mila-ai4h/AIMS.au huggingface dataset:
[8960] These product manufacturing and assembly activities are predominantly carried out in Hong Kong, China, Taiwan, Vietnam, Thailand, Malaysia and Brazil
[8960] In 2021, Worldlines product manufacturing programs have been consolidated in the TSS division, leading to common practices in terms of the supply chain
[8960] Conducting business in an ethical and sustainable way is part of Worldlines culture and strategy in all its spheres of influence, it is a must have that Worldline has integrated into the companys thinking and processes
[8960] We truly believe that our responsibilities go beyond our own company, and we strive to embed our values in our relations with all our employees, customers, partners and across our supply chain
[8960] Worldline operates a Corporate Social Responsibility (CSR) programme, which also focuses on labour practices, with its main objectives being the management of the companys operations in a responsible and ethical manner and which integrates social and environmental factors in the supply chain
[8960] In this respect we address human rights abuses and issues of Modern Slavery
[8960] Since its first Modern Slavery statement in 2017, Worldline has relied on its CSR programme to follow and improve its policies and due diligence practices, as described in this statement
[11998] This statement sets out the steps taken during the financial year ending June 2022 to conform to the Australian Federal Legislation Modern Slavery Act 2018
[11998] Organizational Structure, Operations and Supply Chains EJ & WA Booth Pty Ltd and its associated entities are an Australian business focused on the sales of motor vehicles, vehicle servicing and repairs and parts retailing
[11998] The Company was established in 1939 and today comprises three dealerships across the NSW Central Coast
[11998] Supply chains include the following goods and services
[11998] Vehicles and parts Consumables including oil, fuel, and lubricants
[11998] Vehicle washing and detailing services
[11998] Finance and insurance products
[11998] Risks of Modern Slavery practices in the operations, supply chains of the reporting entity as defined We are committed to identifying possible modern slavery risks in our operations and supply chains
[14781] Risks of modern slavery practices in our operations and supply chains
[14781] The Group has adopted a risk-based approach to modern slavery due diligence
[14781] We are only willing to do business with suppliers that hold similar values and ethical practises as ourselves
[14781] Whilst we consider the risk of modern slavery within our supply chain to be lower than other parts of the automotive industry because of the jurisdictions we operate in and our longstanding and close relationships with our key suppliers, we are mindful of the need to choose our business partners well, to carry out appropriate due diligence before commencing a relationship, and to remain alert to the indicators of modern slavery
[14781] The Group conducted its first analysis of key suppliers that might create a higher risk of modern slavery practices for Turners in early 2020
[14781] We update this analysis each year
[14781] Current key risks for the 2022 2023 financial year identified are below
[14781] Risk of modern slavery practices in sourcing and import of second-hand Japanese cars: low so long as key supplier relationships are maintained, and our expectations are made clear
[8960] In 2021, Worldline renewed its CSR programme with an upgraded 5-year plan - TRUST 2025
[8960] This ambitious CSR programme builds on the achievements of TRUST 2020 and commits Worldline to the same high standards, with new, clear goals1
[8960] In this regard, two specific Key Performance Indicators (KPIs) have been set up
[8960] % of suppliers with an EcoVadis score below 45 having an action plan to solve critical findings identified
[8960] strategic suppliers representing 90% of total supplier expenses assessed by EcoVadis
[8960] Global Compact Worldline joined the UN Global Compact in 2016.and since 2020 has been represented by its CEO, Mr Gilles Grapinet, on the Board of Directors of Global Compact France
[8960] Being a member of the Board of Directors of Global Compact France gives Worldline a real opportunity to join forces with a major institutional player in the field of sustainable development
[8960] The UN Global Compact provides a universal standard for corporate responsibility and provides a framework which guides all businesses regardless of size, complexity or location in the principles that they need to adhere to in order to reduce human rights and labour abuses
[11998] The risks of modern slavery practices mean the potential for an entity to cause, contribute to or be directly linked to modern slavery through its operations and supply chains - in other words, the risk that an entity may be involved in modern slavery
[11998] It is our understanding that our risk profile indicated that the risks of modern slavery are more likely to occur further down the supply chain of EJ & WA Booth Pty Ltd and its associated entities
[11998] FY21- this being our first reporting period, it was the start of our plans of increasing the awareness of modern slavery risks in our business operations and supply chains with a view to be better informed for our purchasing decisions going forward
[11998] Action taken to assess and address these risks including due diligence and remediation processes Addressing the challenges of modern slavery is an evolving process and in FY23 we plan to assess our effectiveness by
[11998] Reviewing existing supplier arrangements
[11998] Create a Risk Assessment Questionnaire to identify ethical, social or governance risks
[11998] Survey the highest value suppliers, then collate and review responses taking action upon any deficiencies
[11998] HR department to review current polices and incorporate modern slavery provisions in our training
[14781] Risk of modern slavery practices in using New Zealand transport agents: low
[14781] Risk of modern slavery practices in supply chain for manufacture of uniforms worn by Turners employees operating in automotive retail: medium high on the basis of identified risk in the garment industry globally
[14781] The Group offers its employees a share plan, which we operate through a separate Group subsidiary, Turners Staff Share Plan Trustees Limited
[14781] Risks of modern slavery in contracted cleaning services for Turners head office, retail offices and the Groups finance, insurance and credit management businesses: medium (particularly due to high staff turnover and a reliance on migrant workers)
[14781] Risks of modern slavery in contracted motor vehicle repairer services for DPL Insurance and Turners retail: low so long as supplier relationships are maintained and our expectations are made clear
[14781] Actions to assess and address risks of modern slavery practices: remediation and whistle-blowing
[14781] The Groups Audit, Risk Management and Sustainability Committee, which reports to the Board, is responsible for assessing the effectiveness of Turners modern slavery risks
[14781] The Audit, Risk Management and Sustainability Committee reports to the Board on an as needed basis, including providing a regular annual risk update
[8960] Principle 5 of the UN Global Compact specifically addresses Modern Slavery and advocates the effective abolition of child labour
[8960] In this regard, the Company is also committed to contributing to the United Nations Sustainable Development Goals (SDGs) which also enshrine the Global Compact principles
[8960] Policies and procedures
[8960] Code of Ethics Worldlines Code of Ethics has been part of every employee's contract since 2011
[8960] It was last reviewed, updated and approved by the Worldline CEO in 2021
[8960] The Code of Ethics has been made available in 12 languages
[8960] Suppliers, partners and third parties who assist Worldline in its business activities must also commit to respecting the principles of the Code
[8960] Additionally, all Worldline employees must complete a mandatory e-learning module on the Code of Ethics, so that all employees are familiar with this key document
[11998] Assessment of the effectiveness of the actions in criterion 4 The effectiveness of steps taken to address modern slavery risks in our business operations and supply chains will be better assessed in the next reporting period when the benefit of reviewing the impact of the processes put in place for this year of reporting
[11998] We intend to communicate with stakeholders involved in our businesses regarding potential modern slavery risks, and what can be done to address these risks
[11998] Process of consultation with any entities the reporting entity owns or controls The operations of the EJ & WA Booth Pty Ltd and its associated entities is controlled by, closely aligned and fall under the same senior management and board composition
[11998] For this reason, we consider it appropriate for a joint report to be submitted in respect to the business operations and subsidiaries that are reporting entities under the Act
[11998] Endorsement from the Board of Directors This statement was approved by the Board of Directors of EJ & WA Booth Pty Ltd on 16th November 2022 and instructs that it be reviewed and updated annually
[11998] Director's signature on behalf of the Board
[11998] David Booth Director
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[14781] Since the Groups first risk assessment in early 2020, our Group Governance Code and Code of Ethics both highlight our expectations and commitments to good business ethics and responsible supply chain management
[14781] We provide all of our suppliers with our Supplier Code of Conduct
[14781] Our Supplier Code of Conduct reaffirms our commitment to ethical, responsible and sustainable business conduct, and particularly Turners expectations regarding modern slavery
[14781] This includes that all suppliers ensure that all employees, agents and sub-contractors should comply with all employment, workforce and health and safety regulatory and statutory requirements
[14781] The Groups procurement expectations are that suppliers will be chosen that have demonstrated their ability to comply with the Code of Conduct
[14781] We are committed to continuing engagement across our supply chain and have taken steps each year to expand this work
[14781] We completed initial risk assessments in 2020 and 2021, and have since undertaken reviews of all our commercial cleaning contractors, uniform suppliers and telemarketers
[14781] We expect each of these suppliers to review and comply with our Supplier Code of Conduct
[8960] Within the Code of Ethics, Worldline commits to ensuring compliance with international labour regulations and to be a responsible company in dealing with all its partners, guaranteeing strict compliance with laws and regulations
[8960] TRUST 2025 is the subject of a set of 15 new objectives to be achieved within the next 5 years in the areas of data protection and security, social innovation, well-being at work, diversity & inclusion, skills & careers development, human rights, ethics, sustainable procurement, as well as the fight against climate change through the reduction of GHG emissions and the protection of biodiversity, as well as the development of local communities
[8960] The Code emphasises the ethical standards and values Worldlines employees and partners must abide by and includes a specific commitment relating to Modern Slavery: Following the United Nations Global Compact principles on human rights, labour and environment, we adhere to the elimination of all forms of exploitative and compulsory labour and the effective abolition of child labour, upholding the freedom of association and the effective recognition of the right to collective bargaining as well as supporting and respecting the protection of internationally proclaimed human rights
[8960] Whistleblowing Policy The Code of Ethics includes the right of any Worldline employee or stakeholder to disclose behaviours or actions deemed inconsistent with the values and principles of the Code of Ethics
[8960] Worldline Compliance Alerts Policy gives an overview on how Worldline acts on reports of compliance breaches including the protection of the person raising the alert
[8960] In 2021, the policy was reviewed and updated in order to align with the EU Whistleblowing Directive
[8960] To support the implementation of the policy, a Compliance Alert System has been established in line with the requirements of data protection authorities by which employees may alert the company to any non-compliance with the Code of Ethics and any other issues of non- compliance via a dedicated email address and an anonymous online reporting line
[8960] Line managers, the Global Head of Compliance and Human Resources are also points of contact for any employee wishing to raise an alert
[12318] Modern Slavery Statement 2022
[12318] This Modern Slavery Statement is made in accordance with the Modern Slavery Act 2018 (Cth) and covers the activities of Coventry Group Ltd ABN 37 008 670 102 and its related entities (Coventry)
[12318] We consulted the relevant companies we own in the development of this statement which sets out actions taken by Coventry to address modern slavery and human trafficking risks in its business and supply chain for the financial year ended 30 June 2022
[12318] This is Coventrys third statement and describes our actions over the past year to assess and address relevant risks
[12318] Introduction
[12318] Coventry is committed to respecting human rights and implementing policies, procedures, and internal checks to eradicate any form of Modern Slavery from its operations and supply chain
[12318] Coventry employees are expected to report concerns, using the appropriate reporting channels, and management are expected to act upon them
[12318] Structure, Operations and Supply Chains
[14781] We have also communicated our expectations that they are properly managing modern slavery risks in relation to their own sub-contractors and employees
[14781] In FY23 we conducted specific outreach for our suppliers of our largest business within the Group, the Turners car sale business
[14781] We have reviewed key suppliers particularly for this business, including office supplies, uniforms, cleaning, , including circulating our Supplier Code of Conduct as above
[14781] We have had some specific positive feedback from key suppliers who have been supportive of our approach
[14781] As set out below, this year we will send key suppliers a Modern Slavery Due Diligence Checklist which sets out our expectations in more detail
[14781] We continue to encourage our staff to raise modern slavery risks if they arise
[14781] Our Group Whistleblower Policy offers an anonymous channel to report any unethical conduct, including any illegal acts and any modern slavery violations
[14781] All reports are treated confidentially and are fully investigated
[8960] Through the Compliance and Data protection committee, the CEO has visibility of these alerts
[8960] The Compliance Alerts Policy ensures that the rights of employees, and the sender or subject of the alert, are protected during the whistleblowing process
[8960] Accordingly, a person who raises the alert is assured of complete confidentiality in relation to the alert
[8960] The policy also states that the reporting employee shall not be subjected to any penalty or retaliatory measure, provided that the reporting employee acted in good faith and without the intention to cause harm, even if the events relating to the alert prove inaccurate or no action is subsequently taken
[8960] It now also includes the formalisation of the alerts handling processes and confirms the right of individuals to raise concerns anonymously in line for instance with the EU Whistleblowing Directive
[8960] The Compliance Alert System is also shared with Worldline suppliers and third parties who are encouraged to report any concerns
[8960] Human Rights Policy Worldline published and implemented a Human Rights Policy in September 2021, reaffirming our commitment to respect and implement both local and international laws and principles of human rights
[8960] The applicable legislation includes, but is not limited to, the Universal Declaration of Human Rights; the International Covenant on Civil and Political Rights; the International Covenant on Economic, Social and Cultural Rights; the Council Directive 2000/78/EC of 27 November 2000 establishing a general framework for equal treatment in employment and occupation; and the International Labour Organisations Declaration on Fundamental Principles and Rights at Work
[12318] Coventry has two operating segments
[12318] a) Trade Distribution comprises Konnect and Artia Australia, Konnect and Artia New Zealand, GHL (NZ), NZ Plank Hire, and Nubco
[12318] These businesses supply a range of fastening systems, cabinet hardware systems, fencing, scaffolding, and industrial and construction products through a network of 49 branches in Australia and 20 branches in New Zealand
[12318] Customers are in the industrial, manufacturing, construction, infrastructure, agriculture and mining sectors
[12318] b) Fluid Systems comprises Cooper Fluid Systems, Torque Industries, H.I.S
[12318] Hose and Fluid Power Services
[12318] These businesses design, manufacture and sell hydraulic, lubrication, fire suppression and refuelling systems and products through 15 branches in Australia
[12318] Customers are in the mining, manufacturing, defence, recycling and agriculture sectors
[14781] If remediation is required involving a supplier relationship, the Group will work with the supplier to reinforce our standards
[14781] We commit to considering termination of a supplier relationship where we are concerned by ongoing breaches or un-remedied behaviour in relation to modern slavery
[14781] The Group Whistleblower Policy is available to all staff for our Group
[14781] We encourage employees to report any concerns and raise grievances, including regarding a risk of
[14781] modern slavery practices
[14781] We are committed to acting on any concerns regarding modern slavery practices raised by our employees
[14781] We continue to identify areas for modern slavery training for staff
[14781] Our Executive team and Financial Controllers have received specialised training on how to identify risks of modern slavery and what to do if employees have concerns that these activities are taking place
[8960] Worldline is also committed to comply with local conventions and legislations devoted to Human Rights
[8960] If these local conventions and/or legislation are more stringent, they shall prevail
[8960] The policy covers both employment practices and social impacts
[8960] Regarding the employment practices, several pillars have been identified
[8960] Prevention of child labour/minimum age worker Worldline ensures that no child labour is used at any of Worldlines facilities
[8960] Worldline entities must comply with the minimum age defined in the legislation of each country
[8960] Suppliers are evaluated on their CSR performance to ensure that they respect these commitments and in some cases are subject to onsite audits to verify compliance
[8960] Forced/bonded/compulsory labour Worldline ensures that none of its employees may be compelled to work through force or intimidation of any form (this can include bonded labour, debt bondage, forced prison labour, slavery, servitude, or human trafficking), or as a means of political coercion or as punishment for holding or expressing political views
[12318] The supply chains for these businesses include trading stock and manufacturing inputs that are sourced widely within Australia and New Zealand (c
[12318] %) and overseas (c
[12318] %) from countries including China, United States and Taiwan
[12318] Staff are employed across all states and territories of Australia and in New Zealand and services are procured for a variety of operational needs including, but not limited to, information technology, marketing, freight, travel, rent and building maintenance
[12318] Identifying and addressing risk Employees
[12318] Coventry takes its employment compliance obligations seriously
[12318] Coventry has robust policies and processes in place to ensure compliance with all legislation and industrial instruments
[12318] Our staff in Australia are covered by a combination of Federal Awards, the National Employment Standards and the Fair Work Act
[14781] Members of our Compliance Team have attended information sessions on consultations led by the Ministry of Business, Innovation and Employment on potential modern slavery legislation in New Zealand
[14781] Our Compliance Manager has undertaken external study through Certified Anti-Money Laundering Specialists (ACAMS) on Modern Slavery
[14781] All staff are trained in DPL Insurance on Modern Slavery as well as our Group Whistleblower Policy
[14781] In FY24 we plan to introduce an internal online modern slavery training module for all staff
[14781] Key Areas of Action 2023 - 2024
[14781] We have made progress against our key action areas and continue to identify further areas of focus in order to strengthen our measures and prevent modern slavery in all parts of our business
[14781] Continue to identify high risk suppliers further down our supply chain ie our second tier suppliers
[14781] As above, we have begun the process of engaging further with all of our operational suppliers and have sent them our Supplier Code of Conduct
[8960] Worldline ensures that it does not use, contract, or benefit (directly or indirectly) from the use of forced labour
[8960] Through the whistleblowing alert system, it is possible for any employee to report such behaviour
[8960] Additionally, Worldline ensures that its third parties must not use forced labour as defined above
[8960] This is ensured through the Group Business Partner Management Policy
[8960] The Human Rights Policy also addresses freedom of association / collective bargaining and the right to strike, health and safety, working conditions and harsh or degrading treatment / harassment
[8960] Social impact topics are also covered, including supply chain management and anti-corruption / anti-bribery
[8960] Worldline Group Business Partner Management Policy The purpose of the Worldline Group Business Partner Management Policy is to establish a framework for an effective Business Partner management programme and to ensure that Worldline is only dealing with business partners of a certain ethical standard
[8960] The Policy documents the fundamental principles and mandatory rules for managing Business Partners from selection through to termination of the business relationship
[12318] Our staff in New Zealand are covered by New Zealand Employment Legislation
[12318] Coventry is committed to a high level of compliance with Modern Slavery legislation, including the Modern Slavery Act 2018 (Cth)
[12318] Along with this Modern Slavery Statement, Coventry has a comprehensive suite of company policies including an established Ethical Sourcing and Modern Slavery Policy, a Company Code of Conduct, a Whistleblowing Policy, and an Anti-Bribery and Corruption Policy
[12318] Page 2
[12318] The Company Code of Conduct outlines Coventrys vision and values, and encourages all Coventry employees to report any breaches of the code to senior management or the Human Resources team
[12318] All Coventry employees are regularly trained on the Company Code of Conduct and it is regularly reviewed and updated
[12318] Identifying and addressing risk Supply Chain
[12318] Coventry acknowledges that there is the potential for modern slavery in certain higher risk geographies within its supply chain
[14781] We will now look to review our intermediary broker and repairer network, as well as our second tier suppliers, such as car dealers and car groomers
[14781] We will engage with these suppliers by sending them our Supplier Code of Conduct and ensuring that we are communicating our expectations that they take appropriate actions to address modern slavery risks in their operations and supply chains