mila-ai4h/AIMS.au huggingface dataset:
[7476] How the Lakehouse Small Companies Fund assesses the effectiveness of actions to assess and address risks 7 Consultation process 7 Other relevant information 7 Approval 8
[7476] Background This document is a Modern Slavery Statement (Statement) made pursuant to section 14 of the Modern Slavery Act 2018(Cth) (the Act)in respect to the financial year ending 30 June 2021 (the Reporting Period) in relation to Lakehouse Small Companies Fund a Reporting Entity under the Act
[7476] The Statement is issued by Equity Trustees Limited ABN 46 004 031 298 (ETL or Responsible Entity) in its capacity as the Responsible Entity of the Reporting Entity in accordance with the Act and has been approved by the Board of ETL as their principal governing body This Statement discloses ETL and the Funds commitment and steps taken in identifying and addressing modern slavery risks within its business and supply chain, which includes the activities implemented in financial year ending 30 June 2021
[7476] This is the first Statement for the Lakehouse Small Companies Fund
[7476] Structure, operations and supply chains of the Reporting Entity Fund Structure Lakehouse Small Companies Fund (also referred to as the Fund) is a registered managed investment scheme, ARSN 615 265 864
[11820] Our sister human services organisation, Aspire4Life, tailor inclusive planning, assessment and case management services which have the needs of the individual at their core and are delivered with respect and understanding
[11820] Our service footprint covers six states and territories across eastern and southern Australia
[11820] As a result, Feros Care is supported by over a combination of direct employees, volunteers and a range of workforce contractors and suppliers of goods and services
[11820] Our supply chains Feros Care procures goods and services needed for completion of day-to-day activities from a range of contracted and preferred suppliers operating in Australia
[11820] Our long-term, strategic relationships with key service partners, contractors and suppliers provide a level of stability in our supply chain and procurement processes
[11820] Our supplier selection and on- boarding procedures includes due diligence of the suppliers reputation, respect for the law, compliance with health, safety and environmental standards, and references
[11820] Our supply chain arrangements include contractors and suppliers from the following key areas
[11820] Corporate Procurement inclusive of goods and services such as stationary, consumables, office equipment and information technology
[1033] NetApps internal policies and practices incorporate key concepts of the RBA Code and are consistent with international labor and human rights standards
[1033] NetApp is committed to complying with the changes to the U.S
[1033] Governments Federal Acquisition Regulation with regard to Ending Trafficking in Persons, and we expect our suppliers to comply
[1033] (See our Purchasing Policy: Combating Trafficking in Persons.) We work with our supply chain to promote an environment in which workers may freely choose employment
[1033] This focus on labor and worker rights is part of a larger effort around supply chain transparency and accountability
[1033] Structure, operations, and supply chain organization NetApp is a provider of storage and data management solutions for data-intensive enterprises
[1033] NetApp storage solutions include specialized hardware, software, and services for open network environments
[1033] We use a multichannel distribution strategy: We sell our products, solutions, and services to end-user business customers and service providers through a direct sales force and an ecosystem of partners
[3847] MACH Energy employs approximately 40 people to manage its operations by providing support through finance, human resources, environment, safety, legal, marketing, logistics, and sales functions
[3847] MACH Energys corporate (and registered) office is located in Newcastle West, NSW but personnel are also based at Mount Pleasant and in Brisbane, QLD
[3847] Description of the Supply chain By way of overview, Mount Pleasants supply chain consists of the following broad categories of suppliers
[3847] Main contractors, who are responsible for mining, coal handling and washing, transport and export of coal
[3847] Other suppliers, who are responsible for various functions at an operational and/or corporate level; and
[3847] Suppliers to R2P, who are delivering this important infrastructure construction project
[3847] Main Contractors Open cut coal mining at Mount Pleasant is conducted by Thiess Pty Ltd under a mining services contract, which represents the most significant spend for MACH Energy
[3847] Operation of the coal handling and preparation plant and train load out facility is the responsibility of Sedgman Pty Ltd under an operate and maintain services contract
[7476] ETL is the responsible entity of the Fund
[7476] Its investors are classified as retail and wholesale clients pursuant to the Corporations Act (Cth) 2001
[7476] The Board of Directors of ETL govern the Funds operations
[7476] Its investments and investment strategy are managed by Lakehouse Capital Pty Ltd (Lakehouse) pursuant to an Investment Management Agreement (IMA) between ETL and Lakehouse
[7476] The business activities of the Fund are conducted in accordance with high levels of ethical and professional standards and in accordance with relevant laws in Australia
[7476] The Fund is committed to mitigating the risk of modern slavery in the business and supply chains of the Fund and the assets in which it invests
[7476] About Equity Trustees ETL is a wholly owned subsidiary of EQT Holdings Ltd which is a diversified financial services company publicly listed on the Australian Securities Exchange (ASX: EQT)
[7476] ETL holds an Australian Financial Services Licence (AFSL) no
[11820] Operational Procurement inclusive of goods and services required for the care of our residents living in our villages and for our in-home community clients, personal protective equipment, linen, recruitment and training, labour hire contractors and agencies; and
[11820] Capital Works & Property including building material, equipment, body corporate and construction related services
[11820] Risk assessment
[11820] Feros Care believes there is minimal risk of modern slavery in our directly employed workforce due to the existing protections and regulations in the Fair Work Act that apply to the assessment, aged care and disability support sectors, along with the presence of unions who represent employees by negotiating employment conditions
[11820] The same protections and regulations are also applicable to our preferred service partners and contractors who operate in these sectors, further reducing any risk
[11820] Feros Care commenced the process of conducting a risk assessment of our supply chain once we identified we met the threshold requirement for reporting
[11820] We initially embarked on a staged approach to assessing and mapping our supply chain, commencing with our top 50 suppliers
[11820] We have assessed the business services rendered by these suppliers and whether they currently report and meet Modern Day Slavery reporting requirements
[1033] NetApp outsources manufacturing operations to third parties located in different countries around the world
[1033] We rely on a limited number of suppliers for materials, as well as several key subcontractors for the production of certain subassemblies and finished systems
[1033] The reporting entity for the purposes of the Australian Modern Slavery Act 2018 (Cth) is NetApp Australia Pty Ltd (NetApp Australia)
[1033] NetApp Australia is a marketer and distributor of NetApp products in the Australian market and a provider of postsales customer support and consultancy services
[1033] NetApp Australia uses external vendors, such as marketing, professional services, real estate, and facilities suppliers, which are largely contracted through a third party
[1033] It does not own or control any other legal entities
[1033] Certification and verification NetApp has taken actions to ensure transparency and to prevent abuses in our supply chain, including the following
[1033] Supplier Code of Conduct
[3847] The transport of coal from Mount Pleasant to either domestic customers or the Newcastle port (for export customers) is performed by Aurizon and Australian Rail Track Corporation (ARTC) under a long term contracts with MEA
[3847] The rights to use either of the two coal storage and ship loading facilities at the Newcastle Port are contained in contracts with each of Newcastle Coal Infrastructure Group (NCIG) or Port Waratah Coal Services (PWCS)
[3847] Annexure B contains a diagrammatic representation of these main contractor activities
[3847] MACH Energy is only responsible for supplying coal to its customers on a free on board basis, meaning it does not charter vessels
[3847] The main contractors referred to in this section are all Australian based and predominantly Australian owned entities
[3847] These contractors have reporting responsibilities under the Modern Slavery Act and MACH Energy intends to engage more deeply with them in the next reporting period
[3847] Other Suppliers MACH Energy directly engages many other suppliers of goods and services across its business to support its open cut coal mining operation at Mount Pleasant
[3847] These suppliers can be grouped into the following categories
[7476] It acts as a trustee and responsible entity for a range of managed investment schemes and unit trusts of which the Fund is one
[7476] ETLs registered office is Level 1, 575 Bourke Street, Melbourne, VIC 3000, Australia
[7476] About Lakehouse Capital Pty Ltd Lakehouse is a proprietary limited company registered in Australia
[7476] Lakehouse is wholly owned by The Motley Fool Australia Pty Ltd which is itself ultimately 100% owned by The Motley Fool Holdings (TMF)
[7476] Lakehouse holds an AFSL 526842
[7476] It acts as investment manager for two managed investment schemes
[7476] Lakehouses registered office is Suite 3, Level 9, 20 Hunter Street, Sydney NSW 2000, Australia and employs 12 workers
[7476] Operations and supply chains The Funds investment objective is to outperform the S&P/ASX Small Ordinaries Accumulation Index over rolling 5-year periods (after fees and expenses but before taxes)
[11820] To date, we have identified that a significant number are already working towards or are compliant with the requirements of the Modern Slavery Act, as evidenced by publicly available policy and modern slavery statements The Procurement team has also commenced implementing initial measures to include screening of modern slavery into procurement processes
[11820] Policies
[11820] Feros Care is currently implementing or revising the following policies to support our approach to reducing the risk of modern slavery in our operations
[11820] Whistle Blower Protection Policy - We encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation
[11820] Code of Conduct - Our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business
[11820] We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain
[11820] Organisational Sustainability Policy We uphold a commitment to practices and standards designed to promote economic, social and environmentally responsible operations with the aim of achieving a holistic practice and culture of organisational sustainability whilst meeting its core purpose
[11820] Procurement Policy We will revise to formally include modern slavery clauses that will also be applied to operational processes
[1033] NetApps Supplier Code of Conduct is aligned with the RBA Code and incorporates its key sections, including workers rights, the eradication of forced labor, working conditions, and supplier accountability and reporting of nonconformance
[1033] NetApp encourages and, in some cases, requires suppliers to adhere to the RBA Code of Conduct, including implementing a management system and audits and completing the RBA Self-Assessment Questionnaire (SAQ)
[1033] The SAQ, which includes an assessment of the suppliers policies and practices, helps NetApp identify whether any human trafficking risks exist
[1033] NetApp expects its suppliers to read and abide by the standards outlined in NetApps Supplier Code of Conduct (including the suppliers to its Australian operations)
[1033] NetApp supplier and partner agreements
[1033] Compliance with the RBA Code is part of NetApps standard contract language
[1033] Where NetApp contracts with services suppliers who participate in a U.S
[1033] Government contract or subcontract, it flows down applicable clauses to its suppliers, such as FAR Clause 52.222-50, Combating Trafficking in Persons
[3847] Site maintenance including services such as weed and pest management, waste removal, dust suppression, water pumping, catering, supply of personal protective equipment, and cleaning
[3847] Site infrastructure such as civil works, road construction and maintenance, carpark (re)surfacing, site drainage, erosion and sediment control, and other similar services
[3847] Energy such as electricity and fuel supplies
[3847] Communications including data and phone, information technology, records management and real time environmental monitoring systems
[3847] Specialist consultants including engineers, designers, tenement managers, environmental scientists, air quality analysts, and environmental auditors
[3847] Critical spare parts for the wash plant, train load out facility and materials handling infrastructure
[3847] Residential property maintenance for MACH Energys various residential land holdings there are services such as real estate managers, builders, demolition contractors, and valuers
[3847] Mining analysis this includes geological services, exploration drilling, mine planning and project management services
[7476] The Funds investment strategy is to invest in a high conviction portfolio of 15 to 30 small companies listed in Australia and New Zealand
[7476] The investible universe consists of companies outside the S&P/ASX 100, though the Fund may continue to hold companies that grow into the ASX 100 as letting winners run is part of the Funds long-term strategy
[7476] The Funds investment management operations include active investments across listed equities in Australia and New Zealand
[7476] These are managed by one investment manager relationship domiciled in a single country (ie Australia)
[7476] The investment manager forms part of the Funds supply chain and is listed on the Funds website here https://www.lakehousecapital.com.au/lscf/
[7476] In preparing this statement, the Funds direct supply chain has been considered
[7476] The Funds operations and supply chains involve custody and administration of assets and also include several support functions including marketing and communication, governance, risk and compliance services and human resources
[7476] These support functions are provided by ETL and other external service providers
[11820] Future Commitments
[11820] In the next 12 months, Feros Care commits to the following actions
[11820] Map and assess all suppliers to determine the response and risk controls to be implemented, including
[11820] consider the services rendered by the suppliers and the location of where any supplies are manufactured
[11820] the risk profile of the locations where the supplier operates or the location of where the supplies are manufactured, to determine a risk profile based on the Global Slavery Index; and
[11820] whether there is a risk of the presence of vulnerable demographic groups
[11820] Update our standard procurement agreements to include contractual obligations to address modern slavery compliance for all new and existing service partners, contractors and suppliers
[11820] Develop awareness education for the workforce and our clients, residents and participants in relation to their role in eliminating modern slavery
[1033] Supplier risk assessments and audits
[1033] NetApp uses the RBA assessment process to identify the risks of noncompliance by RBA member suppliers with NetApps Supplier Code of Conduct and RBA Code, including the actual or potential risks of slavery and human trafficking occurrences
[1033] As a part of NetApps overall participation in the RBA's collaborative audit effort, we expect RBA member suppliers to annually assess their conformance with the tenets of the Supplier Code of Conduct and RBA Code
[1033] Completion of the RBA SAQ includes an assessment of the suppliers policies and practices that may give rise to human trafficking risks
[1033] NetApp may also require audits of RBA member suppliers, via a third party, if deemed necessary to verify their conformance to the RBA Code and related standards and policies
[1033] Third-party audits follow the RBA Validated Audit Process (VAP), which includes an assessment of the suppliers risks and controls regarding human trafficking
[1033] If nonconformance is identified, we monitor the suppliers activities to develop corrective action plans and close audit findings
[1033] For the purposes of the Australian Modern Slavery Act 2018 (Cth), NetApp Australia has carried out a modern slavery risk assessment and has assessed that there is a low risk of modern slavery practices in its operations and supply chains
[3847] Corporate services such as legal advisers, accountants, auditors, office accommodation, stationery, telecommunications, IT services, and specialist consultants
[3847] Travel air travel, hotel accommodation, taxis, and car hire services
[3847] Suppliers to Rail 2 Project (R2P) The supply chain for the R2P consists of a project management function (known as the owners team) that oversees a number of sub-projects, or packages
[3847] The owners team is made up of a third party project management contractor that oversees a team of personnel that are either MACH Energy employees or contractors
[3847] This model of construction contract is not uncommon and allows the owners team greater control over budget and schedule by individually managing the multiple contractors delivering each package
[3847] The R2P packages are as follows
[3847] Materials handling consisting of the fabrication and supply of an overland conveyor and train load out facility together with associated civil works, electrical and commissioning services
[3847] Rail loop this is the principal element of R2P consisting of civil works and track building of the approximately 5km long private siding
[7476] Internal policies and procedures in relation to the selection of service providers are followed and service providers are typically selected after a due diligence (financial & operational) process which includes risk assessments and thorough reviews with internal subject matter experts
[7476] ETL, as Responsible Entity of the Fund, has entered into agreements with each of the service providers which govern the nature and scope of the services to the Fund
[7476] Administration and Custody of the Funds assets are held via Mainstream Fund Services Pty Ltd which has operations in Australia and a number of international jurisdictions including North America, Europe and Asia
[7476] Risks of modern slavery practices in operations and supply chains of the Reporting Entity Modern slavery has been defined by the Act to includes eight types of serious exploitation, including
[7476] Trafficking in persons
[7476] Slavery
[7476] Servitude
[7476] Forced labour
[11820] Revise and develop our compliance to modern slavery to build capacity within the organisation to monitor, and act on modern slavery risk
[11820] Develop a set of key performance indicators and controls to measure our performance in combatting modern slavery, inclusive of reporting frequency and audiences
[11820] Feros Care and Aspire4Life will manage modern day slavery through their risk management framework, policy and procedures and will consult with and report modern slavery to their respective governing bodies
[11820] Process of Consultations
[11820] The Board of Feros Care has consulted with the Executive Leadership and endorses the approach and activities taken by the organisation in order to mitigate against any risks of modern day slavery
[11820] This statement has been prepared by the Executive and the Board have consulted with the Executive and will continue to consult with the Executive in relation to the organisations activities to identify modern day slavery risks and eliminate modern day slavery practices
[11820] Signed on behalf of the Executive of Feros Care
[11820] Karen Crouch, CEO
[1033] Due to the nature and structure of its operations and supply chains, NetApp Australia relies on the actions taken at a global level to assess and address any risks identified
[1033] The specific steps that NetApp Australia has determined to take to respond to its low level of risk are outlined in Training and Awareness, below
[1033] Given that this is the first year that NetApp Australia has reported under the modern slavery legislation, they will assess the effectiveness of these steps before the next reporting period
[1033] Assessment of effectiveness
[1033] NetApp reviews the scores of the SAQ completed by its suppliers who are members of the RBA to confirm that they are not deemed to be a high risk
[1033] NetApp Australia relies on the assessment of NetApp and does not carry out additional assessments
[1033] Internal Accountability NetApps Code of Conduct, which contains specific provisions on procurement from suppliers, vendors, contractors, and supply chain relationships, provides guidance to enable employees to put our companys values into practice
[1033] It is available in seven languages on NetApps intranet and in English on our companys external website
[3847] Signalling owing to its complexity and safety critical nature, signalling design and construction for the private siding and turnout from the mainline is a standalone package
[3847] Design a third party design house was retained to provide detailed design services
[3847] Overlap MACH Energy notes that there are several common suppliers within the latter two categories of the supply chain above, most notably demolition, electrical, labour hire, pumps and pipes, and some civil works services
[3847] Modern slavery risk assessment MACH Energy recognises that risks of modern slavery in the mining sector relate to the location and types of operations that are being undertaken, the make-up of the workforce, and the nature and source of equipment and materials used in the operations
[3847] It has assessed the risks of modern slavery in the first tier of its supply chain over the course of 2020, other than for the Main Contractors, and generally considers that risk to be low in the case of its direct suppliers as all of its direct suppliers are Australian registered companies or resident individuals
[3847] Within the supplier categories, however, we recognise that there are areas of higher risk such as, in site maintenance and security, the supply of personal protective equipment and cleaning
[3847] In addition, several suppliers to MACH Energy source their goods from overseas, for example
[3847] Suppliers of plant and spare parts for use in the coal handling and preparation plant typically assemble goods locally using components sourced from multiple countries including China, France, the United Kingdom, America, and the United Kingdom
[7476] Forced marriage
[7476] Debt bondage
[7476] The worst forms of child labour
[7476] Deceptive recruiting for labour services
[7476] It is acknowledged that the following types of modern slavery risks and their indicators that can exist in the Funds operations and supply chains as well as in the equity holdings of the Fund: Sector and industry risk: Certain sectors and industries may have high modern slavery risks because of their characteristics, products and processes