mila-ai4h/AIMS.au huggingface dataset:
[11328] We will seek further opportunities for collaboration with our suppliers, and continuous improvement of our systems and processes to assess and address the risk of modern slavery in our operations and supply chain
[10980] Define an ongoing consultation framework to utilise for ongoing statement preparation
[10162] We are refreshing our modern slavery training to ensure that it is more targeted for each of the relevant jurisdictions in which we operate The OFX Code of Conduct was updated in July 2021 The Anti-bribery and corruption policy was updated in July 2021 The global Whistleblower Policy is being updated Ensuring internal awareness of Modern Slavery is important to OFX because it is aligned to its ESG commitments and because it ensures staff are alert to and can act on any possible instances of Modern Slavery impacting our clients/vendors Assessing effectiveness We will seek feedback from key stakeholders during FY2022 to gain insight into the effectiveness of our actions and inform opportunities for improvement in future reporting periods
[11539] Industries certain industries carry an inherently higher risk of modern slavery
[11371] We remain committed to ethical business practices and to respecting human rights across our operations and our supply chain
[11293] BUSINESS STANDARDS AND POLICIES FOR MANAGING MODERN SLAVERY RISK NBN Co policies and procedures are an essential part of how the Company identifies and addresses modern slavery riskand undergo regular review
[10297] All people data in this statement are expressed as headcount, not full-time equivalents (FTE)
[11190] Processes such as screening, risk assessment and supplier due diligence both during on-boarding and ongoing are continually reviewed and strengthened to ensure they remain as effective as possible in mitigating the risk of modern slavery practices in our supply chain
[10826] Next steps in 2023 page 8 APPENDIX 1 page 9
[11858] Performance Indicator What is the outcome were seeking Highlights in 2021 2022, unless otherwise stated Strengthen human rights governance Human rights is embedded in our governance framework
[11162] Major categories of spend in FY22 included software providers; professional services (including legal, audit and financial advisors); advertising and media; and IT services
[11235] In 2021 we updated our franchise and master franchise agreements to expressly require compliance with relevant modern slavery laws and our Policy Regarding Modern Slavery Practices
[11235] We also conduct audits in connection with our Franchise Partners businesses to better assure us of their compliance with relevant employment laws
[11183] Through our centralised HR function we have identified workers from countries where exploitative practices may be used against our migrant workforce to impact their welfare
[11183] Our future plans to further mitigate the risk of trafficking, exploitation and slavery include the following
[10885] Therefore, the firm identified these staff as playing a crucial role not only in being able to educate their own teams, but also in their capacity to influence and educate suppliers and identify key areas of modern slavery risks within the firms supply chains
[10116] Arena provides training to all employees on the Anti-Bribery and Corruption Policy
[11111] Customer engagement Mondium works selectively with customers who share our values in respecting the human rights of every person involved in its operations, supply chain and the communities in which it operates
[11466] On our request, suppliers are required to provide evidence of its compliance with illions Supplier Code of Conduct and anti-modern slavery laws
[11190] Modern Slavery Statement 2022 4 We strive at all times to be a bank for good, for those who do good
[12013] BSCI (Business Social Compliance Initiative) Following both external and internal risk assessments, suppliers are assigned a risk rating of High, Medium, or Low
[10312] Overview 4 2.1 Update on commitments from FY2021 5
[12013] In addition to Lovisa Holdings Limited, Lovisa Australia Pty Ltd and Lovisa Pty Ltd are also considered reporting entities under the Act
[11881] Modern Slavery Mitigation Pillars
[10312] The majority of Link Groups workforce is based in Australia (44%), followed by the UK (20%), India (23%) and Ireland (8%)
[10297] See the Supplier onboarding, due diligence and ongoing monitoring section above, on page 27, for further details
[11403] The investment strategy of the Trust is to invest in directly originated loans and other associated debt instruments, designed to broadly reflect the Australian corporate loan market being diversified by industry sector with a credit risk spectrum from A to BB
[10598] The process of consultation has included the engagement of the Executive Management Team, team members with important procurement responsibilities and the Beacon Lighting Group Board of Directors
[10826] Further analysis of Foricos supply chain has identified that most of the procurement spend is local, that is in Tasmania (Australia) suggesting a significant reduction in the risk to Modern Slavery within first-tier suppliers (see Figure 3 - Forico operations supplier profile FY2022)
[11111] Mondium Modern Slavery Statement 2022 | Page 5 Identifying risks of modern slavery Operations The majority of Mondiums employees and seconded parent company personnel are employed directly and under permanent, fixed-term, part-time or casual contracts or under enterprise bargaining agreements, which significantly lowers the risk of modern slavery
[11858] Reflect on how we raise awareness at each important touchpoint in the stakeholder lifecycle of Directors, employees, volunteers, community partners and suppliers
[11111] During the year, we continued our focus on identifying and addressing potential modern slavery risks within our direct supply chain
[10407] New contractual provisions have been developed and deployed to monitor modern slavery risks of suppliers and their supply chains and require adherence to modern slavery laws as well as training on modern slavery
[10514] The objective of the Modern Slavery Act to address modern slavery risks in business operations and supply chains aligns with the fundamental vision and purpose of CoAct - to create a future where everyone can reach their potential through meaningful, sustained employment
[10828] It is part of the Department of Infrastructure, Transport, Regional Development, Communications and the Arts Portfolio of the Australian Government
[11328] <50 50 - 250 >250 Number of factories: High Australia & New Zealand South East Asia Bangladesh and India China, Hong Kong and Taiwan United States of America South Africa Western Europe Mexico Eastern Europe Medium Low Risk level: Japan South Korea RISK LEVEL: HIGH MEDIUM LOW INDICATIVE NUMBER OF SUPPLIER LOCATIONS: >250 50 to 250 <50 MEDIUM AND LOW HIGH AND MEDIUM
[11881] Debt bondage
[11424] Our Regional Network and Freight team provides rail access for freight operators and other Queensland Rail supply chain customers to enable the critical transport of resources and general freight across the state
[11212] Ensure reasonable working hours and wages
[11725] Wingate has assessed the risks of modern slavery in its products, services and supply chains as very low
[10069] The policies, processes and procedures in place to mitigate or respond to modern slavery related risks The results of our Supplier Modern Slavery Risk Assessment survey form the basis of the following actions for our business
[10733] Continued improvement year on year in our procurement process that records our modern slavery investigations and new review processes as contracts are entered
[11858] The article is titled protecting people with communication disability from modern slavery: supporting SDG8 and SDG16; it addresses and builds upon existing scholarship in this field, highlighting the need to ensure that information about modern slavery is accessible to people with communication disability as well as exploring approaches for addressing health inequalities of victim-survivors of modern slavery including advocacy and rights-based approaches
[10885] Our key priorities for the next reporting period are: Continued training: We will design and implement mandatory online e-module training for staff to continue educating our people on modern slavery risks, and to support them in identifying, preventing and mitigating modern slavery risks in Maddocks business and supply chains
[11858] Human Rights and Modern Slavery Committee The Group General Counsel and Group Company Secretary has a dual reporting line and reports to the CEO and Board through the Board Chair and chairs our Human Rights and Modern Slavery Committee
[10297] This included providing the directors of those Telstra Group entities with information about Telstras obligations under the modern slavery legislation and our reporting process
[12075] The Modern Slavery Working Group has consulted with those responsible for the imple- mentation of our human rights and modern slavery program, including regional People and Culture leaders and the Taskforce, regarding the operation of the Modern Slavery framework as well as in the development of this Modern Slavery Statement
[10969] Iron/metals
[10084] This action has been updatedforFY23 to focus on a more specific section ofourworkforcefirst see page 11 Identify and remediate/eliminate risks regarding recruitment practices of third-party labour providers inWebjets operations and supplychains
[10700] In FY22, we continued to monitor and consolidate items of safety clothing and PPE, further reducing the number of brand manufacturers we have on our approved range by 25%
[11858] SDG 8 articulates and addresses the human right to just and favourable working conditions and to be paid fairly and equally
[10312] Employees
[10980] The SPIP will serve to practically embed an enhanced focus on risks to people across relevant business functions through procurement activity
[10235] Operating at the intersection of sports science and analytics, Catapult products are designed to optimize performance, avoid injury, and quantify return to play
[10786] This has been taken into consideration when performing our risk assessment and gap analysis
[10762] Given the international nature of our operations, there are suppliers operating within different geographical and regulatory environments
[10762] Our Communication on Progress describes our ongoing commitment to these principles and our 2022 Sustainability Report further demonstrates how we are advancing our sustainability programme, including the UNGC principles at our airline
[10116] Q DIRECTLY LINKED: Businesses can be directly linked to modern slavery where they are connected to modern slavery by the actions of another entity they have a business relationship with, such as a supplier, through their products, services or operations
[10069] Introduced KPIs to measure the implementation of actions taken to address modern slavery risks Further to this, in the coming 12-18 months, DFP will
[10980] Modern slavery risk inour operations This section details content to partially satisfy mandatory criteria 1(c) and 1(d) under section 16 of the Act
[11706] However, in the coming years Codan will progressively improve its processes to increase its capability to detect these forms of Modern Slavery in its global supply chain
[12075] Review and enhance modern slavery training programs currently in place We recognise we have continuous work to do to identify and manage the risk of modern slavery in our organisation and supply chains
[11190] To assist our Members experiencing vulnerability, we provided practical financial support
[11355] With these challenges in mind, the Ethical Sourcing Team devised a 12-month phased approach whereby every quarter each brand/ department would onboard selected factories starting with sites with the highest spend and working to onboard the remaining factories in subsequent periods
[10312] The UN Guiding Principles sets out the concepts of may cause, may contribute to, and may be directly linked to modern slavery practices or the potential risks of modern slavery practices within Link Groups supply chain
[11212] Continue to support suppliers and business partners to assess and address modern slavery risks and take action to improve transparency, traceability and accountability for modern slavery practices and impacts in our supply chain
[10162] This includes linkages to modern slavery through entities that may use our financial services to launder money derived from modern slavery, such as child exploitation
[10598] All Beacon Lighting Group entities operate under a common set of governance policies, programs and management
[11706] Debt bondage
[11552] Criterion 3: Description of risks of modern slavery practices in the operations and supply chains of the reporting entity and any entities it owns or controls
[10786] Our vision is to build great communities Sarah Constructions Hindmarsh Plumbing Page 7 Sarah Group | Modern Slavery Statement 2022 Page 6 Sarah Group | Modern Slavery Statement 2022
[11459] Technology: such as the IT hardware and software and print services that support WPPLs business; and Travel services: organising and booking travel and accommodation requirements
[11852] The statement has been prepared in consultation with the relevant companies that we own or control and was approved by the Board of St.LukesHealth on 14th December 2022
[11881] We recognise that we are only part way through our journey
[10315] To date Hyland has not been made aware of any human trafficking or slavery activities within Hylands supply chain
[11235] In particular, we have identified the sourcing of green coffee beans by our coffee business from upstream sources that originate in countries such as Brazil, Colombia, Indonesia and Ethiopia, as carrying a heightened risk in connection with modern slavery practices having regard to their geographic regions and socio-economic factors, both of which may facilitate or incentivise those practices
[11401] The framework elevates the ability of our people to approach and resolve workplace issues and encourages on-hire staff to raise any issues of concern, be they internal or client related
[10885] The Supplier Code sets out the firms expectations of suppliers in relation to modern slavery, as well as ethical, human and labour rights, health and safety and environmental standards
[10980] Floreat Kensington IOMRC Watermans Bay and Crawley
[11659] Este Lauder (including Estee Lauder AU) also looks for ways to strengthen our Supplier Code controls and systems and revise and update it as needed
[11659] The Supplier Code is based on internationally recognised standards including the Universal Declaration of Human Rights and International Labor Organizations Conventions
[11212] Review corporate credit card and expense claim policy to ensure alignment with Modern Slavery Policy and Supplier Code of Conduct
[11149] Each of these entities are involved in the Victorian thoroughbred racing industry media supply chain
[11881] All fees associated with the recruitment of staff through third parties are covered exclusively by LAL
[9617] PARTIALLY COMPLETE: The Modern Slavery Policy approved by Council in December 2021
[11328] Supplier Ethical Sourcing Inherent Risk Assessment Level 3 Level 1 Level 2 SUPPLIER ETHICAL SOURCING INHERENT RISK ASSESSMENT SUPPLIER ETHICAL SOURCING SELF-ASSESSMENT SUPPLIER SOCIAL COMPLIANCE AUDIT Level 1 Level 2 Level 3 A suppliers inherent risk is based on specific characteristics associated with their operations, including country, sector and the products being manufactured
[11190] Policies and processes which outline our expectations include: POLICY / PROCESS DOCUMENT PURPOSE AML CTF Program Sets out how we comply with our legislative obligations for anti-money laundering and counter-terrorism financing
[11526] We will be exploring the possibility of incorporating quantitative metrics into our overall toolkit for managing modern slavery and broader ESG related risks on a long-term basis
[11858] Countries and regions suppliers indicated they source goods from
[10969] Continued improvement in understanding our modern slavery risks
[10116] % of tenant partners who participated in the survey indicated they were interested in collaborating with Arena in relation to modern slavery risks
[10084] Servitude N/A Servitude, while considered a form of modern slavery, wasnot identified as a material risk to our operations or supply chain
[11539] analyse data to look for trends and systemic issues allowing us to identify and implement controls to enhance our reporting capability and thereby better manage modern slavery risk in our supply chain, including improved and more informed supplier selection
[11890] Such items include uniforms, gloves, protective glasses, protective hats and ear plugs
[11881] These business relationships also increase the likelihood of being directly linked to forced labour through the providers supply chains - such as cleaners, and security
[10301] Process of consultation There are no subsidiaries or entities owned or controlled by the Trust with which the RE is required to consult with to prepare this Statement
[11828] (On 23 November 2022 BSA announced that it had signed a conditional agreement to sell its APS Maintain business to CBRE Group Inc with completion of the sale expected by 28 February 2023); and 2 Communications and Utility Infrastructure (CUI): providing - on a national basis strategic advice, design, implementation, operations and maintenance services, specialising in telecommunications networks and technologies
[12013] Our employment framework complies with the Australian jurisdiction laws
[11539] Grant Thornton Australia has access to the expertise of fellow Grant Thornton professionals in over 135 countries
[11202] We have created an interconnected, shared purpose and a strong operating philosophy that guides the actions of our leadership and colleagues worldwide
[11190] Today, Teachers Mutual Bank Limited is one of Australias largest mutual banks with more than 230,000 members and over $10 billion in assets supporting five divisions: Teachers Mutual Bank, UniBank, Firefighters Mutual Bank, Health Professionals Bank and Hiver, that provide financial services to essential workers in the education, emergency services, and healthcare sectors
[11430] Modern slavery describes serious forms of human exploitation and takes many forms including: trafficking in persons; slavery; servitude; forced marriage; forced labour; debt bondage; deceptive recruiting for labour or services and the worst forms of child labour
[11328] Once completed, we will request copies of these reports to determine whether any potential risks relating to forced labour exist, and the adequacy of any corrective actions that may be undertaken
[10949] Both as an employer and as a business acquiring products and services, Device Technologies does not tolerate any form of exploitation through slavery, servitude, any type of forced or compulsory labour or human trafficking
[10069] Modern Awards and interpretation rules applied as a minimum Timesheets recorded Detailed payslips provided Payroll independently audited by external Accountancy firm
[11077] VGW Group contractors in Romania are engaged by an external third party based in Romania
[11212] All policies and procedures are published through our document management system which is available to all employees, who are alerted to relevant amendments and updates to policies and procedures
[11328] Case Study: Private Label Factory Analysis (cont.) 10A total of 41 SAQs received, comprising 20 at a head office level, and 21 at a factory level Key areas of Ethical Sourcing Policy non-compliance identified through social compliance auditing 32 33 Self-Assessment Questionnaire - Thematic Analysis In addition to providing information on factory demographics, the SAQ results for our private label supply chain also provide us with information relating to
[10969] Reinforcement of internal training for the understanding and identification of modern slavery risks; and
[11162] Building and facilities services comprising cleaning, grounds maintenance and security
[11881] We were quick to convene a crisis management team who met on a regular basis to adapt our responses to the pandemic, including revised work instructions to ensure the safe continuous operations of our essential transport services
[10312] Leverage the results of the third party assessment of the investment portfolios for which Link Groups Fund Solutions businesses act as manager, and either engage with the investee companies or increase due diligence process where feasible to better understand modern slavery risks associated with its funds financial investments
[11235] Weve recognised that our initial approach to assessing modern slavery risks amongst our supply partners (which included dissemination of a targeted questionnaire) was inefficient, and (as indicated above), in order to evolve and strengthen our knowledge of, and response to, potential modern slavery risks within our supply chain, in 2022 we procured membership of SEDEX, one of the worlds largest online platforms for the collection and sharing of ethical supply chain information
[10885] All new staff are now required to read and confirm they have understood the firms Anti Modern Slavery Policy in our induction training program
[10837] Processes of consultation with reporting entities ARPC does not own or control any other entities
[10060] Suppliers or their contractors engage labour
[10301] Actions taken An assessment to assess the inherent modern slavery risk in the Trusts supply chain has been conducted
[10084] see page 12 Continuously assess the effectiveness ofour actions toensure that we learn, and incorporate improvements in detection and remediation/elimination of Modern Slavery andHuman Trafficking risks
[10837] ARPC is located in Sydney and employed 35 staff as at 30 June 2022
[11162] seven resorts in Victoria and Queensland, two RACV Club and leisure facilities in Victoria, and a hotel in Hobart
[11235] Marketing related services Uniform Providers
[11881] Monitoring internal compliance
[10103] TAP recognises the need to continually assess the effectiveness of actions taken, and pledges to act upon any information suggesting improper action within the supply chain or inadequate due diligence
[10312] The assessment utilised the third partys
[11526] It does not account for variances at the entity, region or product level
[10885] Attendees included members from Business, Communications and Marketing, People and Culture, Facilities and our Finance Department
[11235] Establishing and maintaining the supply chain which services their licensed territory with goods or services necessary to enable the proper and efficient operation of retail outlets consistent with our brand system standards; and
[10297] Our KYS portal was rolled out in FY22
[11017] Human Rights: Public officials should respect and promote the human rights set out in the Charter of Human Rights and Responsibilities by: (i) making decisions and providing advice consistent with human rights; and (ii) actively implementing, promoting and supporting human rights
[10069] Direct and frequent contact with workers on third party worksites
[11111] The review indicated that the Companys processes and controls were operating effectively and no adverse findings were identified
[10312] Link Group is also committed to continuously improving its processes and policies with respect to the identification and elimination of modern slavery
[10786] We demonstrate empathy, fairness and humility
[9758] WAFFinancePtyLtd Australia 100 WuraResourcesPtyLtdSARL BurkinaFaso 100 WestAfricanResourcesDevelopmentSARL BurkinaFaso 100 ChannelResourcesLtd Canada 100 VoltaIILtd1 CaymanIslands 100 Indirectsubsidiaries
[11111] Mondium employment contracts meet or exceed the applicable employment legislation in the geographies in which we operate
[10301] As at 30 June 2021, the Trusts assets under management was approximately $457.1 million
[11293] Remediate where required
[11235] Pre-screen our purchasing categories based on commodity/location and brand (inherent risk) in order to prioritise onboarding at relevant tier levels