mila-ai4h/AIMS.au huggingface dataset:
[5284] Across the regions in which we operate, our suite of policies and employee handbooks contain the following policies
[10291] Atturras modern slavery obligations and policies, procurement process, and awareness of modern slavery risks are communicated to Atturras employees through live and recorded training sessions
[10291] This training is delivered to senior management and personnel involved in procure- ment such as staff in the Marketing, HR, Talent Acquisition, Finance and IT departments
[10291] We encourage our directors, senior managers, suppliers, contractors and personnel to report any concerns or suspected breaches to our Anti-Slavery Policy
[10291] The Atturra Whistleblower Policy protects and safeguards the con- fidentiality, wellbeing and career of any individual who asserts any issues that affect the integrity of Atturras business operations
[10291] e) Whistleblower Protection: Atturras Whistleblower Policy protects employees, service providers and suppliers who voice their concerns about certain events or conduct in the business that may be unlawful or unethical
[10291] The policy validates Atturras efforts in safeguarding the confidenti- ality, wellbeing and career of any individual who asserts any issues that affect the integrity of Atturras business operations
[10291] f) Continuous monitoring and Public Communication: Atturra will continue to monitor and assess modern slavery risks and we will publicly communicate our actions taken to address these risks by publishing a Modern Slavery Statement annually (as required)
[10291] Atturra Modern Slavery Statement FY22 Atturra is focused on continuously strengthening its proce- dures and processes to combat modern slavery practices and ensuring the protection of human rights
[373] We consider that, on the whole, the implementation of our company values and policies establishes an ethical culture and environment in which knowingly allowing human slavery or abuse to enter Tolls operations or supply chain will not be tolerated
[373] A copy of these policies is publicly available on our website
[373] Supplier Governance Framework The Toll Group Supplier Code of Practice (Supplier Code") sets out the behaviours Toll expects from suppliers
[373] This includes Tolls expectation that our suppliers will act with respect and comply with applicable employment and workplace laws and regulations, including labour and child labour laws
[373] The Supplier Code reserves Tolls right to audit suppliers and their operations
[373] If a supplier fails to act consistently with the Supplier Code or specific contractual obligations, this may result in remedial action or termination of a contract
[373] The Supplier Code is available on our website
[373] Review of Operations and Supply Chains In 2019 Toll commenced a review of our potential modern slavery risks across our operations and supply chain
[3584] underwriting guidelines), and governance instruments
[3584] This enables us to reduce or mitigate risks with regard to violations of human rights; these approaches also guide our decision-making in line with conscientious management practices
[3584] As an employer, Munich Re observes international human rights standards and provides optimum working conditions for its staff with special focus on occupational health and safety, promoting diversity, and equal opportunities
[3584] Our Group-wide Diversity Policy sets down the most important principles in this action field and forms the basis for overarching and comprehensive diversity management
[3584] The focus areas of gender, different generations and internationality are key for our activities
[3584] Equal treatment is an inherent part of our corporate culture
[3584] Our Code of Conduct and additional self-commitments for responsible behaviour specify that we expect our employees to observe the personal dignity, privacy and personality rights of every individual
[3584] We do not tolerate any discrimination (on grounds of age, sex, ethnic origin, nationality, political opinion, race, religion or the like), sexual harass- ment, other personal harassment, or insulting behaviour
[5284] Code of Conduct
[5284] Background Checking
[5284] Communication Guidelines
[5284] COVID-19 Policy
[5284] Customer Service Standards Policy
[5284] Environmental Statement
[5284] Equality and Diversity Policy
[5284] Ethical Sourcing Policy
[10291] In doing this, we aim to build more transparent and open relationships with our suppliers in order to mitigate the risk of modern slavery in our operations and supply chain
[10291] In preparation of this Statement, Atturra consulted with external legal advisers on its modern slavery processes to comply with requirements under the Act and to advise on best practice
[10291] Atturra will continue to monitor, evaluate and assess the effec- tiveness of its established procedures by
[10291] monitoring Atturras existing suppliers and undertaking risk assessments in relation to new suppliers to as certain whether they pose a modern slavery risk and, if they do, to reduce that risk to the maximum extent possible
[10291] continually assessing the effectiveness of our actions in identifying and managing modern slavery risks, particularly by undertaking regular internal governance processes in accordance with our governance policies
[10291] reviewing and updating training material to ensure that it is up to date, relevant and effective
[10291] reviewing Atturras policies and implementing a Supplier Code of Conduct for the next financial year to ensure they remain relevant and in compliance with all applicable laws; and
[10291] engaging with Atturras suppliers and key customers to verify they are following through with any modern slavery actions they have committed to undertaking
[373] This review began with identifying the relative risk of the countries in which we operate using the Global Slavery Index (GSI)
[373] We also engaged with key internal and external stakeholders to gain a better understanding of the potential risks
[373] Toll will build on this work in FY21 by undertaking a formal human rights risk assessment to identify and prioritise human rights risks, including those relating to modern slavery
[373] Given the global and diverse nature of our operations and supply chain we will take a step-by-step approach to addressing the identified risks to ensure they are addressed in a robust and effective manner
[373] Further to this, modern slavery questions have been added to the global Compliance Due Diligence questionnaire which was updated in late 2019 which is used as a tool to identify and engage with our network agents5
[373] This was rolled out in late 2019 with a review undertaken in early 2020 to improve the process
[373] In FY20, Group HR initiated a global review of procedures for engagement of labour and recruitment practices globally with the aim to develop a unified approach throughout our growing global operations
[373] As part of this review additional controls are being considered to mitigate modern slavery risks and we are working towards reducing the total number of recruitment agencies
[3584] With regard to all our procurement decisions and activities, we always observe the principles of compliance, and we embrace corporate responsibility throughout the value chain
[3584] Environmental, social and governance (ESG) criteria play a pivotal role in our procurement of goods and services
[3584] We ensure compliance with ESG criteria and acceptance of the ten principles of the UN Global Compact in our day-to-day interaction with suppliers
[3584] To ensure compliance with the UN Global Compact within the supplier relationship, Munich Re implements a Corporate Responsibility (CR) clause into its standard contracts
[3584] If we believe the principles of the UN Global Com- pact have been breached, Munich Re reserves the right to cancel the contractual relationship by way of extraordinary termination for good cause
[3584] If a new supplier wishes to do business with Munich Re, it must first complete a supplier registration process
[3584] Using a self-disclosure questionnaire, it is requested to provide key informa- tion on the subject of sustainability
[3584] This information also addresses aspects relevant for exclusion criteria (refusal to sign the CR clause can be an exclusion criterion)
[5284] Fair and Equitable Workplace
[5284] Gifts and Gratuities Policy
[5284] Grievance Handling Policy
[5284] HR Privacy Policy
[5284] ICT System Usage Policy
[5284] Leave Policy
[5284] Drug and Alcohol Policy
[5284] Manual Handling Policy
[10291] Consultation COVID-19 pandemic Throughout the COVID-19 pandemic, Atturra has consistently complied with Australian government regulations and health advice to ensure the health and safety of our personnel
[10291] To date, the COVID-19 pandemic has had a minimal impact on Atturras operations as our consultants are generally able to work remotely
[10291] However, Atturra recognises this may not be the case for its suppliers and/or stakeholders
[10291] While there has not been an increased risk of modern slavery due to COVID-19 for Atturras operations or supply chain, Atturra has continued to prioritise stakeholder and supplier engagement to ensure modern slavery risks are identified, assessed and mitigated in the context of the COVID-19 pandemic during the reporting period
[10291] Future commitments Atturra is committed to further developing our processes as we progress our understanding about the modern slavery risks in our operations and supply chains and ways to mitigate them
[10291] Atturra takes a continuous improvement approach to compli- ance to ensure that we are demonstrating our progress over time as the business community increases its understanding of modern slavery
[10291] Over the next year, we intend to continue assessing the risks in our operations and supply chain through our Modern Slavery Committee, supply chain mapping, ques- tionnaires, training and other actions taken
[10291] The board of directors in their capacity as principal governing body of Atturra Limited have approved this Statement on 7 October 2022
[373] We are also implementing a global recruitment system which will be integrated into our existing HR system
[373] This will help to ensure that our policies and procedures are executed consistently throughout our operations
[373] At Toll, a Network Agent is an entity with which Toll Global Forwarding establishes a documented non-exclusive business relationship whereby Toll Global Forwarding and the Network Agent on behalf of each other perform and handle freight transportation and other related services (including international and domestic cargo transportation and logistics), limited to specific defined territories
[373] Page 4 of 5 Whistleblower Hotline In December 2019, Tolls new Group Whistleblower Policy came into effect
[373] This was accompanied by an extensive communication campaign aimed at increasing internal awareness of the policy and the Toll Disclosure Hotline
[373] This included widespread communications via the intranet, staff newsletters and throughout our physical operations
[373] Training was also provided to relevant employees with additional information and support to those with direct obligations and responsibilities
[3584] Within the supplier registration process, it is mandatory for the supplier to confirm compliance with the UN Global Compact
[3584] Munich Re has signed up to the Principles for Sustainable Insurance (PSI) and as such is committed to implementing ESG aspects that are relevant for our (re-)insurance business
[3584] The Munich Re human-rights risk mapping tool makes it possible to categorise all countries and sectors according to various human rights aspects, especially in the areas of child labour and modern slavery
[3584] This tool enables all our employees to carry out an initial risk analysis quickly and easily
[3584] A set of underwriting guidelines defines how all underwriters and client managers are to handle ESG risks in insurance transactions
[3584] These binding guidelines as well as best-practice recommendations were drawn up for sensitive topics and industry sectors; they are applicable for reinsurance, primary insurance and investment
[3584] These documents place particular emphasis on child labour and forced labour in mining, farming, and along their respective value chains, as well as the forced resettle- ment of indigenous communities
[3584] Human rights risks that threaten our reputation are presented as part of due diligence to the Reputational Risk Committee, which then takes a decision, possibly rejecting the risky course of action
[5284] Mental Health Policy
[5284] Our Way of Working
[5284] Police Records Checking Policy
[5284] Recruitment and Selection Policy
[5284] Recruitment Referral Policy
[5284] Remuneration Policy
[5284] Smoke Free Workplace Policy
[5284] Social Media Policy
[10291] This Statement is signed by Stephen Kowal in his role as Chief Executive Officer and Director of Atturra Limited and the information in this Statement is accurate as of 30 June 2022
[10291] Atturras corporate governance policies, practices and pro- cedures, including our Anti-Slavery Policy, apply to all entities of Atturra Limited
[10291] During the Reporting Period this Statement covers, and in preparing this Statement, Atturra has consulted with key personnel within the entities it owns or controls, as required under section 16.1(f) of the Act, to ensure a compre- hensive approach to detecting and preventing modern slavery risks
[10291] We discussed details of the Acts reporting requirements and criterion regarding the actions we intend to take to address these requirements
[10291] By doing this, we ensure our key personnel are aware of our commitment to identifying, assessing and addressing modern slavery risks in our supply chain and are conscious of the actions they need to take in accordance with this Statement
[10291] Atturras supply chain mapping process is conducted through an analysis of each individual business unit prior to categoris- ing suppliers by risk
[10291] Additionally, modern slavery awareness training has been delivered to Atturras Executive General Managers and all other personnel involved in supplier pro- curement within Atturra
[10291] /10/22
[373] The Toll Disclosure Hotline enables employees and suppliers in certain Toll locations to anonymously report suspected misconduct, including matters relating to labour practices and human rights
[373] It is managed by a third party which helps to maintain anonymity of whistleblowers as well as protecting data privacy
[373] The system also enables communication between Toll and the whistleblower to ensure they are kept informed of the outcomes of subsequent investigations
[373] Information on how to access the hotline is readily accessible in 20 languages to ensure all parties have equal access
[373] All allegations received are reviewed and appropriately investigated
[373] Toll takes a timely and proportionate approach to implementing corrective or disciplinary actions and learnings
[373] This includes working with managers and other relevant employees to implement necessary changes to prevent any further breaches occurring in the future
[373] Training Our ability to identify and respond to human rights issues is heavily reliant on our employees identifying and reporting potential breaches
[3584] Munich Res Statement on the Australian Modern Slavery Act Page 4/6 GLISE operates an agency model for accessing insurance business but recognises delegated authority can present greater risk due to the operational separation of such arrangements
[3584] GLISE includes contractual obligations on agents to not commit any criminal activity
[3584] It also expressly instructs agents to exercise care and skill in sub-delegating or performing their duties
[3584] The need for personnel to have profes- sional qualification and experience is part of this duty, which is accepted to reduce the likeliness of working conditions that could constitute an offence
[3584] Our Agency function conducts due diligence when onboarding (re)insurance business and any concerns around modern slavery or human trafficking are escalated
[3584] Our dedicated Agency Audit function also includes the topic of Modern Slavery to the scope of audits
[3584] Because Munich Res business model as an insurer has a long-term focus, sustaina- bility criteria play a key, strategic role in investment
[3584] We are obligated to invest our clients money sensibly and profitably in a manner that adheres to strict security and return requirements
[5284] Team Member Purchases Policy
[5284] Workplace Health and Safety Policy
[5284] Number: 2.1 Page: 5 Date: 20 June 2021
[5284] Existing governance in our international regions includes independent grievance mechanisms and risk monitoring in our China operations
[5284] Our work going forward is to gain further understanding of their effectiveness and explore how they are responding to the nature of risks specific to their region
[5284] Our internal policies and checklists are continuously reviewed for improvement to tighten our due diligence around preventing the above forms of modern slavery
[5284] Suppliers found to not be compliant with our internal checklist and policies are prevented from engaging with Ally Fashion until these issues are confirmed as remedied
[10492] P 1300 119 919 E info intellihub.com.au www.intellihub.com.au Unit D1, 15 21 Doody Street, Alexandria, NSW 2015, Australia 1
[10492] INTELLIHUB GROUP MODERN SLAVERY STATEMENT DocuSign Envelope ID: 6B496E5F-D8EC-41BA-A7E5-7DDC90A692EF
[10492] P 1300 119 919 E info intellihub.com.au www.intellihub.com.au Unit D1, 15 21 Doody Street, Alexandria, NSW 2015, Australia 2
[10492] au www.intellihub.com.au Unit D1, 15 21 Doody Street, Alexandria, NSW 2015, Australia P 1300 119 919 E info intellihub.com
[10492] THIS STATEMENT ADDRESSES THE PERIOD FROM 1 JULY 2021 TO 30 JUNE 2022
[10492] INTRODUCTION 2 THE INTELLIHUB BUSINESS 3 ASSESSING OUR RISK 4 OUR ACTIONS 6 APPROVAL AND SIGNATURE
[10492] DocuSign Envelope ID: 6B496E5F-D8EC-41BA-A7E5-7DDC90A692EF
[10492] P 1300 119 919 E info intellihub.com.au www.intellihub.com.au Unit D1, 15 21 Doody Street, Alexandria, NSW 2015, Australia
[373] As such, it is vital that employees have a good understanding of what human rights and modern slavery issues are; how to report them and how to address them
[373] Toll continues to raise awareness of modern slavery with training and e-Learning on the Code of Conduct together with ongoing consultation on modern slavery in higher-risk areas within the business (Procurement department)
[373] In FY20, customised training was provided to the Group Procurement team to give an overview of Modern Slavery, identify the relevant risks to Toll and outline their role in addressing these risks
[373] Our induction e-Learning modules for all employees have also been updated to contain sections on Modern Slavery and Human Rights, with reference to our Anti-Modern Slavery Policy
[373] In FY21 we will continue to build on this with the roll out of a dedicated e-Learning module on Modern Slavery
[373] COVID-19 Response Strict safety protocols were implemented throughout Tolls operations including the provision of appropriate protective gear, social distancing, regular disinfection of workspaces and contactless deliveries to protect the health of our employees
[373] We have also worked closely with our suppliers, contractors and clients to ensure their employees are also implementing similar processes
[373] To prevent the risk of employees and contractors being forced to work long hours we have reinforced our strict policies regarding working hours which have been closely monitored to ensure working conditions are safe
[3584] Therefore we have committed to observing the Principles for Responsible Investment (PRI) and consider it essential to integrate ESG aspects in our investment processes
[3584] For the majority of Munich Res investments, our target is to be sustainable in accordance with our Group-wide Responsible Investment Guideline (RIG), and we track our progress in this regard in an internal sustainability index
[3584] Over 80% of our relevant investments were invested sustainably in 2020
[3584] We systematically incorporate individually defined ESG criteria into the selection pro- cess for the different asset classes
[3584] For investments in equities and bonds we use sustainability indices, ratings and specific ESG research by MSCI, which also includes human rights issues
[3584] In the asset classes of infrastructure, renewable ener- gies, forestry and farmland, ESG aspects including human rights issues are reviewed in the due diligence process for investments
[3584] We regularly review our sustainability criteria for all assets
[3584] b) General measures Monitoring systems help us examine the effectiveness of our measures
[5284] Industries which make use of short-term contract, migrant labour and labour hire agencies such as cleaning, third party warehousing, freight and logistics pose greater risks and as such will be a focus of our efforts
[5284] Over the course of the next reporting period, Ally Fashion will engage in internal and third-party audits to verify the continuous compliance of suppliers and contractors with our internal policies and Code of Conduct
[5284] Whilst audits in some regions will be hampered by the current pandemic, audit assessments will attempt to be conducted virtually, such that business operations can continue with minimal risks
[5284] Our Code of Conduct for Team Members, Suppliers, and Contractors addresses forced labour risks including child labour and debt bondage
[5284] The Code of Conduct, coupled with our Ethical Sourcing Policy, governs the minimum requirements of our trading relationships
[5284] To assist with compliance and understanding, our Supplier Code of Conduct will also be translated into Mandarin for our China-based factories
[5284] We recognise that modern slavery risks exist beyond level-one into further levels of the supply chain
[5284] We have visibility of a portion of our level-one fabric mills and, whilst mapping of this level continues, further due diligence of our most strategic suppliers will allow us to identify whether these facilities have undergone social assessments and audits
[10492] INTRODUCTION Modern slavery is one of the most complex and important human rights challenges of our time
[10492] According to the International Labour Organisation, the term modern slavery covers a set of legal concepts, including forced labour, debt bondage, slavery of children and human trafficking
[10492] Modern slavery is an umbrella term to refer to situations of exploitation that an individual cannot refuse or leave because of threats, violence, coercion, deception, or abuse of power
[10492] At Intellihub, we do not tolerate modern slavery and are fully committed to preventing slavery and human trafficking in our operations and supply chain
[10492] This statement sets out the actions that the Intellihub Group has taken to understand and address potential modern slavery risks related to our business
[10492] STRUCTURE Intellihub Group is made up of privately held Australian and New Zealand companies, employing over 300 people across offices in Sydney, Melbourne, Auckland, Hobart, and Brisbane
[373] Assessment & Effectiveness of our Actions Toll recognises the importance of monitoring how effective our anti-modern slavery processes are and we have actively taken steps to review our approach to assessing and addressing modern slavery risks
[373] In our own operations we utilise our global network of dedicated employees to oversee the effectiveness of the relevant actions taken to address modern slavery
[373] This includes representatives from Security and Compliance, HSE, HR and Procurement who have been trained to identify and act upon risks in our day to day operations
[373] We intend to build upon this in FY21 with the establishment of a modern slavery working group who will meet regularly to discuss actions taken and their effectiveness
[373] For our supply chain partners, we are currently working to better assess the effectiveness of our actions to address modern slavery