mila-ai4h/AIMS.au huggingface dataset:
[7068] Within the construction of development properties, suppliers to Finbars building contractor use labour engaged through third-party providers and subcontractors, which combined with a workforce including higher rates of migrant and unskilled labour, increases risks of modern slavery
[7068] Finbar does not have direct supervision over the third-party workforce or transparency over the terms and conditions of the engagement of these workers
[7068] Notwithstanding, Finbar is prioritising its construction industry suppliers for direct engagement over the next reporting periods to better understand the extent of risk and ensure that suppliers are identifying and addressing risks of modern slavery in their own operations and supply chains
[7068] The Company will also commit to more deeply reviewing its direct supplier list, applying risk assessment criteria including industry, geography and spend criteria to identify those suppliers that may be classified as higher risk of modern slavery, requiring closer engagement
[7068] Supply Chain Finbars overseas based suppliers are largely based in countries that are considered low risk by the Global Slavery Index 2018 (GSI)
[7068] However, it recognises that its suppliers may, in turn, utilise suppliers, or source or produce their goods and services in countries which may include those identified by the Global Slavery Index as having a higher risk of modern slavery
[7068] In light of this, Finbar will engage with its suppliers during the next two reporting periods to determine which jurisdictions their suppliers source from, to better understand their supply chains, and to determine whether they have appropriate policies in place
[7068] Finbar has also considered the sector specific risks in respect of its Australian based suppliers
[11377] MODERN SLAVERY STATEMENT CONSULTATION AND STATEMENT APPROVAL Because of the shared management and governance of Wotton & Kearney Holdings Ltd, Wotton + Kearney Pty Ltd and Pinsani Pty Ltd, the preparation of this statement was inherently consultative
[11377] In accordance with section 13 of the Modern Slavery Act 2018 (Cth), this statement was approved by the Board of Wotton & Kearney Holdings Ltd on 27 October 2022 and is signed by David Kearney, Director and Chief Executive Partner
[11377] Signed: David Kearney Chief Executive Partner Wotton + Kearney Australian offices Adelaide Hub Adelaide, 89 Pirie Street Adelaide, SA 5000 T: +61 8 8473 8000 Brisbane Level 23, 111 Eagle Street Brisbane, QLD 4000 T: +61 7 3236 8700 Canberra Suite 4.01, 17 Moore Street Canberra, ACT 2601 T: +61 2 5114 2300 Melbourne Level 15, 600 Bourke Street Melbourne, VIC 3000 T: +61 3 9604 7900 Perth Level 49, 108 St Georges Terrace Perth, WA 6000 T: +61 8 9222 6900 Sydney Level 26, 85 Castlereagh Street Sydney, NSW 2000 T: +61 2 8273 9900 New Zealand offices Auckland Level 18, Crombie Lockwood Tower 191 Queen Street, Auckland 1010 T: +64 9 377 1854 Wellington Level 13, Harbour Tower 2 Hunter Street, Wellington 6011 T: +64 4 499 5589 www.wottonkearney.com.au
[11499] MCP Wholesale Investments Trust FY22 Modern Slavery Statement For Financial Year ending 30 June 2022 Page 1 of 4 | MCP Wholesale Investments Trust | FY22 Modern Slavery Statement Reporting Entity This statement is submitted under section 13 of the Modern Slavery Act 2018 (Cth) for the MCP Wholesale Investments Trust ABN 67 528 545 446 (WIT or the Trust)
[11499] This Statement has been prepared by the trustee The Trust Company Limited, ABN 59 004 027 749 (Trustee) and approved by the Board of Directors of the Trustee on 14 December 2022
[11499] Mark Smith Director The Trust Company Limited Consultation There are no subsidiaries or entities owned or controlled by MCP Wholesale Investments Trust which the Trustee is required to consult with to prepare this Statement
[11499] This Statement was developed in consultation with the investment manager, Metrics Credit Partners Pty Ltd for the Trust (Investment Manager) Structure, Operations and Supply Chain Structure The Trust is an unregistered managed investment scheme domiciled in Australia and was constituted on 26 September 2017 and has been in operation since 5 October 2017
[11499] The investment strategy of the Trust is to create a diversified exposure to Australian corporate loans generally reflecting market activity diversified by borrower, industry and credit quality
[991] We could be inadvertently linked to slavery-like practices as we sell to them
[991] Operations Risk While no region is immune to modern slavery practices, certain geographies present higher risk
[991] We operate in such a region in Papua New Guinea
[991] We also use agents to facilitate sales in certain regions of the world
[991] These agents are typically located and work in countries that are being assessed as higher risk to have modern slavery practices
[991] We supplement our workforce by hiring temporary workers and contractors
[991] There is an increased risk for poor labour practices to exist if we do not manage our relationships with third-party labour hire agencies and contractors well
[991] SALES IN HIGHER RISK COUNTRIES: APAC Region PAPUA NEW GUINEA <1% of Total Sales CHINA/HONG KONG 10% of Total Sales PAKISTAN 1% of Total Sales EMEA Region EGYPT 1% of Total Sales
[3752] If child labour is identified Suppliers must establish appropriate remediation measures and implement effective systems to prevent the use of child labour in the future
[3752] Suppliers and subcontractors must provide safe and hygienic working conditions for all workers with sufficient and accessible fire exits from all production, warehouse and dormitory buildings
[3752] Workers must also be provided with clean and hygienic washroom and canteen facilities and have regular access to clean drinking water
[3752] Workers must not be required to operate dangerous machinery and suitable Personal Protective Equipment should be provided at all times
[3752] The structure and layout of all buildings should be compliant with local regulations and designed to avoid any risk to workers
[3752] All hazardous chemicals should be stored in appropriate conditions with suitable labels and secondary containers to prevent spillage
[3752] If serious or fatal accidents have occurred, then Suppliers will be required to demonstrate that all appropriate steps have been taken to avoid the risk of similar accidents occurring in future
[3752] Photo by Pop and Zebra on Unsplash
[7068] Approximately one third 34.6% of Finbars first tier suppliers are based in industries that are generally considered low risk for modern slavery
[7068] These include professional services from the following sectors
[7068] legal and consultancy
[7068] financial
[7068] real estate; and
[7068] media, marketing and PR
[7068] Finbar considers that several of its other first tier suppliers are low risk from a sector-based perspective
[7068] These include
[11499] The Trust will invest in and alongside the wholesale trusts which are managed by the Investment Manager
[11499] WIT owns no real property and has no employees
[11499] As at 30 June 2022, the Trust had A$3.295bn net assets under management
[11499] Operations The primary operation of the Trust is the investment in directly originated secured loans and debt instruments
[11499] Perpetual Limiteds subsidiary The Trust Company Linited is the Trustee for the MCP Wholesale Investment Trust
[11499] Perpetual Corporate Trust (PCT) PCT provides a broad range of fiduciary, agency and digital products to the debt capital markets and managed funds industries both domestically and internationally
[11499] Debt Market Services includes Responsible Entity, document custodian, agency, trust management, accounting, standby servicing, and reporting solutions
[11499] Perpetual Digital provides data services, industry roundtables, and our new Perpetual Intelligence platform-as-a-service products supporting the banking and financial services industry
[991] % APAC 41 EMEA 35 AMER 24 Sales to Customers Per Region 12% of our sales are linked to higher risk regions Sims Limited Modern Slavery Statement 2020 | 7
[991] Consultation Assessing Sims operations and supply chain for modern slavery risks required a cross-functional dialogue that involved the Risk, Ethics and Compliance team, as well as the Human Resources, Finance and Operations teams
[991] Sims also sought guidance from non-governmental human rights-focused organisations, such as Walk Free by the Minderoo Foundation, Antislavery International, Liberty Shared, Human Rights Watch and the Human Rights Commission of Pakistan
[991] We have briefed our Board of Directors and executive leadership team on modern slavery risks and engaged them in the drafting of our Modern Slavery Statement
[991] Externally, Sims sought to learn from our shareholders about their concerns and expectations regarding corporate responsibility on Sims part, including activities designed to prevent Sims from contributing to the system of modern slavery
[991] Sims employees also participate in local, national and international trade associations, which provide insight into such issues as gender equality, and environmental and sustainability topics, all of which impact modern slavery risks
[991] We provide Code of Conduct training to all our employees each year
[3752] Dormitories and living accommodation, if provided, must include sufficient fire alarm systems and fire exits and must not be adjoined in any way to production and storage areas
[3752] Suppliers and subcontractors must pay living wages that are at least compliant with local minimum wage regulations and sufficient to meet basic needs
[3752] Suppliers and subcontractors must maintain accurate employment records for all employees, including current and resigned temporary and permanent workers, and be transparent and cooperative during the inspection of wages and working hours records
[3752] Bribery, corruption and similar unethical business practices are not tolerated by the Group and suppliers and subcontractors must not engage in such activities
[3752] Photo by Nathan Waters on Unsplash
[3752] About the St Hilliers Group St Hilliers is one of Australias leading, private, integrated property and construction groups, based in Sydney and Brisbane
[3752] It carries out construction projects all over the Australian mainland
[3752] Our Operations principally involve
[7068] public and regulatory bodies (eg, local councils or tax authorities); and
[7068] utilities and postage
[7068] Taking action against modern slavery Overview Modern slavery continues to remain a global issue, affecting approximately 40 million victims around the world (as estimated by the United Nations and Walk Free Foundation)
[7068] Finbar respects the human rights of every person involved in its operations, supply chain and the community in which it operates
[7068] It will not accept any form of modern slavery in the conduct of its operations and in its supply chain and is committed to ensuring that all workers are treated fairly, ethically and with respect
[7068] To date, the Group has not identified any instances of modern slavery in its operations or supply chain and is committed to addressing risks of modern slavery to which it may be exposed
[7068] Operations To mitigate against modern slavery risks in its operations, Finbar is committed to
[7068] engaging its employees under fair, just, and ethical employment contracts
[11499] Managed Funds Services provides services including independent responsible entity, wholesale trustee, custodian, investment management and accounting
[11499] Supply chain The Trusts supply chain consists of direct service providers
[11499] These suppliers are all located in Australia
[11499] Procurement categories for service providers include
[11499] Trustee
[11499] Investment Managers
[11499] Auditor
[11499] Tax Agent
[991] Our Actions We work hard to stay abreast of developments in the area of human rights, such as safety in the workplace, fair wages and equal treatment
[991] At a minimum, we comply with all applicable local laws, regulations and standards of the countries in which we operate, and we strive to exceed basic compliance
[991] In FY20, Sims Limited implemented a global governance structure focused on increasing the effectiveness of current and future efforts to protect human rights in our operations and supply chain
[991] Sims Risk & Compliance Group has been tasked with providing centralised leadership and guidance related to these efforts
[991] It spearheaded the issuance of our Supplier Code of Conduct in FY20, and will drive future improvements to and training on policies and procedures
[991] Our Code of Conduct details our commitment to human rights
[991] This includes specific policies for the protection of rights for employees, including
[991] the right to equal opportunity and non-discrimination, regardless of ethnicity, gender, religion, age, sexual orientation, health status or other such protected classifications
[3752] Property development (including design, programming, marketing and sales) in the commercial, industrial, retail and residential sectors; and
[3752] Building and construction (including design) in each of those sectors, across mainland Australia
[3752] Currently the Group engages some 140 staff
[3752] At St Hilliers we are committed to supporting the many diverse communities in which we live and work across the country
[3752] Our partners include: Legacy / The Kids Cancer Project / Meals on Wheels / Property Industry Foundation / Mates4Mates / SwichOn Inc / Randwick Rugby Club / Kids West Charity/ Cancer Council
[3752] St Hilliers have been operating for more than 30 years and we have built this business by ensuring our clients expectations and our delivery are consistent
[3752] About the Reporting Entities Our Structure: The Group is broadly divided into Property and Contracting arms
[3752] The entities which have reporting obligations under the Modern Slavery Act 2018 (Cwlth) and are making this statement jointly are in the Contracting part of the Group, being as follows
[7068] not partaking in high risk or unethical labour engagement practices, including by ensuring that it does not
[7068] use migrant or seasonal labour
[7068] charge employees to work through recruitment fees or imposing fines
[7068] retain employee original identification documents or preventing employees from moving freely
[7068] use child labour; or
[7068] undertake deceptive recruiting practices
[7068] Given the higher likelihood of modern slavery in the cleaning industry, over the coming reporting period Finbar will engage directly with its cleaning contractor as a priority to understand its policies and processes for ensuring compliance with all relevant labour laws and regulations and for identifying, assessing and addressing risks of modern slavery
[7068] Supply chain To reduce exposure to modern slavery risk in its supply chain, Finbar has commenced direct engagement with its major supplier of building services during the current reporting period
[11499] Administrator
[11499] Custodian
[11499] Independent Valuer
[11499] Registry Provider
[11499] Legal Counsel
[11499] Distribution Partners/ Channels Modern Slavery Risks The Trustee understands that modern slavery risk can occur in operations and supply chains
[11499] The Trustee considers risk assessment a critical process to identifying the inherent risk of modern slavery across the MCP Wholesale Investments Trust
[11499] Defining modern slavery risks Modern slavery is serious exploitation that undermines a persons freedom
[991] the right to personal security, including protection against improper and unlawful harassment, as well as against retaliation for employees who report non- conformance with government regulations, company policies and codes of conduct
[991] the right to a safe and healthy workplace for each and every employee, regardless of status
[991] the right to competitive remuneration, supporting the concept of competitive pay for work performed; and
[991] all other legal rights in respect of the workplace granted to our people in the regions in which we operate
[991] All of our employees are trained to act in accordance with our Code of Conduct and to raise any concerns or breaches to management or through our hotline
[991] Our hotline allows employees and third parties to anonymously report breaches or concerns in all jurisdictions where we operate
[991] We address all reports
[991] We provide new refresher training on our Code of Conduct to all employees annually, including detailed guidance for key areas on a rotating basis
[3752] STH Holdings Pty Ltd ABN 71 069 565 331, which is the holding company for the Contracting part of the group and does not trade
[3752] its subsidiary St Hilliers Pty Ltd ABN 78 003 819 681, which does not trade and is the parent of the trading company St Hilliers Contracting Pty Ltd ABN 66 082 729 039
[3752] St Hilliers is a closely held Group and the same directors and managers are involved and work directly with all the reporting entities and their subsidiaries in relation to these issues
[3752] Photo by Shane McLendon on Unsplash
[3752] Benefits of Combatting Modern Slavery There are many benefits in combatting Modern Slavery, including
[3752] helping to protect vulnerable workers
[3752] helping to prevent and remedy severe human rights violations
[3752] protecting and enhancing the Groups reputation and brand
[7068] The builder is participating in the dialogue process and has indicated its commitment to reducing modern slavery in its own supply chain
[7068] Finbar recognises that continuous improvement is key to reducing the risk of modern slavery
[7068] To this end, it is committed to undertaking the following actions during the coming reporting periods
[7068] Continue to directly engage with its major builder, as well as seek to extend this engagement to other major suppliers that have been identified as high-risk following supply chain mapping, screening and risk assessment
[7068] This will allow Finbar to determine the extent of these suppliers anti-modern slavery actions, and to ensure these suppliers are monitoring their own operations and supply chains for risks
[7068] Establish roles across the Group that will have responsibility for managing risks of Modern Slavery
[7068] Finbar will establish a modern slavery team comprised of the Company Secretary (reporting to the Board), the Development Manager and General Manager of Project Coordination
[7068] This team will report quarterly to the Board advising progress, particularly of the data gathered from the Groups suppliers in respect of their suppliers
[11499] In a situation where modern slavery occurs, a person cannot refuse or leave due to threats, violence, cohesion, abuse of power, or deception1
[11499] Modern slavery occurs in a variety of forms, there are eight types including human trafficking, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruiting for labour or services and the worst forms of child labour2
[11499] Modern slavery risk means the potential for the Trust to cause, contribute to, or be directly linked to modern slavery through their operation or supply chain
[11499] The Trust recognises that COVID-19, conflict and climate change driving migration has exacerbated modern slavery risks for people in vulnerable situations3
[11499] Risk assessment methodology In FY22, the Trustee collected information on the Trusts supply chain to include in a modern slavery risk assessment
[11499] Specifically, the Trustee investigated the service providers that we have a direct relationship with
[11499] The service providers were then assessed for inherent modern slavery risks and an inherent risk profile was determined for each entity
[11499] Inherent risk is the level of risk before any actions are taken to manage the risks impact or likelihood
[991] In addition, posters are displayed at all of our sites and visible to both employees and visitors
[991] Drafted and issued the Sims Limited Supplier Code of Conduct to codify our expectations for the business conduct of our suppliers and partners and the support we will provide for them
[991] Developed training to further build understanding of and address modern slavery risk Conducted Code of Conduct training Established a global governance structure to support centralised and standardised administration and response
[991] Signed the World Business Council for Sustainable Development call to action on human rights to help promote the protection of human rights in business sustainability plans
[991] Developed targeted training for employees with a higher likelihood of contact with modern slavery, such as those in procurement, human resources and site management
[991] Continued to provide an independent hotline available to employees and third parties for anonymously reporting breaches, concerns or asking questions
[991] 2020 Progress Sims Limited Modern Slavery Statement 2020 | 9
[991] Addressing Operational Risks To help address risks within our operations, we developed both general awareness training and targeted training for employees with a higher likelihood of contact with modern slavery, such as those in procurement, human resources and site management
[3752] protecting and growing the Groups client base as more clients seek out businesses with higher ethical standards
[3752] improved investor confidence
[3752] greater staff retention and loyalty based on values and respect; and
[3752] developing more responsive, stable and innovative supply chains
[3752] Our Supply Chains Currently, due to the Covid 19 pandemic, supply chains are mostly intra Australia
[3752] Our construction operations utilise Australian-based professional services (architects, surveyors) and subcontractors (concreters, tilers, carpenters, bricklayers) local to the Australian project site, where possible
[3752] These operations also use products and raw materials from our suppliers, which are currently Australian-based
[3752] Historically we did source materials or products internationally
[7068] Review existing policies, systems and practices to identify areas for improvement and articulate an effective framework for identifying, assessing and addressing risks of modern slavery
[7068] This will be integrated with the Groups risk management framework and will incorporate a mechanism for employees, contractors and members of the public to report instances or risks of modern slavery and unlawful or unethical conduct associated with Finbars operations
[7068] Developing procurement and on boarding processes to improve supply chain visibility
[7068] As part of this process, the Company has commenced developing a Supplier Self-Assessment Questionnaire designed to capture supplier information, supporting the identification of potential modern slavery risks and labour rights issues
[7068] Suppliers with high risk and low visibility results will be requested to complete a detailed modern slavery and labour rights supplier SAQ
[7068] Implementation of supplier minimum standards and incorporation of anti-modern slavery requirements in key supplier contracts
[7068] Undertaking training in respect of risks of modern slavery, actions that can be taken at the time of procurement to minimise the risks and available reporting mechanisms
[11499] International Labour Organization (ILO), Walk Free, and International Organization for Migration (IOM), 2022
[11499] Global Estimates of Modern Slavery: Forced Labour and Forced Marriage, 13
[11499] As defined in the Australian Modern Slavery Act 2018 (Cth) 3 International Labour Organization (ILO), Walk Free, and International Organization for Migration (IOM), 2022
[11499] Global Estimates of Modern Slavery: Forced Labour and Forced Marriage Page 2 of 4 | MCP Wholesale Investments Trust | FY22 Modern Slavery Statement
[11499] Page 3 of 4 | MCP Wholesale Investments Trust | FY22 Modern Slavery Statement Risk Assessment Results Supply Chain The Trustees FY22 risk assessment did not identify any high-risk service providers
[11499] All service providers are categorised as low to medium as all service providers operate and are domiciled in Australia