mila-ai4h/AIMS.au huggingface dataset:
[1074] The GPT Group 2020 Modern Slavery Statement 13 Whistleblower Policy Our Whistleblower Policy governs the reporting of and responding to any actual or suspected instance of misconduct or an improper state of affairs (which would include breaches of laws or company standards, such as workplace matters and the Supplier Code of Conduct)
[568] Commitments sought from suppliers: Following the due diligence process, IPH conducted a risk assessment to identify Group Business external suppliers which may have a higher potential exposure to modern slavery
[2637] In our operations Despite the low risk Pacific National may be connected with modern slavery practices via its direct operations, we have taken actions during FY2020 to consider and further reduce this risk
[6375] Continue to assess risks of modern slavery across operations, investments and our supply chain to monitor known and identify additional risk areas
[5932] This policy applies to all current and former directors, officers, employees, associates and suppliers of the Group (which includes each of the Australian Reporting Entities and the UK Reporting Entities)
[6575] Westfunds operations include investment activities
[5471] A key initiative of ACT is its Global Purchasing Practices Commitments, aimed at developing a common set of purchasing practices that will support the movement towards living wages in the apparel industry
[4516] Country of operation for example, some suppliers are in countries with higher incidences of modern slavery practices than that experienced within Australia
[6006] Human Rights Principle based Certifications held by these organisations, such as National Standards for Disability Services and National Disability Insurance Scheme
[4073] During the reporting period, Iberdrola Australia did not receive any complaints or notices relating to modern slavery issues raised through any channel
[3926] Due to our pivot to home-based working during the pandemic, we were not required to procure significant amounts of personal protective equipment (PPE)
[8141] Further information about IM and the services we provide can be obtained from our website at: www.ironmountain.com.au
[8602] We are primarily based in Australia, but our suppliers span the globe
[8036] Please confirm what steps you have taken to identify and address modern slavery risks within your own organisation and supply chain by answering the questions below
[7440] Offsite interviews with workers conducted as part of audits
[9402] Modern Slavery Module The consultancy firm provides an online platform created in collaboration with an international law firm -- that has a Modern Slavery risk assessment database and tools
[7370] Training services including nationally accredited qualifications
[9088] For commodities purchased from suppliers based outside of Australia and New Zealand, we note that these commodities may have originated in countries different to that of the supplier, and that the commodity may have originated from multiple countries
[8467] We procure more than $3.8 billion of direct raw material, contract manufacturing and equipment from more than 7,800 suppliers worldwide and manage distribution through various channels to external customers
[10541] The provision of Modern Slavery training to our staff to reinforce our compliance obligations
[10997] Sydney Seafood School
[11496] During FY22, the Board completed a comprehensive review of its existing policies, including those policies relevant to the Companys modern slavery response
[10165] We have rolled out a new software platform via Robobai that is assisting in our identification of our high-risk suppliers and categories
[9753] The objective of this risk mapping is to capture operational risk exposure posed by the Group on its environment and ecosystem
[11622] Supply Chain Brennan has assessed its supply chain and overall considers there to be minor areas of risk
[10345] Infinera employees with direct responsibility for supply chain management receive training on all Infinera policies, practices, and procedures designed to ensure that Infineras supply chain is free of human trafficking and slavery, including general risk mitigation
[10466] OTHER INFORMATION Looking forward We will continue to embed the prevention of Modern Slavery into operational as well as our supplier driven processes
[1383] Kane have worked closely to provide support every step of the way during this reporting period to ensure that we are working together to understand and establish best practice on how to reduce risks of modern slavery
[2859] In assessing our overall supply chain within the definition of modern slavery and within our direct operations, the analysis concluded that our supply chain risk, overall, is low
[1600] Work Health and Safety We have policies and procedures in place to ensure the health and safety of our employees is catered for
[757] As with all office-based businesses, there is inherent risk in the IT hardware
[3650] Reviewing and updating risk related policy and governance control measures
[3367] Of this approximate 2,000 suppliers, 98% (based on their direct engagement business locations) are based in Australia with a small number based overseas in Canada, Germany, UK, Hong Kong, Ireland, Japan, New Zealand, South Korea and the USA
[1447] Vicinity Centres FY20 Modern Slavery Statement 6
[6813] Risk Assessment Results Supply Chain The REs FY21 risk assessment did not identify any high-risk critical service providers
[6214] Our Supplier Code of Conduct, which is available on our website, articulates our minimum expectations to suppliers on issues such as labour practices, human rights and modern slavery
[6837] Through our sister companies around the globe The food industry in which we operate unfortunately has many opportunities for exploitation in its supply chain, particularly around agriculture and fishery workers
[4506] We manage more than 90,000 vehicles for our customers Australia-wide
[5543] RAPHA RACING LTD MODERN SLAVERY & TRANSPARENCY IN SUPPLY CHAINS STATEMENT This statement has been published in accordance with the UK Modern Slavery Act 2015, the Australian Commonwealth Modern Slavery Act 2018, and the California Transparency in Supply Chains Act 2012
[6602] Development of a new Supplier Code of Conduct
[3926] I CPA Australia Modern Slavery Statement 2020 CPA Australia Modern Slavery Statement 2020 I 23
[8526] Our approach At Chobani, we recognise and take very seriously the risk of modern slavery in our operations and supply chain
[9232] As a result, throughout 2021, we developed a visual inspection checklist and supplier employee questionnaire
[7445] Case Study
[9533] Partnering As a leading investment solutions partner with multi-asset and multi-manager capabilities, Russell Investments leverages a broad set of relationships to exert influence and enable multiple levels of engagement
[8880] detailed discussions with internal subject matter experts
[7861] Our local operations are identified as low risk, while our offshore manufacturing program presents a higher risk
[7822] Uniting has developed an online Modern Slavery Awareness Training Module and this is currently available for all employees and volunteers to complete
[10671] the sector with which the supplier conducts business
[11326] stories from survivors of modern slavery
[12003] The proportion of Agreements containing appropriate modern slavery provisions has increased year on year
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[11326] Modern Slavery Statement 2022 15
[10977] Contract Registers
[10222] Looking more closely at the FY2022 program, the following tables outline the country of origin, category of spend and industry alignment of the 145 SAQ respondents
[3184] The Group will use the results of our risk mapping and risk assessment exercises and any potential risks identified to guide the actions we take to mitigate these risks as outlined in this section
[3494] Airbus SE Modern Slavery Statement, Year Ending 31 December 2020 Training and capacity building During 2020, the Company continued to raise awareness of human rights through communication, presentations and the promotion of its dedicated training on human rights and modern slavery which is available to all employees in four languages
[358] Commenced supply chain scoping exercise
[35] Risk Management
[2865] Through modern slavery awareness training, embedding specific contractual obligations in supplier contracts, development of a modern slavery assessment framework and supplier and joint venture engagement, Beach continued to strengthen its ability to manage and mitigate direct and indirect modern slavery risks resulting from our operations
[3027] Individuals wishing to make a complaint under the Redbubble Whistleblower Policy may report the matter to either the internal Redbubble Whistleblower Reports Officer, a designated external Whistleblower Reports Agency or to any executive, senior manager or auditor of Redbubble
[3147] All high-risk suppliers were requested to complete an internal Rivet Group Supplier Questionnaire
[3184] provide appropriate remediation where incidents of modern slavery have occurred
[5932] Among other things, these sessions emphasise the importance of partnering with the Groups suppliers and manufacturers on the eradication of modern slavery, how purchasing practices can influence supplier actions, the need to look at second tier suppliers and what to do should slavery or human trafficking be suspected
[5148] Richard Winnall 4
[4515] MODERN SLAVERY RISKS ACTIVITY POTENTIAL MODERN SLAVERY RISK AREA OPERATIONS Offices Cleaning workers Manufacturing sites Cleaning, Casual and labour hire workers
[6813] Risk assessment methodology In FY21, the RE collected information on the Trusts supply chain to include in a modern slavery risk assessment
[4322] Education In FY20, Dicker Data conducted internal training on modern slavery for members of our Executive team in sessions tailored to our business, our industry and the risk of modern slavery
[4811] We recognise the potential modern slavery risks associated with receiving donations where we have limited oversight of the sourcing arrangements and we are committed to working with our major donors moving forward to better understand their supply chains
[8132] California Transparency in Supply Chains Act This is a joint statement which has been prepared on behalf of United Malt Limited (ABN 61 140 174 189) and its subsidiaries which are also reporting entities under their respective Acts, which include: Reporting entities under the Australian Act
[7370] Commercial In Confidence Page | 2 Modern Slavery Statement Year Ended 30 June 2021
[6956] Our Management is accountable for creating and promoting a workplace culture in which compliance and ethical business conduct are fully expected and reinforced
[7590] Katrina Barry Chair of HHA and Hollard Boards December 2021
[7636] Heinemann Australia Modern Slavery Statement Page 7 / 15 To implement preventive measures such as waste reduction, circular economy and recycling in every part of the value chain
[9370] Internal risk assessment of Human Slavery Risk In 2019 CCEP conducted its first human rights risk assessment in Europe and identified nine key areas, including forced labour, posing the greatest risk to our people at work and across our value chain
[8699] This statement is made pursuant to the Australian Commonwealth Modern Day Salvery Act 2018, and sets out to identify and mitigate any form of modern day slavery that may be present within the Pon Australia Group of companies and our supply chains
[9240] The MRIO is then examined against the following international standards
[10977] Related activities Section 16(1)(g) of the Modern Slavery Act 2018 allows for reporting entities to include any other relevant information that the reporting entity thinks is relevant
[11496] Regis Resources Limited | Modern Slavery Statement 2022 14
[10191] For example: accounting, assurance and tax; advertising and marketing; contingent commercial labour; financial services; and human resource services
[11326] FY20 Established a leadership role dedicated to Sustainable Procurement
[11326] Our Code of Conduct and values articulate the behaviour expected of Directors, Senior Executives and employees
[10184] ( 4) Thi rd Part y Assessment based on a ri sk based due d i gence approach i n order t o promot e t he due di l i genFe Of Labour i n suppl y chai ns , one of our sal i ent human ri ght s i ssues, NEC i s st art i ng t o t ake a ri sk based due di l i gence approach i n accordance wi t h OECD Due Di l i gence Gui dance f or Responsi bl e Busi ness Conduct
[11109] Future Program iSelect has a number of formal and informal feedback mechanisms across its operations and works hard to create a culture where employees can share their concerns
[9894] Our commitment to human rights is part of this culture and is expressly set out in our Modern Slavery Policy
[3650] This statement covers the activities of Golden Cockerel Pty Ltd ABN 84 009 906 432
[918] Our goal is to work with our suppliers to increase our understanding of our supply chain and support informed decision making within procurement
[3845] We remain acutely aware that we have more to do, particularly to ensure the efficiency and sustainability of corrective actions
[2237] Other Activities Daracon, via Arenco, provided sponsorship for the short film Capt
[2955] It exists independently of countries abilities and/ or willingness to fulfil their own human rights obligations and it exists over and above compliance with national laws and regulations protecting human rights
[35] As part of sustainable sourcing and human rights standards, modern slavery is an important element
[2963] The data analytics tool will be used by Crown in future reporting periods to identify high risk onboarded suppliers based on the following four risk factors
[2730] As a result, COVID-19 had a minimal effect on HUB24's modern slavery risks
[5543] Outside of our product supply chain, Rapha also uses a network of non-stock suppliers, providing services such as cleaning and maintenance in our offices, distribution centres and clubhouses, and legal advice
[4848] Describe the reporting entitys structure operations and supply chains Structure and Operations section, and Campari Group Supply Chain section
[6953] P&N Management Pty Ltd ABN 24 009 198 681
[6883] Each RCC conducts an in-depth review on a regular basis of the risk profile of the relevant business unit, or of Headquarters, as the case may be, including their respective exposure to material environmental or social risks and identifies and assesses the effectiveness of mitigants for those risks
[4516] Approach Vanguards approach to Investment Stewardship includes
[4569] Some of our current key projects include building the new Sydney Football Stadium, delivering the Melbourne Metro Tunnel and Stations Project, and undertaking a major upgrade of the Bruce Highway in Queensland
[6535] This unfortunately impacted the progress of Modern Slavery updates and face-to face awareness sessions with our supply chain, however plans are underway to recommence engagement in 2020/21
[6507] One of the suppliers has improved the gender balance of the employee base for Metros contract
[9559] Alexion continues its business as a subsidiary of AstraZeneca
[6981] Due to our oversight and control of our employee arrangements and operating in the professional services industry, we subsequently assess the risks in our own operations as low, however we provide strong protections to ensure we do not cause any risks.11 Procurement and outsourcing: There are known modern slavery risks in any procurement or outsourcing of products and services
[8504] Once a subcontractor has been engaged, our team has a suite of procedures and processes which enables the project team to effectively manage subcontracted service delivery and suppliers
[9240] The vision of the Burnet Institute is to create an equitable world through better health
[9248] Our progress will be reported in our next Modern Slavery Statement
[8680] Going forward, as previously executed agreements come up for renewal, we will look to make the necessary amendments to include these enhanced contractual protections
[8680] In 2022 modern slavery content will be added to the onboarding program to inform our new employees of the key role Graymont plays in helping to eradicate modern slavery from global supply chains and how they can assist Graymont to achieve this
[9552] These procedures allowed PON to identify the geographic risks, industry risks and overall modern slavery risks, associated with its suppliers
[11396] ____________ Michael Baulch DocuSign Envelope ID: 69CE14B0-98E8-4E3F-BC26-6D9680F98C62
[11073] They offer step- by- step advice and help with
[12064] All new staff receive information relating to our whistleblowing policies and modern slavery grievance mechanisms as part of the induction process
[12064] A MESSAGE FROM OUR CEO When reviewing Cromwells FY22 Modern Slavery Statement, I was reminded of how, in our fortunate first world business environment, it could be difficult to link Cromwells actions and efforts in identifying, managing, and responding to modern slavery risk to real and tangible change
[12064] We updated part of our corporate procurement process mid-way through FY22, resulting in a small number of non-material suppliers not completing the questionnaire before formal engagement
[9753] Modern Slavery Framework Effectiveness
[10437] They support a safety net of minimum entitlements, enable flexible working arrangements and fairness at work and prevent discrimination against employees
[10668] Cleaning and Facilities Management
[918] Procurement of goods and services is performed through one-off and ongoing arrangements with suppliers
[1447] We have also worked with our suppliers to minimise staff working across multiple sites to reduce risk of COVID-19 transmission and raised awareness of governments guidance related to leave payments for staff who are required to isolate
[2924] Consultation Process During the process of developing a Modern Slavery statement, Sunny Queen has adopted a Supply Chain Analysis tool which assisted in the development of the Supplier Code of Conduct
[302] ASSESSMENT AND MITIGATION OF MODERN SLAVERY RISK Our management of Modern Slavery Risk, in our operation and supply chain, is guided by our Ethical Purchasing and Modern Slavery Policy as endorsed by the Bundaberg Brewed Drinks Board
[2739] Baptcare is in the process of updating contractual terms to give effect to this advice
[827] Our supply chains are diverse and geographically aligned to our operations in each (mainland) Australian State or Territory, encompassing SOHO and SME businesses through to medium and large, multi- national businesses
[515] This was initially conducted on a trial basis of the top 25 suppliers and has now been progressively rolled out to our vendors with contracts in place, with responses received from 170 of our key suppliers
[5702] Actions on modern slavery risks During the reporting period, Sunwater has taken the following actions
[3926] Accountants have a key role to play in supporting businesses to combat modern slavery
[5720] These meetings were typically with executive management or company boards, often with sustainability and investor relations specialists from these companies
[4916] In December 2020, DB Schenker sent Modern Slavery questionnaires and compliance forms to all Tier 2-4 DB Schenker Suppliers using the CENTRL MSA360 electronic Modern Slavery platform
[3926] Since May 2020, every tender/RFP document issued by us to potential suppliers has included at least one modern slavery question
[4175] FY2020 Modern Slavery Statement - Fresenius Medical Care Australia Pty Limited 5
[4569] Joe Barr Director and Chief Executive Officer 29 June 2021 4 Directors may serve on the boards of multiple entities within the John Holland group
[6305] The individual suppliers, investments and industries with the most elevated risk of modern slavery
[7343] (see Figure 4 - Reporting and Remediation framework approach) In this FY21 reporting period, as per our reporting and remediation framework below, those suppliers who completed their first modern slavery screening questionnaire have been assessed for their initial risk allocation whereas those suppliers that were screened in FY20 have progressed to step one and two actions
[7542] Step 4 Allocate a risk rating to each supplier
[9533] This publication provides general information only and should not be relied upon in making an investment decision
[7095] Encourages the reporting of suspected unethical, illegal, fraudulent, corrupt or dishonest conduct and shall ensure that those who promptly report may do so with confidence and without fear of intimidation, ramifications or adverse consequences
[7912] LOW A signed copy of AirRoads Modern Slavery Statement for Suppliers (**AR-HR-QF-1083)
[8880] Whistleblower Policy Ampol has a Whistleblower Policy, which establishes a framework for Ampol to comply with obligations regarding whistleblowers, including legal protections provided by law for whistleblowers
[7636] Heinemann Australias presence at Sydney International Airport now consists of eight Duty Free shops with a total floor area of around 10,000 m2
[7818] Supplier self-assessment questionnaire sent to high risk suppliers, and forms part of supplier engagement process
[10986] Actions ACTION 10: Corporate Policy Development ACTION 1: SunPork Working Group - Modern Slavery Formation of a cross-functional SunPork Working Group to set strategic goals and oversee identification and risk assessment initiatives
[9736] These suppliers purchase components for their product springs and seals from suppliers in the Asia Pacific region
[11271] Modern Slavery risk assessment In FY22, New Aim undertook high level modern slavery risk assessments of our operations and supply chains for FY20, FY21 and FY22, to inform development and implementation of these policies and processes
[11496] During the reporting period, no direct modern slavery grievances were raised via our online enquiries function on our website or our whistleblower reporting framework
[11541] The Group continually works with key suppliers to review supply agreements and suppliers statements as part of the invoicing and service level agreements in line with Noumis Modern Slavery and Anti- Human Trafficking Policy (Policy) to ensure risks in an evolving supply chain are promptly identified and addressed
[11326] The trustees of the STP Group trusts are registered in Sydney
[11192] Other significant grant and donation recipients include large philanthropic organisations focused on the wellbeing of people and our planet
[10121] Supagas Pty Limited has been directly involved in the preparation of this Statement
[2479] Typically these types of specialist roles are less vulnerable to modern slavery
[2924] These included ingredients and products such as eggs, dairy, salt, oils, vegetables and spices, as well as packaging materials such as packaging, paper, plastics and adhesives
[3845] In 2020, we continued to work with our Procurement and Quality teams
[2706] Closing statement Bairnsdale Regional Health Service is confident that the steps taken this year have built a strong foundation for a robust modern slavery framework
[2084] For further information see our 2019-20 Responsible Investment Report at sunsuper.com.au/investments/ how-we-invest/responsible-investing 2.1 Investment management Sunsuper has diversified asset portfolios that may have exposure to various asset classes including listed shares, private equity, fixed income securities, property, infrastructure, cash, currencies and derivatives
[3633] This is supported by a Risk Appetite Statement where the Boards specify and agree to the level of risk it is prepared to tolerate in a number of risk categories
[2390] To perform the risk assessment, publicly available information on modern slavery risk was applied to our procurement categories to identify high risk suppliers