mila-ai4h/AIMS.au huggingface dataset:
[1973] Supply Chain In order to assist us to better understand our modern slavery risk in our supply chain, taking account of the Australian Governments guidance, we developed and sent a tailored modern slavery questionnaire to a sample group of our higher volume Tier 1 suppliers to test the usefulness of responses received
[1973] The responses received have helped to further refine this modern slavery supplier questionnaire for ongoing use during future reporting periods, including as we incorporate it into our supplier onboarding processes
[1973] To further assist us to scope our modern slavery risk in our supply chain in line with the regulatory guidance, we evaluated sector and industry risk, as well as product and services risk, to determine our high-risk procurement categories
[1973] We also considered the relative % of total spend in each of the identified at-risk categories
[4128] Load and Haul Operations
[4128] Bulk Earthworks & Rehabilitation
[4128] Urban Development
[4128] Tunnels & Bridges
[4128] Underground Services
[4128] Road Construction
[4128] Culvert Installation
[4128] Drill and Blast
[8585] As part of the onboarding process for new employees and contractors
[8585] The Code of Ethics policy is displayed at all project offices; and
[8585] All of the mentioned documents are hosted and updated as required on the IMS company Additionally, our Recruitment and Selection Procedure details the responsibilities of our HR department to complete for all employees a pre-employment verification process that includes validation of identification of potential ID and age of potential employees
[8585] Our Subcontractor Onboarding checklist provides for the same verification of all our subcontractors identification and ages for labour hire, short term workers and personnel seeking to attend any of our projects
[8585] Supplier Assessment and On-Boarding Our actions across our suppliers were primarily geared around assessment and identification mechanisms through reporting, due diligence on new supplier on-boarding and supplier reviews
[8585] A spend and category analysis for FY21 was undertaken on organizational spend footprint which helped to inform and assess our potential exposure and risks across our supply chain as already highlighted in 4
[8585] Risks of Modern Slavery in our Supply Chain Further to this, at supplier level, we updated our contractor management system, MyOSH, to incorporate screening of new suppliers to ascertain process and policies in place in relation to addressing modern slavery and ethical sourcing within their organization
[8585] Our procurement team maintains and conducts a schedule of business review meetings (BRM) across our key supplier relationships which enables a forum to identify and manage supply risks, including modern slavery
[14984] Risen Energy has engaged external experts to closely follow the NSW Anti-Slavery Commissioners proposal of a Renewable Energy Code of Practice so that we can ensure steps we take in our modern slavery approach are consistent with best practice industry standards that are being discussed in those forums
[14984] Values Our values include
[14984] Respect: respect everyones culture, background, time and privacy to build a foundation of mutual trust and a positive environment
[14984] Care: show utmost care about our work, our personal wellbeing, our team, our stakeholders, the community and the environment
[14984] Improvement: we commit to continuous improvement of our company, our products and our solutions
[14984] Excellence: we commit to being a renewable powerhouse by fostering the best practices, robust policies and developing world-class products and solutions
[14984] We believe that the culture of Risen Energy as embedded in these values is one that fosters and supports a strong approach to identifying, assessing and addressing modern slavery risks
[14984] The renewable energy industry is one that we believe is very focussed on sustainability and taking care of the world
[1973] Impact of COVID-19 on our supply chain During the COVID-19 pandemic, the Groups focus has been maintaining the safety of its employees and other persons accessing or using our sites whilst maintaining our operations which are critical to the state
[1973] The Groups initial response involved the procurement team identifying critical supplies to ensure continued support of the Groups operations and taking steps to secure those supplies
[1973] Recognising the possibility of increased exposure to modern slavery risk due to the impacts of COVID-19 on global supply chains, in particular increased pressures on suppliers and availability of supply, the Group continued, where possible, to secure supply from its qualified preferred suppliers
[1973] Demands and lack of available supply (in particular for Personal Protective Equipment) did require procurement of a minimal amount of supplies from outside of the Groups preferred suppliers
[1973] The amount procured was negligible
[1973] Procurement staff were made aware of the heightened risk of modern slavery when demand necessitated procurement outside of the Groups approved supplier list, and made additional enquiries as required
[1973] Our actions to assess and address modern slavery risks Assessing the effectiveness of our actions
[1973] OUR PLAN We developed a high-level plan for addressing our risks of modern slavery in our supply chain and operations in the reporting period (modern slavery response plan) which relevant staff have had responsibility for designing and implementing
[4128] Project & Statutory Management
[4128] Tailings Storage Facility Construction
[4128] Hard Rock Quarry Operations
[4128] Haul Road Construction & Maintenance
[4128] ROM & Waste Dump Management
[4128] Topsoil Removal & Management
[4128] Concrete Installation and Removal
[4128] Crusher Feed
[8585] To date however, no issue in relation to directly impacting us on modern slavery has arisen through these review meetings
[8585] Major Investment in Systems and Reporting We commenced a transformational review in FY21 and business case development to upgrade our enterprise business systems that would uplift reporting capability, improved integration and supporting business processes
[8585] We anticipate that the enhancement in reporting capability and analytics will have help contribute to refining ongoing Modern Slavery risk identification and assessment across our supply chain
[8585] ACTIONS TAKEN BY IRON MINE SERVICES TO ASSESS AND ADDRESS In developing this Statement, we engaged and informed key functional areas (Procurement, Business Systems, Human Resources, HSEQ, Indigenous Partnerships, Finance, Commercial, Operations) across Iron Mine Services and its affiliated joint ventures
[8585] Reviews of the statement were conducted by senior leadership members as to the Board of Directors
[8585] MODERN SLAVERY STATEMENT PAGE 6 During COVID19, the business experienced increased organic growth to meet increased client opportunities in the WA mining sector
[8585] With the additional focus in supporting our workforce through the pandemic and managing global supply risk disruptions impacting our supply chain, more comprehensive and targeted supplier engagement and educational initiatives to assess and address modern slavery were limited despite our best endeavors
[14984] Whilst we are aware of the high-risks within our industry we believe the very values that underpin this industry are surely aligned to protective approaches to human rights and as such we are optimistic as to progress in this space
[14984] Policies and Procedures We understand that staff play a key role in our due diligence
[14984] We have a range of policies applicable to all staff that further our approach to modern slavery directly but also that ensure our workplace generally aligns with legal and ethical workplace requirements including our: Modern Slavery Policy; Anti-bribery Policy; Whistleblower Protection Policy; Grievance Policy; Anti-discrimination, bullying and harassment Policy; Code of Business Conduct and Ethics
[14984] Our Modern Slavery Policy refers to the UN Global Compact and Ethical Trading Initiative Base Code as underpinning our procurement policies
[14984] It generally provides our commitments to our own workforce as well as to identifying, assessing, and addressing risks in our supply chain
[14984] Our Code of Business Conduct and Ethics speaks to compliance with laws, improper personal gains/benefits, conflicts of interest, insider trading, competition and fair dealing, confidentiality, gifts/donations, record-keeping, proper use of assets, discrimination and harassment, environment, health and safety, money laundering, and suspicious activities
[14984] It also explicitly prohibits any form of forced and child labour and provides avenues through which employees can report any illegal or unethical behaviour
[14984] All employees have to sign off on a certificate of compliance with the Code of Business Conduct and Ethics
[1973] The diagram below captures the core elements of that plan
[1973] Our modern slavery response plan takes a targeted and continuous improvement approach that focusses on our Tier 1 suppliers and on key areas and associated tasks
[1973] Flinders Port Holdings
[1973] Conducting modern slavery risk assessment
[1973] Undertaking supplier onboarding and contract review
[1973] Developing policies and procedures
[1973] Conducting training/awareness
[1973] Establishing reporting channels
[4128] Workforce At the end of FY20 RJV had a workforce totalling approximately 160 people, employed on a full time equivalency basis
[4128] This included 120 employed directly and approximately 40 employed through a number of local specialised labour hire companies
[4128] RJV has policies and procedures in place to ensure that all direct employees are screened, on- boarded and employed in a manner that mitigates the risk of Modern Slavery
[4128] Under our terms and conditions, all labour hire suppliers are required to comply with RJV policies and code of conduct
[4128] The business strives to ensure that all employees and contractors are aware of their rights and responsibilities by providing information, policies and a grievance mechanism for individuals to raise concerns and a process to resolve any issues raised
[4128] Supply Chain During FY20 RJV began working on an analysis to review probability of the risk of Modern Slavery occurring within the supply chain
[4128] The risk within the business is minimised by the fact that all business services are conducted solely within Western Australia
[4128] Machinery used in civil construction are sourced from Tier 1 suppliers, that have offices based in Australia and have advanced policies and procedures in place, along with quality systems
[8585] IMPACT OF COVID19- ON FY21 STATEMENT Clinton Keenan Chief Executive Officer (Signing as authorised Responsible Member)
[8585] ASSESSING THE EFFECTIVENESS OF OUR ACTIONS The ongoing effectiveness of Modern Slavery assessment and continuous improvement implementation will be coordinated by the Procurement function with support of the leadership team
[8585] As FY21 is our first statement, we remain committed to reviewing our progress against actions moving forward
[8585] Process mechanisms that already exist within our business to gauge the effectiveness and validity of a range of actions outlined in our statement, include but not limited to
[8585] Scheduled internal policy reviews and updates
[8585] Grievance investigation process
[8585] Supplier review meetings
[8585] STATEMENT APPROVAL This Statement is made on behalf of Iron Mine Contracting for the financial year ending 30 June 2021 and it has been approved by our governing body, the Board of Directors on 31st May 2022
[14984] We understand that the nature of modern slavery is that victims and witnesses are often powerless to come forward
[14984] Our Whistleblower Protection Policy is a particularly key part of our approach to modern slavery in that it provides a safe reporting avenue free of retribution
[14984] We have updated both our Whistleblower Protection Policy and Grievance Policy to include human rights related complaints
[14984] Training We have engaged key business representatives and raised awareness across the group by implementing a training program for all staff, through which we publicise all new and updated policies and procedures relating to modern slavery
[14984] We are also preparing a more in-depth training program, with sessions to occur once per fortnight in DocuSign Envelope ID: 9714B3FC-DE88-4657-A83C-1C0FD6AF6F64
[14984] Page 5
[1973] Developing a modern slavery reponse plan
[1973] Reviewing actions against the plan
[1973] Modern Slavery Statement Our performance Consistent with our continuous improvement approach, our modern slavery response plan for the reporting period targeted our highest priority tasks, that is, identifying and addressing our risks of modern slavery in our operations and supply chain
[1973] Our team have worked hard in the reporting period to undertake the following tasks that are relevant to our modern slavery response plan
[1973] PLAN FY 19/20 TASKS
[1973] ASSESS & IDENTIFY Risk assessment We undertook a supply chain modern slavery risk assessment exercise- focussing on our Tier 1 suppliers and trialling a risk assessment tool
[1973] Due diligence We tested a supplier modern slavery questionnaire on a sample group of Tier 1 suppliers to be included in supplier onboarding documentation
[1973] ACTION Training and capacity building We trained relevant staff (including delivering training sessions for the Group Leadership Team and procurement team) on identifying and addressing the risk of modern slavery practices, and on modern slavery legislative compliance
[4128] Parts are purchased to service and maintain this equipment and these parts are all sourced from local suppliers, as are uniforms and other business consumables
[4128] Service providers including Labour hire who source labour and services locally, predominantly work under RJVs Audited Safety, Quality and Environment systems
[4128] RJV has a subcontractor and supplier prequalification process which must be completed for any business that will be providing goods and services
[4128] This process includes agreement to Modern slavery requirements
[4128] Terms and conditions are currently under review and being updated where necessary, to ensure that suppliers and contractors are made aware and have systems in place to meet these requirements
[4128] Policies and Procedures RJV does not tolerate any form of slavery, human trafficking, forced or child labour
[4128] We have formal policies in place that are intended to promote the values of the business along with ethical and legally compliant business conduct
[4128] Our policies contribute to our commitment to prevent
[14984] Page 5 of 7
[14984] person or via videoconference for the whole of Risen Energy to spread awareness on our anti-slavery requirements
[14984] We have also created a Frequently Asked Question/Template Response document for our staff which spans 14 questions and which we hope will increase awareness as to our internal modern slavery approach and commitments
[14984] We provide recognition for individual staff members who go above and beyond expectations in advocating for robust ethical sourcing
[14984] Suppliers We have been working to communicate Risen Energys intention to take action to assess and address the risk of modern slavery in its supply chain through cooperation with our suppliers and clients to optimise their own approaches to their supply chains
[14984] We are focussing first on conducting a review process of critical suppliers, obtaining relevant information from those suppliers (for example, a particular panel manufacturer and its suppliers)
[14984] We have in place a supplier code of conduct which clearly details to our suppliers our expectations regarding modern slavery, human rights, labour practices, environmental responsibility, consumer safety, ethical conduct and data and privacy
[14984] We advise suppliers that failure to comply may prompt us to reassess our relationship with the supplier
[1973] Policy and procedure development We developed a Sustainability Policy and Ethical Sourcing Policy
[1973] We commenced planning for
[1973] the development of a Supplier Code of Conduct; and
[1973] a review of procurement policies and procedures to incorporate anti-modern slavery requirements
[1973] We revised our Group Whistleblower Policy
[1973] Supplier contract review and revision We included specific modern slavery compliance clauses in our template supplier agreements and in new/varied supplier contracts, including ensuring dispute resolution clauses include appropriate remediation options where a supplier is in breach of a modern slavery compliance clause
[1973] Supplier onboarding We developed a pre-qualification supplier questionnaire and developed modern slavery related RFX questions (a set of questions requiring mandatory response as part of our formal market approach)
[1973] Reporting channels We established an outsourced whistleblower reporting portal, FairCall, enabling reporting by internal and external parties
[4128] violations of human rights in our business, they including our Code of Conduct, Whistle-blower Policy and Corporate Social Responsibility Policy
[4128] Our policies set out conduct expectations and apply to all employees, contractors and consultants
[4128] These policies are reviewed and updated on a regular basis to ensure that they remain current and compliant
[4128] Whistleblower Policy RJV values the people who work within the business and encourages a culture of openness, where employees can raise concerns about any business conduct or practices
[4128] The Whistleblower policy establishes a mechanism, so that staff and contractors can freely and anonymously (if desired) report conduct that goes against the ethics and values of the business
[4128] This includes raising any concerns of Modern Slavery within the RJV supply chain
[4128] Potential Risks In preparation for our first annual statement RJV are reviewing potential risks of modern slavery practices across our operations and supply chains using the RJV Risk Management Framework
[4128] During this assessment process, we have considered risks that may possibly cause, contribute or be directly linked to modern slavery practices
[14984] It is also a mechanism through which we can request relevant information as to compliance and monitor this on an ongoing basis
[14984] We have also created modern slavery clauses and covenants for supply contract templates in our Australian operations, requiring suppliers to comply with the Act, implement appropriate controls and notify Risen Energy immediately if they become aware of any modern slavery within their own supply chains
[14984] We are in the process of conducting reviews and updating all of our contract templates to ensure they include these clauses
[14984] In 2022, we also worked to map the part of our supply chain that relates to PV modules, given the suppliers of polysilicon have been identified as an area we need to ensure we have as complete as possible oversight of
[14984] We intend to interrogate and review second and third tier suppliers, such as those providing solar cell and wafers, in future reporting periods
[14984] We aim to focus specifically on suppliers policies and procedures around worker labour and payroll conditions; factory audits of workplace practices; and processes for developing cooperative solutions that meet international human rights standards
[14984] We have developed a modern slavery self-assessment template which enables us to undertake a risk assessment of our suppliers through a questionnaire and review form
[14984] This tool was developed using resources from the Global Slavery Index, Global Compact Network, TRACE International, the Transparency International Corruption Perceptions Index and the Australian Modern Slavery register
[1973] REVIEW Performance assessment We focussed our approach by developing a plan of key tasks for the reporting period which we reviewed our actions against
[1973] Oversight We expanded our internal risk and assurance capability with a view to incorporating oversight of modern slavery compliance into our audit program
[1973] Each entity within the Group is committed to identifying and addressing risks of modern slavery in its operations and supply chain
[1973] We have ensured that our Board and senior management are kept updated on activities in relation to our obligations under the reporting requirement in the Modern Slavery Act
[1973] Relevant senior staff, have been advised about, and involved in, our modern slavery response plan actions as relevant
[1973] We have conducted training sessions for our procurement team and our Group Leadership Team on our Modern Slavery Strategy, outlining our plan for the reporting period and the status of related tasks
[1973] The Groups consultation approach has reflected the close relationship between its entities and the holistic approach the Group takes to embedding its compliance activities across its entities and departments
[1973] As part of its broader Sustainability Policy and accompanying Sustainability Plan, the Group aims to foster an organisational culture committed to corporate social responsibility, including the recognition of human rights
[4128] The results from this assessment process have identified areas within the supply chain that have different risk profiles
[4128] For example areas with lower risk include operational activities that are directly undertaken by RJV employees and contractors who are covered by our internal processes
[4128] This process has also identified some potentially higher risk areas eg where a local supplier may source a product from overseas sources
[4128] We are using these potential risk scenarios to prioritise our supplier engagement activities over the next financial year (FY2021)
[4128] We have also identified that risk is minimised by sourcing equipment through local reputable suppliers with audited quality systems in place, rather than buying directly from overseas
[4128] This also increases our ability to meet with suppliers, agree terms and conditions, develop ongoing relationships and audit supplier processes
[4128] Actions 6.1
[4128] Actions Taken in FY20 The actions taken in FY20 to gain greater understanding of the RJV supply chain and to combat any risk of Modern Slavery include
[14984] It contains over 20 questions that enable us to better understand the risks posed by each of our suppliers
[14984] We have a vendor assurance program wherein all new and existing vendors will be subjected to due diligence processes that include answering a brief pre-qualifications questionnaire (PQQ) on an annual basis
[14984] The PQQ enables us to identify potential areas of risk and to assess the business mechanisms and policies for managing modern slavery risks
[14984] We have sent the PQQ to the majority of high risk suppliers identified with Risen Energys initial risk mapping exercise as detailed above, and are in the process of reviewing the responses received
[14984] After the review process suppliers will be further categorised as either entities whose modern slavery approach we are comfortable with, or entities that we will work further with to better understand the risks theyre facing and how to manage these
[14984] Another step that we are proud of is that we have introduced social audits through the Initiative for Compliance and Sustainability (ISC) for our overseas production operations
[14984] These audits are then provided to our Australian entities each year confirming compliance by our overseas entities
[14984] At the end of 2021 a survey was conducted of the Risen Yiwu factory in the Zhejiang Province which generated an overall rating of 93 out of 100
[1973] Flinders Port Holdings Consultation within the Group
[1973] The Group is committed to continuously improving its understanding of and management of its modern slavery risks
[1973] In doing so, the Group has engaged with industry to participate in discussion on risks and issues that arise