mila-ai4h/AIMS.au huggingface dataset:
[8142] The risk and compliance team have been consulted to undertake risk assessments of suppliers and supplier categories
[10217] b) Corporate Procurement Policy, due diligence and tendering process The Corporate Procurement Policy is designed to guide the procurement of goods and services with processes underpinned by fairness, accountability and transparency
[10197] our procedures in place to reduce these risks
[10756] We have continued to use this analysis in this reporting year as the nature of our business and supplier base has not significantly changed
[11330] WHERE WE OPERATE
[11691] In that context, Perpetuals third Modern Slavery Statement sets out the actions we are taking to address modern slavery risks across our business
[10197] The countries and regions we source from may have a higher risk of Modern Slavery due to factors such as culture or the enforcement of legislation
[10099] Fudheri nf ormat i on on sMBC Group sust ai nabl e procurement pol i cy can be accessed at : h S11WWW
[10217] Monitor SpeakUp Line statistics and ensure that compliance reports are investigated and appropriate corrective actions are implemented
[2345] Processes: Processes were updated to include modern slavery considerations when on-boarding and managing suppliers including contract obligations
[2450] We adopted a risk- based approach in our modern slavery due diligence, by applying risk factors such as sector, industry, types of products and services and geographic locations
[850] Our Communication on Progress describes our efforts to implement the ten principles of the UNGC
[1289] David Martin Chairman
[2574] In view of the low risk of any modern slavery practices occurring, the effectiveness of Sumos actions cannot suitably be assessed by tracking actual identification and remediation of such practices
[16] We aim to be a company that exceeds international standards by responding not only to the expectations of all our stakeholders but also to the expectations of society as a whole
[872] In 2019, the Group worked with 9,000 suppliers globally, with the majority of our annual $12.5bn supplier spend occurring with our first-tier suppliers located in Australia, followedby the United States, Singapore and New Zealand
[3618] identify labour rights risk, including modern slavery
[6029] Cargill also expects our Suppliers to stand with us in prioritising the safety, well-being, and dignity of all individuals whose talents and hard work help us deliver our products and services
[6062] This helped us continually adapt our strategy, proactively meet everyones needs and support their ongoing health and wellbeing
[4817] The registered office for both entities is Level 5, 35 Boundary St, South Brisbane, QLD 4101
[6794] Modern slavery risks in our supply chains and operations Modern slavery describes situations where coercion, threats or deception are used to exploit victims and undermine or deprive them of their freedom.9 The MSA defines modern slavery as including eight forms of serious exploitation, which are explained in Appendix 2
[4817] The operation of the entities required to report are closely aligned and fall under the responsibility of the same team of senior management (the Executive Committee) and substantially similar Board composition
[6717] Procurement has overall responsibility for setting AGLs approach to procurement and developing related policies and procedures
[5833] In response to the pandemic, Nextracker undertook the following steps to ensure our ongoing commitment to mitigating modern slavery and ensuring our employee's welfare: Nextracker shifted its staff to work from home, attempting to ensure ongoing continuity of our operations and ensuring the safety of our staff; Nextracker has since started our Return to Work program that allows employees to voluntarily return to the office while ensuring the safety of our staff; and Our response to COVID-19 has allowed Nextracker to continue operations and retain staff without exposing our employees to risky labor practices
[6717] These policies are underpinned by our Purpose, Progress for Life, and our Values, which are summarised below: Our Values
[7515] To address these risks, we are continuing to engage with our suppliers in India through both the performance of external social auditing and ensuring that through our onboarding process the mitigation of modern slavery risks are addressed
[7418] More recently as a result of the acquisition of the Primero Group, we started operating, to a limited extent, in Canada and in the United States of America
[8011] CAG is a leading provider of sustainable pavement construction and maintenance solutions across Australia
[7287] With both China and Asia identified as high-risk geographical locations for modern slavery and human trafficking, there is a potential risk of the company being linked and contributing to modern slavery
[8158] The results of any formal investigation into misconduct will be recorded in writing in a formal internal report that will be confidential and is the property of the Company
[7515] We will be undertaking further due diligence on our cleaning suppliers throughout the next reporting period
[8546] This category is assessed as having an elevated risk because of common practices within the sector, including heavy reliance on labour hire agencies, outsourcing, lower skilled work, lower paid contracts and migrant labourers
[7515] Background and Detail All Australian entities with at least A$100 million annual consolidated revenue must comply with the Modern Slavery Act 2018 (Cth) (Act)
[11691] Cotton, palm oil, thread, mica, zinc, electronics, rubber gloves, cobalt ore, tinore, garments, textiles, fluorspar (mineral)
[10522] To meet the surging demands of COVID-19 testing, our businesses often needed to rapidly upscale operational capabilities by employing additional staff in relatively short time periods, either directly or via labour hire firms
[10321] In doing so, we looked at the risk that our: (a) operations may directly result in modern slavery practices; (b) operations and/or actions in our supply chains contribute to modern slavery; and (c) operations, products or services are connected to modern slavery through the activities of another entity, including business partners
[10349] As we cannot address all potential risks at once, the map below helps us to prioritise and create a staged approach
[10217] NMA also sources replacement parts and accessories for Nissan vehicles from overseas suppliers, some of which are Nissan affiliated entities and others are independent third party manufacturers
[9952] Although modern slavery risks are considered to be greatest in sectors such as cleaning, hospitality, agriculture, textiles production and some types of manufacturing,6 the mining industry has an inherent risk of modern slavery, particularly due to the reliance on imported equipment and products
[11691] Once theyhave been flagged, the decision tree sets out several optionsfor engagement, which starts with discussing the riskprofile with the vendor management team or investment portfolio manager
[11514] Forced labour
[3721] We are committed to acting ethically in all of our operations and continually evolving how we can address important ESG considerations in our investment approach
[2182] The figure below provides an overview of our banking supply chain based on our first- tier industries being; (1) finance and investment services, (2) property services; and (3) computer/technical services
[2306] Provide an annual modern slavery statement outlining how modern slavery risk has been assessed and our approach for future management
[1030] Traffic management
[1512] Page 5
[2302] IDENTIFYING OUR RISKS Peter Macs Procurement Team has developed an initial risk assessment tool for use by the team in its direct procurement activities, to assist in identifying specific risks across the four areas of concerns
[2728] Kimberly Williams, Chair
[2574] The Statement has been approved by the Sumo Australia Limited Board of Directors
[6717] Assets owned by Powering Australian Renewables (PowAR)
[4817] Lactalis Australia 16 Modern Slavery Statement POLICIES At Lactalis Australia we are committed to the development of a zero harm philosophy throughout our business operations
[5765] Avant Mutual Group Limited is an organisation owned by its members and run purely for their benefit
[6794] As an extended measure of assurance, we partner with forensic science organisation, Oritain, to conduct origin fingerprint testing to scientifically verify selected wool and cotton fibres to the country-of-origin of Australia
[6020] About Ansell continued Ansell Limited Modern Slavery Statement 2021 09
[4709] Ethics Reporting / Whistleblower Hotline and Whistleblower Protections CCL Industries Ethics Hotline - Global Compliance is the third party operator of CCLs Ethics Hotline
[5758] All employees are regularly trained to detect and report potential suspicious activity
[6904] US Head Office Level 7, 117 Lambton Quay Home Park, Grove Road 250 Park Avenue, 7th Floor Wellington, New Zealand 6011 Bladon, Oxfordshire OX20 1FX Manhattan, NY 10177
[8128] Reporting Entity
[8718] Risks and Controls below
[9029] Mitigating and remediating risks of modern slavery Adjustments made to GSS audit protocol due to COVID-19 Throughout the COVID-19 pandemic, we have endeavoured to maintain our audit program wherever possible (subject to government restrictions and mandates) and have considered advice from third-party auditors, using different ways of working such as remote and virtual remediation testing procedures, where required
[7084] During the process of drafting this statement the Group engaged with all parties to clearly outlined its values, policies, and strategies as well as requirements under the Modern Slavery Act 2018
[7885] Beauty products
[8079] In addition, Credit Suisse is a member of the Wolfsberg Group, which aims to develop financial services industry standards for policies on preventing money laundering and terrorist financing, which are often associated with modern slavery and human trafficking
[8079] reporting unusual incidents and misconduct (including whistleblowing)
[9541] The risk of mistreatment of minorities and modern slavery In 2021, we continued to see concerns related to the potential mistreatment of ethnic and other minorities
[10987] Nukon Pty Ltd specialises in software and systems engineering, developing products and delivering high-end digital solutions that increase operational efficiency, service level, quality and other business outcomes
[10349] The risk map below summarises potential risksacross our activities and spend over FY22
[11787] Anoverviewoftheclassificationofthefirsttierofoursupplychainbycountry andindustry,includingrelativemodernslaveryrisk
[11241] - Communicate its Supplier Code of Conduct to all its suppliers
[10321] Supply Chain Management Code of Conduct (Australia) At Collins Foods we are committed to conducting our business in an ethical, legal and socially responsible manner
[11702] They are procured on the following basis
[9729] Kathmandu and AAT agreed to communicate openly and transparently and find a solution that protects and respects the dignity of the victims, in recognition that they will be better protected by the two organisations working collaboratively together
[11150] Due Diligence & Assurance Due Diligence QAL has identified effective due diligence as a central element of the Modern Slavery Improvement Program
[1445] *The Bulgarian business is a branch of Reward Gateway UK (Ltd), and therefore shares the same company number
[2313] We believe collaboration with all stakeholders across industry, government and non-governmental organisations is of critical importance to assessing and addressing the risks of modern slavery
[1758] Completed Suppliers Policies Purpose: Operations and Execution of Corporate Strategy (includes investments and acquisition) Status Scope Community & Sustainability Policy Outlines our commitment to the United Nations Sustainable Development Goals and how these are considered in our strategy and operations
[2517] Utilities consists of costs of gas, electricity, water and related costs at each production facility
[1471] Moving forward, the Bids and Tenders unit will introduce the SAQ to this process
[1445] Modern Slavery and Human Trafficking Statement | 2020/2021
[1541] Mr Brian Lowe commenced as Managing Director and Chief Executive Officer on 1 October 2019, having led both the Australasian Beverage and Fibre Packaging businesses since joining the Company in 2011
[452] % of employees completed the training which was designed to provide employees with a clear understanding of what modern slavery is, how to identify it and the process for managing suspected cases
[6519] United Kingdom
[5953] This has resulted in a response rate of 94% as at 30 June 2021 (and at the time of drafting this Statement the response rate has increased)
[6371] Volvo Car Group manages the procurement of products and services from third parties connected to the manufacturing and distribution of Volvo Car products, which end up for sale to consumers in Australia
[4689] Develop wider engagement through shared knowledge, training and transparency across our supply chain and operational businessunits
[6794] All of these policies and processes are communicated to our staff at employee inductions, through our intranet and social workplace platforms and through communications at Governance Week
[4432] Building facilities management
[5476] Vendor-branded products are bound by our Responsible Sourcing Policy, and in fresh categories many are captured by compliance activities
[4451] Each of these risks has been assessed, and risk mitigation strategies put in place
[7375] As part of the support structure we provide our workforce, all team members are offered, and have available to them, a number of programs including
[9266] See our Position on Resolving Employee Grievances
[8718] DocuSign Envelope ID: 780B409E-DF8F-489B-A792-806C8512DFE1
[6987] Following on from the completion of the modern slavery risk assessment, an Action Plan focusing on six key areas has been developed, which has been endorsed by the Audit and Risk Committee, that will guide the direction, resource allocation and progress in risk mitigation
[7105] Our Operations The Fund is distributed to the public through the Fiducian Superannuation Service (the Service), which is a public offer superannuation fund
[7367] Sustainable sourcing practices, including consideration of human rights issues, are critical to Pacific Nationals ESG performance
[7375] All have confirmed that their workers
[7213] Describe the process of consultation with any entities that the reporting entity owns or controls (a joint statement must also describe consultation with the entity giving the statement) N/A Provide any other relevant information Introduction (pg
[11234] Australias Modern Slavery Act 2018 (Cth) requires Australian and Australia-based organisations with more than AUD$100 million in annual revenue to report on the risks of modern slavery in their operations and supply chains and actions taken to address those risks
[10157] We recognise that as an ASX100 company we must take action to address modern slavery risks; not only because it is expected of us legally and ethically but because it is the right thing to do
[10245] Corval Groups Responsible Sourcing Program guides our purchasing decisions and embeds risk management principles to assist in mitigating human rights and modern slavery risks in our supply chains
[10712] Factory Visits Due to travel restrictions imposed as a result of COVID, it was not possible for ADA personnel to visit overseas suppliers factories and conduct inspections for the current reporting period
[10522] For a list of the Sonic operating subsidiaries covered by this Statement, please refer to Note 30 in Sonics Annual Report 2022, available at www.sonichealthcare.com/annual-reports Sonic Healthcare acknowledges the Traditional Owners of Country throughout Australia
[10522] Sonics global operations include more than 150 operating subsidiaries across nine divisions
[11150] QAL utilises strategic level internal controls which apply across all airports, with operational level internal controls, as appropriate and required, for each airport
[11573] Audit & Risk Committee Oversees CH2s internal audit and controls
[2306] Established a modern slavery risk assessment framework and applied it across our entire investment portfolio
[3618] What is the Victorian Governments position? The State believes that all workers in its supply chain deserve to be treated with dignity and respect
[3325] We believe in, and respect, the power of diverse perspectives
[3197] prepared in the correct form for the Minister to approve
[1030] Where Western Power is unable to find a suitably qualified local candidate, Western Power may look to engage a migrant worker
[1541] Facilities management (including cleaning) - carries a higher risk of modern slavery, including in Australasia, due to low-skilled, low-paid, manual work and the high prevalence of short-term, seasonal and migrant workers and subcontractors
[2036] Board Formally delegates certain functions to Board Committees and to management via the formal Board and Committee Charters
[2583] MODERN SLAVERY STATEMENT | 2021 ASSESSMENT APPROACH The following approach was taken to scope HCF Groups modern slavery risks
[6383] The Companys principal place of business and registered office is 7 London Circuit, Canberra, ACT 2601
[6062] Our major categories of spend include
[6427] Internal business units including Procurement, Legal, People and Culture, and the Company Secretariat were also consulted and worked to incorporate modern slavery awareness into training and their ongoing organisational processes
[5878] Depending on the outcome of the initial risk assessment, external due diligence may be sought to help inform any decision to either entering into or declining the knowledge sharing activity
[6717] Accordingly, workers may be subject to forced labour or child labour
[4689] The 2020 Perth Festival closed just prior to the state lockdown in response to the COVID-19 pandemic
[6347] Zoetis remains bound by these above ethical policies and resources comprising the global Corporate Compliance Program in addition to its own domestic efforts to assess and address modern slavery risks
[4260] Commitment to Modern Slavery At Columbus we recognise the responsibility that we have as a commercial organisation to prevent and combat modern slavery in our business and the supply chains we participate in
[7418] the Australian Border Forces Modern Slavery Act Supplementary Guidance: Reporting Entities Signature of a Responsible Member; and
[9266] Working with suppliers to check how they are progressing any actions they have put in place to address modern slavery risks to ensure they are compliant with Johnson & Johnsons RSS; and
[9541] We conducted 64 in-depth CR audits (24 in 2020) at 28 supplier sites (24 in 2020), and 339 (340 in 2020) suppliers were assessed using EcoVadis scorecards
[9541] Freedom of association and
[8131] The abundance of frequent short-term engagements, across multiple sites, often with small sized businesses, provides a challenge to facilitating a collaborative approach to risk management
[8079] This statement has been prepared as a joint statement
[7515] Modern slavery concerns continue to be at the forefront of all of our governance decisions
[7504] The fund manager utilises three unrelated, specialist third party providers of ESG data analysis as part of its investment screening process and applies several Labour Rights screens to our investment portfolio
[10321] This system allows criteria to be developed into a workflow management system which can then assess risk and accountability and generate corrective actions where required
[10870] Falcon Mining Pty Ltd ACN 099 182 368, which provides underground coal mining services
[10522] Dr Colin Goldschmidt CEO Sonic Healthcare 9 November 2022 As a global healthcare organisation with diverse supply chains and operations, we take our obligations to protect human rights seriously
[10794] Transport industry participants We also added a module to our online Security training which is undertaken by all team members contracted directly with Virgin Australia, to provide our workforce with a basic understanding of what modern slavery is, how to identify modern slavery and the internal reporting mechanism to use when risks are identified or suspected incidents occur
[11913] ACTIONS TAKEN TO ADDRESS MODERN SLAVERY RISKS
[11573] Code of Conduct
[11691] This means that an estimated 49.6 million people are in modern slavery and it is incumbent on governments, businesses and civil society to address the extremely negative impact this has on people throughout the world
[10476] The review did not reveal any evidence or indication of non-compliance with relevant labour laws and industrial instruments
[2128] Proposed Overview of Initiatives FY2021
[2306] Organisational approach to modern slavery risks
[2274] Most of our water supply comes from Warragamba Dam
[1522] This may involve the procurement of products and services from third parties
[2903] The Colleges could be contributing to this Sector based risk
[872] While both training initiatives have been temporarily suspended during the Covid-19 crisis, they will be reinstated when it is safe and suitable to do so as the Group recovers from the impacts of thecrisis
[1322] There is a limited number of approved external fund/investment managers who are considered our key suppliers in this category
[2036] This meant the modern slavery risk rating of our procurement reflects not only the generic risk of first tier suppliers, but also second and third tier suppliers that exist upstream of first tier suppliers
[6487] Further details on WestConnex roads and projects managed by the reporting entities outlined above, together with all Transurban Group roads and projects, are covered in the Transurban FY21 Corporate Report
[4505] Forced Labour and Human Trafficking - We do not accept or condone any aspect of forced or compulsory labour
[6717] In addition, employees are provided with access to an Employee Assistance Program that offers confidential phone counselling and online support for employees and their family members in relation to either work or personal problems which may be impacting their health and mental welfare
[6733] The Minderoo Foundation, 2018
[4476] WithheadquartersintheUnitedStates,wehavesimplifiedourorganizationstructureinto six(6)BusinessUnits(eachaBUandcollectively,theBUs)asfollows
[5076] Moderate Project Management Consultants Acknowledgement required of awareness and steps taken against Modern Slavery via Perkins Modern Slavery questionnaire
[5468] FOUNDED 1838 CUSTODIAN OF THE MCG
[5765] Confidentiality Policy
[6970] Globes sourcing employees and suppliers are reminded annually of the Policys minimum standards and their obligations in this area, particularly in relation to policies around banning both forced and child labour along with the requirement to provide a safe workplace for all
[7968] Seasonal workers that KEW employs directly
[8127] Select Harvests conducts/reserves its rights to conduct supplier audits
[9029] These include the Fair Labor Association, the American Apparel & Footwear Association (AAFA)14 and the International Accord for Health and Safety in the Textile and Garment Industry15
[7519] ActewAGL Modern Slavery Statement 2021 Modern Slavery Statement 2021
[8604] 1,200 Asia Pacific
[7418] Material published by: Anti-Slavery Australia; Informed 365; Practical Law; Minter Ellison; Norton Rose Fulbright; and the Supply Chain Sustainability School of Australia
[9519] Governance
[10321] The Statement has been signed by a member of the Board of Collins Foods Limited on behalf of all reporting entities
[10643] Background and Purpose
[10794] Due diligence Enhancing our due diligence capabilities Improving visibility of potential risks and impacts of modern slavery across both our new and existing third-party relationships is an important element of Virgin Australias road map