mila-ai4h/AIMS.au huggingface dataset:
[991] When chartering vessels, our due diligence focuses on ethics and compliance red flags, including the countries of ownership as well as operation, the registered and beneficial owners, commercial operators, technical managers and if there are any EU, HM Treasury (UK), Office of Assets Control (OFAC) and OFAC non-SDN sanctions against these parties or the vessel in order to ensure the vessel meets our standards for quality and is operated in a manner that respects human rights
[991] We include our customers in the selection process so they may ensure the vessel meets their standards as well
[991] We continuously look to improve our processes to identify, address and prevent human rights violations, including modern slavery risks in our operations and our supply chain
[991] In pursuit of this, we issued the Sims Limited Supplier Code of Conduct to codify our expectations for the business conduct of our suppliers and partners
[3786] In FY20, 65 per cent of the total spend was for products manufactured overseas and procured from suppliers with operational representation within Australia or through Australian distributors
[3786] The suppliers we engage with are primarily based on long term arrangements and are located in a number of countries including China, South Korea, Austria, Mexico, Indonesia, Malaysia and Australia
[3786] Our supply chain includes the following products and services
[3786] Solargain PV Pty Ltd 2 Support Services accounting and finance services, marketing, IT services, consultants
[3786] engineering and legal and procurement
[3786] Construction Installation Services residential and commercial Solar PV, energy storage and hot water systems installations and maintenance Product and Material Supply, including products that are manufactured overseas and supplied either direct from overseas manufacturers or via distributors located in Australia
[3786] Solargain does not manufacture any goods itself
[7474] The Fund is committed to mitigating the risk of modern slavery in the business and supply chains of the Fund and the assets in which it invests
[7474] About Equity Trustees ETL is a wholly owned subsidiary of EQT Holdings Ltd which is a diversified financial services company publicly listed on the Australian Securities Exchange (ASX: EQT)
[7474] ETL holds an Australian Financial Services Licence (AFSL) no
[7474] It acts as a trustee and responsible entity for a range of managed investment schemes and unit trusts of which the Fund is one
[7474] ETLs registered office is Level 1, 575 Bourke Street, Melbourne, VIC 3000, Australia
[7474] About L1 Capital L1 Capital is a global investment manager founded L1 Capital in Melbourne in 2007 by Raphael Lamm and Mark Landau with the launch of the Australian Equities strategy
[7474] They have grown the firm through the selective cultivation of new strategies, adding the Long Short equities in 2014, then adding Global Opportunities (multi-strategy hedge fund managed from Miami) in 2015, UK Residential Property (managed from London) in 2017, International Equities (managed from Sydney) in 2018, and Catalyst equities (best ideas, concentrated Australian equities with an activist overlay managed from Melbourne) in 2021
[7474] Today, the firm manages $4.5 billion in funds under management (FuM) for a range of investors including large superannuation funds, pension funds, asset consultants, financial planning groups, family offices, high net worth individuals and retail investors
[11660] All of OCLs subsidiary entities (as at 30 June 2022) are set out in the attached Annexure A, which are each 100% directly owned by OCL
[11660] Operations Objective is a leading provider of digital government software solutions that drive stronger communities and nations
[11660] Our solutions offer rich functionality focused on content management, planning and building processes and regulatory compliance
[11660] We develop software solutions to help government workers work smarter with secure access to the information they need to make decisions, anywhere on any device
[11660] Our clients are primarily government sector entities including many large departments and agencies but also include commercial entities operating in financial services and highly regulated industries
[11660] As at 30 June 2022, we had a headcount of around 450 people, and our operations included 15 offices globally: Australia: Sydney, Wollongong, Melbourne, Brisbane, Adelaide, Canberra, Perth New Zealand: Wellington, Palmerston North United Kingdom: London, Edinburgh
[991] Our Supplier Code of Conduct can be found at www.simsltd.com/governance/
[991] Working with External Stakeholders Our commitment to respecting, promoting and upholding fundamental human rights goes beyond meeting regulatory requirements
[991] We understand that our business affects human rights through our daily interactions with employees, suppliers, customers, partners and communities
[991] We also understand that our business can bring positive change to the lives of people who are affected by our operations
[991] That is the reason why our CEO signed the World Business Council for Sustainable Developments Call to Action for Business Leadership on Human Rights to support and promote the realisation of human rights for all
[991] We strongly support efforts in our industry to ban practices that enable human rights violations
[991] We support the Australian governments efforts to address the issues raised in the final report produced by the black economy taskforce
[991] In todays modern digital economy, there is no need for large cash transactions to take place
[3786] Our material supply chain is represented as: 65% - direct overseas manufacturers/suppliers (all with an Australian office) 5% - products manufactured overseas, sourced though an independent Australian distributor 30% - Generic other supplies and services, including subcontractors and indirect suppliers
[3786] Solargain employs its own in-house installers (including electricians and plumbers)
[3786] We also rely on the use of independent contractor installers and plumbers, all of whom are small businesses
[3786] Modern Slavery Risk Solargain recognises that modern slavery may impact our business activities and we are committed to our responsibility for reducing the risk that we might contribute to modern slavery through parts of our business operations and supply chains
[3786] The majority of Solargains purchases are for solar PV and hot water systems and components, all of which are manufactured overseas
[3786] Due to the products, product raw materials and the manufacturers geographical location these may have higher prevalence of modern slavery risks
[3786] There is also some risk indirectly through the equipment used in corporate services (computers, laptops mobile phones and uniforms and safety equipment)
[3786] From Solargains Australian operational view, the risk of modern slavery in the workforce is low
[7474] The firm remains 100% owned by its senior staff
[7474] L1 Capital holds an AFSL no
[7474] It acts as investment manager for a range of managed investment schemes and unit trusts
[7474] L1 Capitals registered office is Level 28, 101 Collins Street, Melbourne, VIC 3000, Australia
[7474] Operations and supply chains The Funds investment objective is to achieve strong, positive, risk-adjusted returns over the long term (in AUD terms)
[7474] The Funds investment strategy is to conduct bottom up company research to identify mispriced securities
[7474] The Fund may hold long or short stock positions (or derivatives) to profit from this mispricing
[7474] Securities will be listed (or expected to list) on a global stock exchange
[11660] PAGE 21 December 2022 | Document ID: A2602420 | OBJECTIVE.COM 3 United States of America: Marietta GA, Washington DC, Charlotte NC Asia-Pacific: Singapore Our procurement and human resources functions are largely centralised at our Sydney headquarters, which provides us with greater visibility over our supply chain and workforce
[11660] Our total revenue for FY2022 was AU$107 million
[11660] Our software solutions are developed, marketed and sold by Objective personnel directly employed by us
[11660] We do not outsource any of our software development nor do we operate any call-centres
[11660] Supply Chain Our key suppliers include: data centre IT hosting service providers; technology (eg laptops, monitors, etc.) and internet suppliers; office space landlords; and business software application suppliers, and they are commonly direct suppliers of products and services to us
[11660] In FY2022, we engaged directly with close to 200 suppliers, the vast majority of which were located in either Australia, the United Kingdom or the United States of America
[11660] Risks of modern slavery practices in Objectives operations and supply chain (Mandatory Criteria 16(1)(c)) In 2022, Objectives legal department undertook a risk assessment regarding any possible presence of Modern Slavery in our operations as well as in the operations of our key suppliers
[11660] In respect of our own operations, we did not identify any presence of Modern Slavery
[991] In the Australian scrap metal recycling industry, the widespread use of cash, primarily by small to mid-tier market participants, is a fundamental enabler of illegal activity, such as tax evasion, money laundering and organised crime many of which are linked to human rights violations
[991] We work with community partners to help solve challenges
[991] In Australia, we are supporting reconciliation efforts to improve the economic, health and social opportunities for Aboriginal and Torres Strait Islander people and their communities
[991] We have developed a REFLECT Reconciliation Action Plan (RAP) with the support of a newly established RAP Working Group that represents employees from the region
[991] The Sims Metals RAP was published and shared on the dedicated Respect & Inclusion page on our intranet
[991] Information is also included in the regions new hire welcome pack
[991] We are committed to the prohibition and elimination of child, forced and compulsory labour throughout the communities in which we operate
[991] Our human rights Downstream vendor audits conducted by Sims Lifecycle Services have included a focus on social responsibility since 2010
[3786] Apart from our direct employees, a large number of our suppliers are subcontractors who are small business operators with a majority of them working within their businesses
[3786] We are seeking to engage with suppliers who lack awareness of modern slavery risks in order to help them improve their awareness
[3786] Actions and Due Diligence to assess Modern Slavery Risk Solargain is committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain
[3786] Having a direct purchasing relationship with a majority of the manufactures, we request the same high standards from all of our suppliers and other business partners
[3786] Solargain prohibits the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, and we request that our suppliers hold themselves and their suppliers to the same accord
[3786] Due Diligence Solargain has undertaken an initial internal risk assessment to identify any key modern slavery risks that exist within our operations and supply chains
[3786] Following the risk
[7474] In preparing this statement, the Funds direct supply chain has been considered
[7474] The Funds operations and supply chains involve custody and administration of assets and also include several support functions including marketing and communication and governance, risk and compliance services
[7474] These support functions are provided by ETL and other external service providers
[7474] Internal policies and procedures in relation to the selection of service providers are followed and service providers are typically selected after a due diligence (financial & operational) process which includes risk assessments and thorough reviews with internal subject matter experts
[7474] ETL, as Responsible Entity of the Fund, has entered into agreements with each of the service providers which govern the nature and scope of the services to the Fund
[7474] Mainstream Fund Services Pty Limited is the administrator of the Fund
[7474] Credit Suisse Securities (Europe) Limited & Morgan Stanley & Co
[7474] International plc are the custodians of the Fund assets
[11660] This was predominantly due to us not outsourcing any software development work, and we have a sophisticated human resources function that is responsible for managing the hire of all employees and contractors
[11660] We assessed the risk of Modern Slavery in our operations as low given that our operations require skilled work performed by Objectives employees and contractors
[11660] In respect of our supply chain, we assessed the risk as relatively low, due to: the nature of the goods and services we acquire in connection with our business; us typically contracting directly with the supplier (which provides more visibility over worker arrangements and the types of supply being made and by whom); the operations and nature of most of our suppliers; the highly technical operations and nature of our business; many of our key suppliers have their own anti-Modern Slavery practices and statements; and the fact that the vast majority of our suppliers are primarily located in Australia, the United Kingdom or the United States of America
[11660] PAGE 21 December 2022 | Document ID: A2602420 | OBJECTIVE.COM 4 However, whilst we see the risk as relatively low, we do acknowledge that there are certain more risk- prone areas in our supply chain, where there is the potential for Modern Slavery to exist, as follows: Office Cleaning: Noting the nature of work in this sector, and the use of less skilled or migrant labour, we acknowledge that there is an inherent risk of labour exploitation with these suppliers; and Hardware Suppliers: whilst most of our hardware suppliers (eg laptop and monitor suppliers) are located in lower risk countries, we note that the manufacturing of the hardware, including some components, may occur in higher risk countries; and there is limited ability to practically determine whether any Modern Slavery exists at the component level
[11660] We manage these risk areas as follows: In regards to Office Cleaning, we typically have to use the office cleaners dictated by the landlord of our offices; however, most of these landlords are large reputable organisations (that have published Modern Slavery statements), and our offices are mostly situated in lower risk countries, so we see the risk as relatively low; and In regards to Hardware Suppliers, we use large reputable global brands of equipment, and rely on their Modern Slavery practices and statements to limit the risk
[11660] Actions taken to assess and address risks (Mandatory Criteria 16(1)(d)) Accountability for addressing Modern Slavery risk in our operations and those of our suppliers is multi- departmental
[991] This includes areas such as labour conditions, child labour and compensation systems
[991] policy reflects our commitment to act ethically and with integrity in all our business relationships and to implement and enforce effective systems and controls to avoid purchasing products that rely on inappropriate labour processes
[991] Assessing Effectiveness A review of the outcomes from Sims due diligence and monitoring programs including hotline reporting, site visits and performance reviews for FY20 did not identify any specific instances of modern slavery harm
[991] We have identified potential risk areas within our operations or supply chain as outlined in this statement
[991] Impact of COVID-19 The COVID-19 pandemic impacted human rights around the world
[991] While peoples health and safety were obviously impacted, less obvious impacts include: lost incomes; necessary goods becoming scarce; travel and contact restrictions causing people to become isolated, affecting their mental health; formal education becoming challenging or non-existent; and non-emergency medical care becoming more difficult to obtain
[991] The related financial pressures made many people more vulnerable to the risks of modern slavery as they sought new sources of income
[3786] Solargain PV Pty Ltd 3 assessment, Solargain is either implementing or improving our process to address these risks
[3786] Solargain undertakes an internal supplier assessment for all major suppliers as part of our due diligence, which is completed on an ongoing and regular basis
[3786] An assessment of modern slavery risk is being incorporated into the supplier assessment, which will include a modern slavery questionnaire to be completed by suppliers and submitted to Solargain annually
[3786] In the FY20 reporting period, major suppliers were requested to advise Solargain in relation to any of their modern slavery risks
[3786] The modern slavery assessment will be expanded to contractors in the FY21 reporting period
[3786] Solargain also undertakes factory inspections of major suppliers
[3786] This is to meet with manufactures and inspect facilities to review quality and ethical practices
[3786] In 2019/2020 this included inspection of facilities in Austria, China, South Korea and Australia
[7474] The administrator and custodians have operations in Australia and a number of international jurisdictions including North America, Europe and Asia, as part of global groups of companies
[7474] Risks of modern slavery practices in operations and supply chains of the Reporting Entity Modern slavery has been defined by the Act to includes eight types of serious exploitation, including
[7474] Trafficking in persons
[7474] Slavery
[7474] Servitude
[7474] Forced labour
[7474] Forced marriage
[7474] Debt bondage
[11660] The Board of Directors of OCL is ultimately responsible for Objectives efforts to avoid Modern Slavery in our operations and those of our supply chain
[11660] Our legal department has raised awareness at the executive level for senior business managers to support this initiative
[11660] Notwithstanding that the risks of the presence of Modern Slavery in our operations and those of our supply chain are assessed as relatively low, we have taken the following actions to address the risks: Modern Slavery Position Statement: we have provided a copy of this Statement to all of our employees and contractors, globally, and also made it publicly available on all of our websites to raise awareness and as a clear expression of our commitment to avoid the presence of Modern Slavery in our operations and those of our supply chain
[11660] Supplier Code of Conduct: we are in the process of creating a Supplier Code of Conduct (which includes provisions around our expectations and requirement that there is no Modern Slavery within the operations of our suppliers); and this will be published on our websites, again as a clear expression of our commitment to avoiding the presence of Modern Slavery in the operations of our supply chain
[11660] Our legal department manages the engagement of all suppliers, from a contractual perspective, and wherever possible they will require the Supplier Code of Conduct (or anti-Modern Slavery clauses) to form part of our contract with any new supplier going forwards
[11660] Modern Slavery Risk Assessment: our legal department performed a Modern Slavery Risk Assessment in respect of our operations as well as our supply chain
[11660] Whistleblowing Policy: we have a well-established Whistleblowing policy, under which concerns about our operations, or those of our supply chain, can be disclosed by Objective workers without fear of retaliation
[11660] Modern Slavery Questionnaire / Due Diligence
[991] Recognising this, we implemented precautionary measures for our employees and visitors to keep our sites open, swiftly shifted to working from home arrangements for a large portion of our workforce, and sought to maintain continuity in our commercial arrangements with suppliers to the greatest extent possible
[991] As local jurisdictions imposed lockdowns, our business was particularly affected in the U.S., UK and New Zealand, where we had to close a number of our sites and furlough a number of employees
[991] To alleviate some of the financial burden placed on our employees, we administered all government-provided relief mechanisms available to our employees, and where there were none, introduced company-funded emergency relief programs and continued healthcare coverage for employees negatively impacted
[991] Further information on the measures taken can be found in our 2020 Sustainability Report at www.simsltd.com
[991] A number of planned actions were delayed due to employees being furloughed, temporary site closures, and redirecting our focus in taking actions to preserve and protect the company and our employees
[991] Sims Lifecycle Solutions completed only 89 percent of the scheduled downstream vendor audits due to travel restrictions and revised priorities
[991] Annual Code of Conduct training had been launched in January 2020 and 93% of all employees completed it
[991] However, the resources needed to drive it to 100 percent completion were retasked to supporting our COVID-19 response
[3786] Plan for Remediation
[3786] Although Solargain is a major retailer in the Australian solar market, the Australian market only represents 2-3% of the global solar market, and as such we lack leverage over international manufacturers
[3786] In this way, we are reliant on the global renewable energy industry and governments to apply influence over the manufacturers and suppliers policies and processes in relation to modern slavery
[3786] Indirectly however, Solargain through its larger business partnerships is working towards offering only those products where the manufacturers comply with modern slavery obligations
[3786] Where it is identified that a manufacturer has engaged in modern slavery, where unable to work with the supplier to improve their modern slavery practices, Solargain will cease purchasing from that supplier
[3786] Solargain will provide education and training for suppliers as to the existence of the Modern Slavery Act (Cth) and invite them to make their own statements, policies and procedures
[3786] We will also provide awareness training to employees to equip them with the knowledge to identify modern slavery risks
[3786] Solargain has implemented a Modern Slavery Policy as part of our continued effort to have in place effective systems and controls to ensure modern slavery is not taking place anywhere within our own business or our supply chain
[7474] The worst forms of child labour
[7474] Deceptive recruiting for labour services
[7474] We acknowledge the following types of modern slavery risks and their indicators that can exist in the Funds operations and supply chains as well as in the equity holdings of the Fund
[7474] Sector and industry risk: Certain sectors and industries may have high modern slavery risks because of their characteristics, products and processes
[7474] Indicators of this type of risk include the use of unskilled, temporary or seasonal labour, use of short-term contracts and outsourcing, use of foreign workers or temporary or unskilled labour to carry out functions which are not immediately visible (ie at nighttime) for example, security and cleaning
[7474] In respect of the Fund based on the sectors identified using the Responsible Investment Association, Australasia (RIAA) investor toolkit and the Australian Council of Superannuation Investors (ACSI) Modern Slavery Risks, Rights and Responsibilities: A Guide for Companies and Investors and the Responsible Sourcing Tool, we have identified that the Funds investments are exposed to the following categories that exhibit sector and industry risk: Security and cleaning services Catering services Hotel and other travel services Agricultural and fishing industries Apparel industry Electronics manufacturing and electronics recycling industry
[7474] Food and beverage industries Health care Financial services Mining and resources
[7474] Product and services risk: where certain products and services have high modern slavery risks because of the way they are produced, provided or used