mila-ai4h/AIMS.au huggingface dataset:
[2824] In relation to assessing our investments, we focussed on ASX listed companies in the consumer staples, consumer discretionary and transportation sectors, and included meetings with executives or board members
[2824] We covered issues such as underpayments of employees, supply chain monitoring (particularly in the horticulture sector), audit outcomes and disclosure
[2824] Investor engagement has resulted in improvements with
[2824] more structured oversight and reporting of employee conditions in franchising companies
[2824] supermarket chains raising the bar for their horticultural suppliers by setting clear expectations on the use of labour-hire providers, and
[2824] the introduction of regular auditing programs and improved whistleblowing systems to support ongoing compliance
[2824] Our modern slavery statement APPENDIX AREA MODERN SLAVERY RISKS IDENTIFIED Internal operations Other investment service providers (eg custodians, brokers, data providers, valuers) We did not consider the potential modern slavery risks within this area to be high
[2824] They involve the provision of specialised professional services and are provided predominately from Australia
[5169] Risk Identification & Management Resolute adopts a consistent approach to both corporate and asset-level risk management
[5169] Significant residual operational risks are integrated into our Enterprise Risk Management Framework (ERMF) which is reviewed regularly by the Resolute executive team and overseen by the Audit and Risk Committee of the Board
[5169] The ERMF prescribes the methodology, minimum performance standards and risk appetite applicable to the assessment and treatment of strategic, corporate, operational, ESG and project risk and opportunity
[5169] The Committee provides oversight and guidance to the assessment and treatment of actual and emerging ESG risks and opportunities across the Company
[5169] In 2020, the Charter was updated to include specific reference to human rights
[5169] ESG risks and opportunities are discussed as a standing agenda item at all meetings of the Committee, with key actual or emerging risks escalated to the Board as required
[5169] The below figure outlines Resolutes ERMF
[5169] Document Owner: Lead Document Controller (RSG) Page 5 of 7 Document Number: ADM-ADM-TMP-0022 Revision 1.02 Issue Date: 7/06/2021 Next Review:12 months Modern Slavery Voluntary Statement
[10291] For clarification, each of Atturras controlled entities are covered under this joint Statement and when referring to Atturra in this Statement, it includes all the entities set out under Figure 1 (collectively referred to as Atturra)
[10291] The consolidation of the revenue of the entities owned by Atturra Limited triggers the requirement under the Act of entities over a $100 million annual consolidated revenue threshold that are either classed as an Australian entity or a foreign entity carrying on business in Australia during the reporting period, to prepare and publish an annual Modern Slavery Statement
[10291] We are proud to share with our stakeholders our commitment to addressing modern slavery and we recognise that we will require a culture of continuous improvement over a number of years
[10291] We intend to work in partnership with our stakeholders to promote ethical practices to reduce the risks of modern slavery in our operations and supply chains
[10291] Our structure, operations and supply chain Structure Atturra is an ASX-listed technology services business
[10291] Atturra is a leader in designing, implementing, and maintaining IT solutions for many of Australias largest private and public entities
[10291] Atturra offers consulting, IT services and technology solutions to accelerate digital transformation in the growing Australian IT services market
[10291] Atturra Limited is the parent of several other Australian com- panies that ultimately form the Atturra business
[241] SRG has completed previous campaign projects in Hong Kong, Indonesia, Ireland, Lesotho, Malaysia, Panama, Papua New Guinea, Singapore, Sudan, Thailand and Zambia
[241] No current or permanent locations are in these territories
[241] SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 4 Managing the Risk of Modern Slavery at SRG Global Governance and Policies SRG recognises the importance of developing a clear structure for the management of its businesses to protect human rights and the abolishment of slavery practices
[241] Pursuant to our 2020 Corporate Governance Statement, our Board has developed a framework for the management of SRG Global including the adoption of corporate governance practices, the implementation of internal controls and risk management processes
[241] The SRG Boards role is to represent and serve the interests of shareholders and the expectations of our stakeholders through the oversight and appraisal of SRGs operations
[241] This includes the setting and review of compliance systems commensurate to our values and governance framework
[241] Delegation of SRGs management is passed to our Managing Director, who in association with SRGs Officers implement the strategic objectives and plans as approved by the Board
[241] Through the Managing Director, SRGs Executive Leadership Team is accountable for the implementation and delivery of the Organisations strategic directions
[2824] We will look to assess and address any possible risks in a future reporting year
[2824] Operating superannuation (accumulation and pension) products We did not consider the potential modern slavery risks within this area to be high
[2824] Administering all superannuation (accumulation and pension) products We did not consider the potential modern slavery risks within this area to be high
[2824] Providing inbuilt benefits and offering external insurance to members We did not consider the potential modern slavery risks within this area to be high
[2824] Providing general and personal financial product advice to members and their families via UniSuper Advice We did not consider the potential modern slavery risks within this area to be high
[5169] Resolute considers human rights compliance to be a material issue and human rights and associated modern slavery risks feature prominently in Resolutes risk management processes
[5169] The level of risk depends on key intersecting factors including geography, services and employment practices and supplier capacity
[5169] These are outlined in further detail below
[5169] Geography Exposure to modern slavery risks will be correlated to the social, political and environmental conditions in the countries in which Resolute and its suppliers operate
[5169] Using indicators to assess prevalence, vulnerability and the effectiveness of government responses to address modern slavery in these countries will be central to understanding the level of risk and to prioritising interventions
[5169] Country Global prevalence index ranking Estimated number of people living in modern slavery Vulnerability to modern slavery Estimated proportion of the population living in modern slavery Government response rating Australia 163/167 15,000 4.27/100 0.65/1000 BBB United Kingdom 132/167 136,000 11.13/100 2.08/1000 BBB* Mali 95/167 62,000 55.88/100 3.7/1000 CCC Senegal 109/167 43,000 46.20/100 2.87/1000 B Ghana 71/167 133,000 51.16/100 4.84/1000 CC Cote dIvoire 56/167 137,000 57.20/100 5.91/1000 B Guinea 28/167 94,000 66.33/100 7.80/1000 C *The lower the score in the global prevalence index ranking, the higher the prevalence of modern slavery Prevalence of modern slavery in the countries in which Resolute operates (Global Slavery Index 2018, Walk Free Foundation)
[5169] Document Owner: Lead Document Controller (RSG) Page 6 of 7 Document Number: ADM-ADM-TMP-0022 Revision 1.02 Issue Date: 7/06/2021 Next Review:12 months Modern Slavery Voluntary Statement In both Senegal and Mali, we have actively established links between our international suppliers and local distributors thus enabling Resolute to source goods onshore and in so doing, strengthen the local supply chain which will facilitate the identification of human rights and modern slavery risks
[5169] Services & Employment Practices Exposure to modern slavery risk is also specific to the production of certain goods and services due to sector specific pressures and labour force structures
[10291] Our mission is to become a leading Australian IT solutions provider with high engagement across industries, employees and clients
[10291] Atturras registered office is Level 33, 88 Phillips Street, Sydney NSW 2000
[10291] Introduction Atturra Limited (Atturra) is a leading Australian technology services business, providing expertise across a broad range of specialist, in-demand IT areas
[10291] At Atturra, we understand that modern slavery is a complex issue and acknowledge that the nature of our business means we are exposed to potential modern slavery risks across our operations and supply chain
[10291] We are committed to developing our understanding of the modern slavery risks in our business and taking action in responding to this problem by working with our business, subsidiaries, stakeholders, business partners and suppliers to limit modern slavery risks
[10291] Atturra Modern Slavery Statement FY22 Figure 1: Atturra Corporate Structure ACN 654 662 638 Atturra Limited ACN 132 368 104 Atturra Holdings Pty Ltd 46% NZ Company No 3566154 Kettering NZ Limited Incorporated in NZ ACN 104 218 804 FTS PHC Pty Ltd 100% ACN 627 989 584 Galaxy 42 Group Pty Ltd ACN 626 386 132 ESAM Consultants Pty Ltd ACN 167 654 382 Galaxy 42 Pty Ltd Trading as Atturra Business Applications - Education Trading as Atturra Business Applications ACN 133 375 112 Chartsmart Consulting Pty Ltd Trading as Atturra Business Applications - Government ACN 114 612 001 Kettering Professional Services Pty Ltd Trading as Atturra Business Applications - Manufacturing 100% 100% 100% 100% ACN 654 045 557 Atturra Operations Pty Ltd 100% ACN 652 098 489 Atturra Personnel Pty Ltd 100% ACN 101 129 588 Foundation Technology Services Pty Ltd 100% ACN 126 566 336 FTS Data & AI ACN 616 447 397 FTSG Pty Ltd 100% SINGAPORE COMPANY NO
[10291] E Anatas Pte Ltd Incorporated in Singapore 100% ACN 133 185 458 Anatas Pty Ltd 100% ACN 169 127 824 Hayes Information Systems and Communications Pty Ltd 100% NZ Company No 8177133 Anatas Pty Ltd (NZ) Overseas ASIC company operating in NZ NZ Company No 7852799 Hayes Information Systems & Communications Pty Ltd (NZ) SINGAPORE ENTITY Hayes Information Systems Pte Ltd Overseas ASIC company operating in NZ Trading as Atturra Data & Integration ACN 106 981 560 SME Gateway Pty Ltd 100% ACN 105 421 976 Kobold Group Pty Ltd Trading as Atturra Management Control Solutions ACN 156 123 723 Mentum Systems Pty Ltd Trading as Atturra MCS 100% 100% ACN 149 193 519 FTS Nominees Pty Ltd 100% ACN 133 048 290 FTS Resourcing Pty Ltd 100% ACN 166 492 575 FTS VHC Pty Ltd 100% ACN 166 493 394 Veritec Pty Ltd 100% 100% ACN 105 196 423 Connexxion Pty Ltd Trading as Atturra Cloud Business Solutions ACN 133 185 547 Cubic Consulting Pty Ltd 100% NZ Company No 8228600 Cubic Consulting Pty Ltd (NZ) Overseas ASIC company operating in NZ Trading as Atturra Change & Adoption 25% 55% ACN 646 747 113 FTS NHC Pty Ltd 100% ACN 117 643 240 Noetic Group Pty Ltd ACN 098 132 024 Noetic Solutions Pty Ltd Trading as Atturra Advisory 100% 54%
[10291] Atturra Modern Slavery Statement FY22 Operations Atturra provides a broad range and flexible suite of integrated solutions across the main business service segments including
[241] Our Framework Our Code of Conduct sets the foundation for the minimum expectations and behaviours to which we hold ourselves, our employees, service providers and suppliers to account
[241] Collectively these expectations and behaviours establish the values to which we as a Company hold ourselves to account
[241] Supporting our Code is our risk management system comprising of our Policies and Procedures that provide the structure for how we deliver on these values and the Code, delivered through our Integrated Management System (IMS)
[241] Our Diversity & Inclusion Policy outlines our commitment to ensuring the fair and equitable treatment of local suppliers and workers without discrimination on the basis of aspects such as gender, race, ethnicity or religious views
[241] We are committed to creating a diverse and inclusive workforce through sourcing, selecting, developing and recognising our own people and those of our stakeholders
[241] Supporting our Diversity & Inclusion policy is our Sustainability Policy
[241] This sets our commitment to develop an operational model to manage the economic, environmental and social risks and opportunities encountered across our operations
[241] SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 5 Assessing our risk to Modern Slavery Practices As a global Company, we procure goods and services from both domestic and international suppliers and as such, our framework is designed to support our operations in the identification and eradication of slavery practices
[2824] AREA MODERN SLAVERY RISKS IDENTIFIED Supply chains Goods and services In the assessment of our supply chains pertaining to products or services provided to us by suppliers, all goods and services procured by UniSuper were considered via tier one of the supply chain that provides the goods or services
[2824] The vast majority of the reporting entities suppliers of goods and services are not suppliers at higher risk of involvement with modern slavery
[2824] Overall, on a headcount basis, 94% of our tier one suppliers of goods and services were located or carrying on an enterprise in Australia, 3% in the United States and the remainder elsewhere
[2824] Our suppliers (and types of services obtained) include
[2824] custodians, brokers, research providers and external investment managers (investment services)
[2824] professional services firms (accounting, audit, advisory)
[2824] marketing of branded goods
[5169] The services sector and those business models engaging migrant workers, entry-level workers or outsourcing are especially at risk
[5169] For Resolute, key supplier categories presenting a higher risk include transport and logistics, construction, consumer goods, electronics, catering and cleaning, maintenance and security
[5169] Resolute will prioritise evaluating the employment practices of these suppliers, especially if their operations are in a high-risk country, in order to assess the supply chain modern slavery risks
[5169] Resolute is developing a tool to facilitate the identification of suppliers most at risk based on the types of goods and services provided, and their sourcing geography
[5169] Supplier Capacity Identified high-risk suppliers will be evaluated on the strength of their internal governance, processes and practices to ensure they have strong operational safeguards in place to eradicate human rights violations and modern slavery from their operations
[5169] To support this process we are developing a Supplier Standard for Sustainability and Due Diligence Questionnaire that will identify suppliers needing to improve their safeguards
[5169] Training & Awareness Resolute supports training and awareness raising across its workforce
[5169] Currently, all employees and contractors receive mandatory induction training on the application of key policies when joining the Company, including the Code of Conduct and Whistleblower Policy
[10291] Advisory and Consulting
[10291] Business Applications
[10291] Data and Integration
[10291] Cloud Services
[10291] Change Management and Adoption
[10291] Management Control Solutions
[10291] Industry Engagement Atturra currently engages over 600 consultants, IT and support personnel in Sydney, Melbourne, Brisbane, Canberra, Adelaide, Perth, New Zealand and Singapore
[10291] Atturra monitors its opera- tional activities carefully, including staff and contractors, and has determined that there is very low risk of modern slavery practices occurring
[241] To this end SRG recognises that its greatest exposure to modern slavery related issues exists within the companies purchasing and distribution supply chain
[241] To address the exposures of modern slavery within our operations, in consultation with the Executive Leadership Team, a review of SRGs operations was undertaken
[241] This focussed on: Areas of exposure; Existing methods of treatment; and Areas of improvement In consultation with representatives from each business unit, including input from the commercial, finance, procurement, human resources, quality, health & safety and risk and communications teams, a strategic review was undertaken on the existing supply chains within the Company
[241] This heatmap4 below provides a graphical summary of exposure to modern slavery practices
[241] Heat Map taken from the Minderoo Foundation 2018 Global Slavery Index Report
[241] SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 6 Supplementing the review on our supply chain, an analysis was also undertaken on our operations considered high risk in terms of either; exposure to modern slavery or having the potential to influencing decision making within the SRG supply chain
[241] The influencing factors identified include: Supply Chain Risks: Identification, Action and Treatment As a result of the assessments completed to identify the territorial and operational risks above, we recognise that a vast array of circumstances may affect our suppliers, leading to changes in their manufacturing and distribution practices and subsequently may increase our exposure to modern slavery practices
[241] To combat these risks, we are committed to undertaking the necessary steps with the aim of preventing and removing any risk we may have to modern slavery conditions
[2824] telecommunications (internet, telephone, computing, data storage)
[2824] facilities and premises (real estate)
[2824] logistics and freight suppliers (postage and couriers)
[2824] industry and professional organisations (subscriptions, memberships)
[2824] information technology companies (software, data services, technical services)
[2824] recruitment and human resources firms (human resources); and
[2824] office-related suppliers (cleaning, catering, stationary)
[2824] In determining which aspects of our supply chains were at a higher risk of modern slavery, an enterprise wide assessment of spend and supplier data for the 2019 calendar year was conducted alongside consideration of
[5169] Regular awareness raising campaigns on selected material topics are also delivered
[5169] These existing approaches will be essential in ensuring that human rights and modern slavery considerations are embedded in its operations
[5169] The Company will continue to refine and improve its training and awareness programs relative to human rights and modern slavery and is developing a standalone trainings that will become a mandatory requirement for all employees in 2021
[5169] Stakeholder Engagement As a responsible corporate citizen Resolute understands its role in raising awareness and strengthening the capacity of institutions, in the countries in which it operates, to address human rights and modern slavery both locally and nationally
[5169] Resolute engages with its key stakeholders in all countries of operation, regarding business activities, performance, risk identification and management
[5169] Resolute is working to implement a stakeholder engagement framework to further develop its networks with governments, civil society, industry bodies, host communities and suppliers
[5169] Increased engagement will contribute to the elimination of modern slavery through the sharing of information, resources and the early identification of risks
[5169] Performance Review Resolute regularly commissions asset-level audits of established processes, management systems and operations to review performance
[10291] Atturra ensures that all employees are legally entitled to work in the relevant jurisdiction and complies with all applicable laws, including providing employees with appropriate employment conditions such as hours of work, fair remuneration and wages and access to employment benefits
[10291] In the event that recruitment agencies are engaged to source personnel in jurisdictions outside Australia such as New Zealand and Singapore, Atturra ensures the rate (if any) charged to the individual is reasonable and that all local employment laws are followed
[10291] At the time of this Statement, Atturra does not employ any contractors or subcontractors in jurisdictions outside Australia
[10291] Supply Chain Atturras supply chain consists of more than 800 suppliers, the vast majority of which are companies based in Australia
[10291] Atturra engages a very small number of suppliers outside Australia, including from suppliers based in India and Singapore
[10291] These arrangements with overseas suppliers are considered low risk and the suppliers are engaged on a short-term or ad-hoc basis
[10291] Atturras substantial and material contractual relationships are with suppliers based in Australia
[10291] Atturra contracts with its higher value and strategic suppliers by way of a Supplier Services Agreement or Contractor Agreement depending on commercial terms
[241] This includes a process of identification, buying locally and education and treatment
[241] A Process of Identification The management of supply chain risks forms part of SRGs wider corporate risk management framework and practices
[241] This framework includes the incorporation of controls and processes prudent to ensuring we meet the values established by our Board, our stakeholders and the community
[241] To support its commitment within its Sustainability Policy the Companys risk assessment process serves to identify potential risk factors by focussing on: Understanding the scope of what we are trying to achieve; Identification of whether the activities can be completed by SRG or require the services of an external supplier; Undertaking and analysis of the risks associated with achieving the outcome; Evaluating the likelihood and exposure
[241] SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 7 Implementing treatment strategies to mitigate the exposure to unforeseen events or circumstances; and monitoring, reviewing and communicating
[241] Buy Local We recognise that Australia holds strong and regulated importation and manufacturing regulations to support local industry
[241] SRG will continue to procure where practical, the services of Australian suppliers to support its operations however recognises that this is not viable in all circumstances
[241] Education and Treatment Supplier Onboarding and Management To support the identification and assessment of slavery exposures in addition to wider human rights exposures, SRG has commenced the establishment of a Supplier Onboarding and Management procedure capturing the life cycle of external suppliers
[2824] global slavery index data
[2824] qualitative assessment in conjunction with industry bodies
[2824] industry commentary on modern slavery, and
[2824] a de minimis spend threshold of $5,000
[2824] Out of the thousands of suppliers to our operations, the assessment process yielded a result of 38 higher risk suppliers with which we have focussed our efforts and conducted enhanced due diligence in respect of modern slavery risks
[2824] Our actions described in pages 5-8 detail how we began engaging with these suppliers and, of course, any further development during the 2020-21 financial year will be reported in our next modern slavery statement
[2824] Further, there is a dedicated procurement function to manage the contracting, delivery and relationship process end to end alongside the relevant business unit within UniSuper
[2824] As part of this function, the appropriate contracting approach is determined in accordance with the reporting entitys procurement strategy
[5169] These audits can be internal (performed by corporate) or contracted to independent third party organisations, and remedial actions identified are implemented within the calendar year under the oversight of the mine site General Manager
[5169] Resolute will follow this approach to ensure ongoing compliance with human rights and modern slavery best practice and standards
[5169] In 2021, Resolute will perform a human rights review across all its