain
[14039] STRUCTURE, OPERATIONS AND SUPPLY CHAINS
[14039] Overview of Operations
[2405] We intend to work our way through our full supply chain in the reporting periods to come, ensuring that we do so in a meaningful way which will require greater timeframes
[2405] Mills Oakley also acknowledges 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] We have every intention of keeping our approach adaptable and responsive to these changes
[2405] Suppliers Mills Oakley has created a specific Supplier Code of Conduct (the Code) centred around Modern Slavery issues
[2405] Once this is rolled out, it will apply to all of our direct suppliers and will assist greatly both in due diligence around our suppliers and in our remedial powers in the event that actual instances of Modern Slavery are ever discovered
[2405] The Code also provides that we expect our suppliers to have their own suppliers adopt the commitments in the Code
[2405] The Code clearly articulates the standards of practice we expect of our suppliers and details our commitment to combatting Modern Slavery
[2405] Mills Oakley wants to partner with suppliers who are willing to join us in strengthening our response to Modern Slavery, who are committed to high standards of transparency and ethical conduct, and who support other suppliers in promoting corporate social and environmental responsibility
[10726] Busways Group employs over 2,600 employees
[10726] The main components of our staff are bus drivers, mechanics and administrative support
[10726] Supply chains Busways Group is wholly Australian owned, and it only provides services within Australia
[10726] As such, all Busways Groups employees are based in Australia
[10726] Busways Group purchases goods and services from suppliers who are almost exclusively Australian based
[10726] Busways Group engages with suppliers for tyres, spare parts, fuel and lubricants and other goods and services required to operate its bus fleet
[10726] In addition, Busways Group sources and purchases uniforms from external suppliers
[10726] For depot construction, refurbishment and maintenance projects, Busways Group engages external companies for materials and services
[13294] We have robust labour, employment and recruitment practices in place
[13294] The pharmaceutical industry is highly regulated and is not generally recognised as an industry that poses a significant risk of modern slavery, compared to other industries (eg agriculture, construction, electronics, extractives & mining, hospitality, textiles, apparel, forestry, fishing, food processing and transportation)
[13294] IN OUR SUPPLY CHAINS We have assessed that the risk of modern slavery practices occurring within our supply chains is predominantly associated with our use of third-party suppliers and service providers that operate in countries that are known to present a significant risk of modern slavery, such as those listed on the Walk Free Foundations Global Slavery Index, as well as other recognised external data sources on modern slavery and human trafficking
[13294] We recognise that companies with supply chains that extend into high-risk countries potentially face greater risks of modern slavery
[13294] Our company can be indirectly exposed to modern slavery risks through our supply chains, as some of our third-party suppliers and service providers operate in countries that have a high prevalence of modern slavery
[13294] ACTIONS TAKEN TO ASSESS AND ADDRESS MODERN SLAVERY RISKS IN OUR OPERATIONS From June 2021, as a standalone public company, we have worked and are continually working to detect and address the risks of modern slavery within our own operations through: Organon Code of Conduct - Respecting and abiding by our companys core values and standards, as stated in our company Code of Conduct
[13294] We consider these to be the foundation of our companys success
[13294] They apply globally, wherever we are doing business
[14039] HFG plc is a leading international multi-protein food producer dedicated to serving customers and millions of consumers over the world with high-quality meat, seafood, vegetarian and vegan foods, and ready-to-eat products
[14039] HFG plc was established in the United Kingdom in 1994 and listed on the London Stock Exchange in May 2007
[14039] HFG plc conducts business in 13 markets across the UK, Europe, Australia and New Zealand operating 24 technologically-advanced food processing facilities
[14039] Further information related to HFG plc can be found at the following link: https://www.hiltonfoods.com/who- we-are/
[14039] Hilton Foods Australia was established in June 2016 to supply Woolworths Limited (Woolworths) stores in Australia
[14039] Our business model is to process and pack both natural and value-added meat and plant based raw material products for the Australian retail markets
[14039] Processing takes place across meat processing facilities in Bunbury (Western Australia), Heathwood (Queensland) and Truganina (Victoria)
[14039] Hilton Foods Australia supplies packaged meat and food products to over 1,000 Woolworths stores across Australia
[2405] The Code requires compliance with the following: (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 (g) ILO Convention (No 182) concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour
[2405] We require our suppliers not to do or omit to do anything that will cause us to breach any of the above laws and instruments
[2405] The Code educates suppliers on the definition of Modern Slavery, as well as detailing several relevant human rights and human rights related instruments and requires that suppliers uphold and comply with same
[2405] The Code details our expectations of suppliers in relation to their own risk assessments and due diligence processes
[2405] Under the Code, Mills Oakley has the right to audit our suppliers in a number of in-depth ways, and the Code requires our suppliers full cooperation with any such processes or requests
[2405] We also require our suppliers not to take any adverse action against staff or third parties as a result of their disclosure of information under the Code
[2405] Suppliers are informed that referral action to proper authorities will be taken in cases involving breaches of the criminal law
[2405] Our contracts with suppliers contain clauses relating to compliance with local laws
[10726] A small number of suppliers, who supply specialised consultancy and technical advice to Busways Group, are based in North America
[10726] Risks of modern slavery practices in the operations and supply chains, and any entities the Business owns or controls 1.3.1 Risk in our operations From a geographical perspective, Australia is based in a low-risk region
[10726] Given the strong legislation and guidance in place, the risks of our operations being directly exposed to modern slavery is low
[10726] However, Busways Group is aware that there may be indirect exposure to risks further down our supply chain
[10726] Busways Group has strong visibility over its own employees and complies with Australian workplace laws, including the Fair Work Act 2009 (Cth), National Employment Standards (NES), and work health and safety legislation
[10726] We are confident there are no modern slavery practices within operations directly under our control
[10726] In accordance with various legislation and enterprise agreements currently in place, Busways Group regularly engages with the Transport Workers Union (TWU) and the Rail, Tram and Bus Union (RTBU) who act in their capacity to represent the interests of their members
[10726] Furthermore, Busways Group seeks external legal advice from specialist employment lawyers and service providers to ensure we meet various legal and social obligations, and our employees receive the correct entitlements
[13294] Standards - Upholding and maintaining company standards on modern slavery and human trafficking
[13294] These are reflected in our Public Policy Statement on Human Rights and we expect our suppliers to adhere to our Business Partner Code of Conduct (BPCC) and Supplier Performance Expectations
[13294] Speaking Up - Fostering an environment where employees feel safe to speak up and report concerns
[13294] We rely on employees to speak up about potential violations of our Code of Conduct, policies, procedures, the law or other misconduct, including any that are suggestive of modern slavery
[13294] We are committed to investigating any report of potential incidences of modern slavery occurring anywhere in our operations and confirm that we would take all appropriate steps to rectify any confirmed incidences of modern slavery in our operations
[13294] Tone at The Top - Communications from senior leaders emphasising the importance of ethics and integrity and the importance of speaking up and reporting issues/concerns before they become a bigger problem
[13294] Communication Channels - Maintaining multiple communication channels to make it easy for employees and others to ask questions or report concerns
[13294] Employees can report concerns to their managers, human resources, compliance or legal
[14039] Structure
[14039] Hilton Foods Australia is a proprietary company incorporated on 16 June 2016 in Victoria, Australia
[14039] The company is 100% owned by Hilton Foods Asia Pacific Limited, a company incorporated in the United Kingdom
[14039] Hilton Foods Asia Pacific Limited is wholly-owned by HFG plc
[14039] Approximately 1,250 people are employed by Hilton Foods Australia on a permanent, full- time basis
[14039] This is an increase from approximately 1,120 in 2021
[14039] A further 1,076 people are employed through agency contracts
[14039] The permanent employee distribution effective up to 31 December 2022 was
[2405] We have drafted precedent contract clauses that speak more specifically to Modern Slavery to add contractual weight to our supplier code of conduct
[2405] We will seek to negotiate with various suppliers for the inclusion of same in our agreements in reporting periods ahead
[2405] We currently monitor the performance of our suppliers carefully and ordinarily engage in annual review sessions with suppliers to examine any issues with the relationship and dealings
[2405] We have also drafted a detailed supplier questionnaire aimed specifically at assisting Mills Oakley in identifying and assessing the risks of Modern Slavery within our supply chain
[2405] The questionnaire is
[2405] currently over 40 questions long and is reserved for particularly high risks identified as it is quite robust
[2405] We endeavour to work with our focus group to assist them in filling out the questionnaire
[2405] COVID-19 Mills Oakley has taken great care to monitor the health and wellbeing of our staff during the pandemic
[10726] Busways Group is confident that we are not directly causing or contributing to modern slavery practices in our workforce
[10726] We have assessed the risk of modern slavery involving our direct employees to be low
[10726] However, we recognise contracted or contingent workers, including those provided by third-party labour hire, may be more vulnerable to modern slavery risks
[10726] The greatest potential of this being workers who are lower-skilled, temporary, or migrant workers
[10726] This may include workers in areas such as bus and on-premises cleaning, and catering
[10726] As part of our commitment to continuous improvement, Busways Group is in the process of requesting Modern Slavery statements and commitments from these identified third-party providers
[10726] Supply chain risks Busways Group recognises that even though most of our suppliers are based in Australia, some of their products and services may be, partly or wholly, manufactured in other countries in the Asian, North American, and European regions
[10726] Modern Slavery Statement FY22 Page 4 of 8
[13294] Speak Up Tool - Providing a speaking up tool
[13294] The Speak Up tool EthicsPoint - Organon is operated by an independent third-party and it is available 24 hours a day, 7 days a week
[13294] It allows employees to raise concerns or ask questions confidentially, and if preferred, anonymously, in their preferred language via telephone or the internet
[13294] Investigations - All allegations of misconduct are investigated in accordance with our companys Compliance Issues Visibility Response process, which promotes confidentiality, dignity and respect, objectivity, promptness and non-retaliation
[13294] [Organon] Proprietary Corrective Action - We take violations seriously
[13294] Corrective and disciplinary actions are taken against individual employees who are determined to have engaged in misconduct based on the findings of an investigation, which is independently overseen by our Office of Ethics & Compliance, Internal Audit and/or Legal investigations teams
[13294] Training - New employees, as well as existing employees receive annual training on our company Code of Conduct, through a series of online compliance courses
[13294] Training completions are closely monitored and reported to senior management
[14039] Australia Baulkham Hills, New South Wales 11
[14039] Bunbury, Western Australia 168
[14039] Heathwood, Queensland 567
[14039] Truganina, Victoria 504
[14039] Supply Chain
[14039] Woolworths sources the meat and meat products processed by Hilton Foods Australia
[14039] All food ingredients and packaging materials are sourced by Hilton Foods Australia from Australian and international suppliers
[14039] Our supply chain is inclusive of labour hire and the procurement of specialised consulting services
[2405] We have provided frequent communications with staff regarding support services available including our free employee assistance provider lines
[2405] We have also asked staff to participate in a number of anonymous surveys in order to effectively identify any issues that need to be addressed