mila-ai4h/AIMS.au huggingface dataset:
[11660] PAGE 21 December 2022 | Document ID: A2602420 | OBJECTIVE.COM 5
[11660] In 2022 we produced a comprehensive Modern Slavery Questionnaire, which includes a number of questions for suppliers to answer that are designed to indicate whether the supplier is engaging in any Modern Slavery within its operations, or there is a risk of that
[11660] This Modern Slavery Questionnaire was provided to our top 20 key suppliers (by spend) that dont already publicly report on Modern Slavery
[11660] None of the responses received from these suppliers gave rise to a concern that any of these suppliers were at risk of Modern Slavery, and the responses did not highlight any need for us to conduct further investigations or due diligence into any of these suppliers
[11660] It is now a requirement that every new prospective supplier must complete our Modern Slavery Questionnaire, to our satisfaction, before we accept them as a supplier
[11660] As regards remediation, we have not found any examples of Modern Slavery either within our own operations or those of our supply chain, so no remediation has been necessary
[991] The revisions to our Human Rights policy were delayed, as was our modern slavery training to employees, and the additional due diligence procedures we had planned to roll out
[991] These have been incorporated into our future actions and goals for FY21
[991] In FY20, Sims Lifecycle Services personnel conducted 66 on-site audits across the globe to confirm first-hand that our operational, safety and ethical standards were being met by downstream vendors
[991] The vendors audited were located in Australia, Belgium, Canada, Colombia, Ecuador, England, Finland, France, Germany, Hong Kong, Ireland, Israel, Italy, Japan, the Netherlands, the Philippines, Portugal, Russia, Saudi Arabia, Scotland, Serbia, Spain, Sweden, Thailand, Turkey, Ukraine and the United States
[991] Sims Limited Modern Slavery Statement 2020 | 13
[991] Future Actions Improving Governance Although Sims has a Human Rights policy in place, it will be revised and published to re-emphasise our overall focus on human rights, including modern slavery
[991] Revisions to the policy will be approved by the Board of Directors to underscore the importance of the topic and set expectations
[991] Addressing Operational Risks In FY20, we developed training to educate our personnel on modern slavery
[3786] In addition to the Modern Slavery Policy, Solargain will review and improve any policies and procedures relevant to actions in relation to Modern Slavery
[3786] Assessment and Effectiveness Solargain will continue to review the effectiveness of our actions and refine our process for mitigating the risk of modern slavery
[3786] Senior management meet annually to consider and review
[3786] Whether our modern slavery risks are being appropriately identified and evaluated
[3786] - The number of actions that have been implemented in relation to modern slavery
[3786] - Supplier evaluations including modern slavery assessments and responses
[3786] Solargain PV Pty Ltd 4
[7474] We have not identified any significant areas of product services risk in the Funds operations or supply chains
[7474] Geographic risk: where some countries may have higher risk of modern slavery, including due to poor governance, weak rule of law, conflict, migration flows and socio-economic factors
[7474] We have analysed the Funds investments in respect of geographic risk and have not identified any areas of significant geographic risk in its investments
[7474] Entity risks: where an entity may have particular modern slavery risks because of poor governance structures, a record of treating workers poorly or a track record of human rights violations
[7474] We have not identified any instances of entity risk in the Funds investments and suppliers
[7474] Actions taken by the Reporting Entity to assess and address risks, including due diligence and remediation processes
[7474] The Reporting Entity is committed to continuously improving awareness and response to the risk of modern slavery in the Funds operations and supply chains
[7474] L1 Capital will undertake to do this through the following actions
[11660] However, should an incident of Modern Slavery be discovered in our supply chain, we would engage with the supplier to resolve the situation, with the key focus being on the welfare of any potential victims
[11660] Ultimately, we would terminate the relevant supplier arrangement if an appropriate resolution is not achieved
[11660] Effectiveness of above Actions (Mandatory Criteria 16(1)(e)) We are cognisant that we only met the reporting threshold under the Act on 30 June 2022, when our revenue surpassed AU$100 million
[11660] We are therefore at the start of our journey towards the goal of having robust and effective practices and procedures that ensure there is no Modern Slavery within our operations or the operations of our supply chain
[11660] Our legal and procurement teams work together to review our Modern Slavery processes and procedures, to evaluate their effectiveness
[11660] Taking into account their review and effectiveness assessment of the above actions, we note as follows: The actions taken to-date include a number of important steps towards the above goal, particularly noting the short period since meeting the reporting threshold and us making this first Statement, but we recognise we have much more to do; We are very comfortable no Modern Slavery exists within our own internal operations (anywhere globally), due to our centralised human resources function and comprehensive pre-employment checks that are run on every new employee and contractor, and noting the low risk countries we operate in
[11660] As regards our supply chain, whilst we see it as a relatively low risk, it is obviously harder to make guarantees in relation to third-party suppliers, which we have no control over and limited visibility of what may be happening behind closed doors; We are also conscious that we have so far only provided our Modern Slavery Questionnaire to a relatively small portion of our supply chain
[11660] So, during the course of our financial year 2023, we will expand the Modern Slavery Questionnaire and due diligence activities to a much larger segment of our suppliers, with a particular focus on higher risk areas such as cleaning providers, hardware manufacturers, and any suppliers located in higher risk countries; and
[991] In FY21, we will provide the training developed in FY20 to educate all of our personnel on modern slavery
[991] This includes targeted training with detailed information on risks within the company and our supply chain for those employees in Purchasing, Human Resources, Security and site management as they are in positions to detect and prevent modern slavery issues
[991] We will review our existing practices in Papua New Guinea to identify where controls can be improved to reduce the risk of modern slavery in our operations
[991] This could include changes to oversight, communication, grievance mechanisms and more
[991] Papua New Guinea Our assessment of potential modern slavery risks within our operations led us to revisit the mechanisms in place to report concerns
[991] As we worked with management overseeing our Papua New Guinea locations, it became evident that the mechanisms in place to report a grievance were not adequate for our operations
[991] Our current service provider does not support the local language spoken by many of our employees
[991] We are in process of identifying a reporting tool that allows for anonymous reporting in this local language
[3786] Supplier factory visits, observations, and results of discussions in relation to modern slavery
[3786] We recognise that there are further steps we can take to assess and address the risk of modern slavery in our operations and supply chains and to work collaboratively with our employees and suppliers to recognise modern slavery risk
[3786] During the 2020-21 financial year we are committed to continually building on and improving our modern slavery approach
[3786] Approval
[3786] This Statement was approved by the Board of Solargain PV Pty Ltd as the parent entity on 26th March 2021
[3786] ___________________
[3786] ____________________ Domenico Mercuri
[3786] Wayne Petridis Executive Director and Secretary
[7474] screening new outsourced service providers for modern slavery risks and conducting ongoing due diligence
[7474] assessing the risks of modern slavery in investment portfolios as part of the investment process
[7474] analysing and understanding the Funds supply chain more deeply, exploring options to work with suppliers and partners on an increasingly collaborative basis
[7474] developing measures to assess the effectiveness of the steps taken to enhance the Funds understanding and capacity to identify and address modern slavery risks
[7474] reviewing the requirements of any regulations and guidance issued in connection with the Act and incorporating an effective response within the Funds risk management framework
[7474] maintaining a Modern Slavery Register to track any incidents of modern slavery
[7474] ensuring that the Fund does not commence commercial arrangements with entities that contravene the UN Guiding Principles on Business and Human Rights
[7474] If any existing commercial arrangement is found to have breached the UN Guiding Principles, ensuring the Fund will take steps to reassess whether it would continue to provide services with that entity and cease commercial relations unless a satisfactory remediation process is established
[11660] PAGE 21 December 2022 | Document ID: A2602420 | OBJECTIVE.COM 6 We are also conscious of the inherent weaknesses with relying on suppliers completing a Modern Slavery Questionnaire under a self-assessment model, so we will evaluate whether there are more sophisticated, practical and effective ways to assess Modern Slavery within our supply chain
[11660] Process of consultation with Objective group entities (Mandatory Criteria 16(1)(f)) OCL and all of its owned and controlled entities (as listed in Annexure A) operate under a uniform delegated authority policy for governance which includes prioritising the absence of Modern Slavery from our operations and those of our supply chain
[11660] All lines of business within all of these entities share the same Executive Leadership Team, which ensures a consistent and transparent approach across our entire organisation
[11660] Additionally, the vast majority of Objectives procurement is managed out of our Sydney headquarters
[11660] Accordingly, this Statement has been prepared in consultation with our procurement team in Sydney
[11660] Where procurement activities have been undertaken by any of the subsidiary entities (as listed in Annexure A), they are always managed by our legal department, to ensure consistent treatment of suppliers, appropriate contract terms are put in place, and Modern Slavery assessments are performed
[991] 2021 Priorities Issuing a revised Human Rights Policy to reflect our focus on human rights Continuing to embed the Supplier Code of Conduct in our contractual agreements with suppliers Performing additional due diligence on vendors identified as presenting higher risk of modern slavery practices Continuing to increase awareness of human slavery risks through employee education and communication Refining and implementing further due diligence procedures in response to identified risk areas 14 | Sims Limited Modern Slavery Statement 2020
[991] Addressing Supply Chain Risks We will begin embedding our Supplier Code of Conduct in our vendor relations by revising our standard terms and conditions to include reference to our Supplier Code of Conduct as well as a right to audit clause
[991] We will also update our existing supplier contracts in high-risk regions
[991] We intend to refine and implement due diligence and monitoring activities to improve prevention and detection of modern slavery and other human rights issues in our operations and supply chain, focusing on identified high- risk areas
[991] As an example, the downstream vendor audits conducted by Sims Lifecycle Services will be expanded to explicitly include other modern slavery risks such as sourcing of employees and conditions of employment
[991] The implementation of these new procedures will include educating affected employees on the importance of the new processes for reducing the risk of modern slavery within Sims and our supply chain
[991] We will also define key performance indicators to assess the effectiveness of these new processes
[991] At Sims, we know that in pursuit of our purpose to create a world without waste to preserve our planet, we can directly and indirectly impact peoples human rights
[3786] Director
[3847] MACH Energy Australia Pty Ltd Suite 1, Level 3, 426 King Street Newcastle West NSW 2302 ACN 603 495 441
[3847] t: +61 2 5517 1150 e: info@machenergy.com.au www.machenergyaustralia.com.au
[3847] v1Page | 0
[3847] MACH Australia Holdings Pty Ltd ACN 608 494 828
[3847] MACH Energy Australia Pty Ltd ACN 608 495 441
[3847] 2020 Modern Slavery Report
[3847] /5/2021 0 Approved Michael Howard Jason Culpeper Board Date Rev Status Prepared By Checked By Approved By
[7474] utilising remediation processes including whistleblower hotlines, contract clauses and improving appropriate policies and procedures such as the L1 Capital Code of Conduct, the L1 Capital Internal Dispute Resolution Policy and the L1 Capital Whistleblower Policy to mitigate risks and effects of modern slavery practices
[7474] During the Reporting Period, ETL undertook the following actions
[7474] updated the annual due diligence questionnaire to include modern slavery questions designed to identify any potential risks in the supply chains of the Fund
[7474] undertook Modern Slavery training to the ETL Board of Directors relating to the obligations of the Act and the responsible members of the ETL Board in approving Modern Slavery Statements
[7474] How the Reporting Entity assesses the effectiveness of actions to assess and address risks ETL will provide its Board of Directors with an annual assessment on the implementation and effectiveness of actions to ensure the obligations within this Statement are met
[7474] The Board shall consider the effectiveness of the measures as set out above and have the authority to make amendments to this Statement as it sees fit
[7474] Consultation process There are no subsidiaries or entities owned or controlled by the Reporting Entity, which is a Trust
[7474] However, the Responsible Entity of the Trust and the investment manager of the Trust consult on the preparation of this MSS
[11660] Approval of this Statement (Mandatory Criteria 16(2)) This Statement was approved by the Board of Directors of Objective Corporation Limited
[11660] Tony Walls Chief Executive Officer Objective Corporation Limited 20 December 2022
[11660] PAGE 21 December 2022 | Document ID: A2602420 | OBJECTIVE.COM 7 Annexure A OBJECTIVE CORPORATION GROUP All of Objective Corporation Limiteds subsidiaries and controlled entities (as at 30 June 2022), and its ownership percentages, are stated below: Company Name Country of Incorporation Ownership Objective RegTech Pty Limited Australia 100% The Objective Corporation Limited Employee Share Trust Australia n/a Objective Corporation Solutions NZ Limited New Zealand 100% Alpha 88 Limited New Zealand 100% Objective Corporation Singapore Pte Limited Singapore 100% Objective Corporation North America Inc.* United States of America 100% Objective Corporation USA Inc United States of America 100% Objective Corporation UK Limited United Kingdom 100% Objective Keystone Limited United Kingdom 100%
[11660] * Includes ownership interest in Simflofy, Inc (a United States of America entity), which was acquired through a forward triangular merger that closed on 17 March 2022
[11820] Introduction
[11820] Modern Slavery is an umbrella term that includes practices like slavery, servitude, human trafficking and forced labour
[991] We believe that all human beings are born free and equal and should be treated with dignity and respect
[991] While society has made progress to protect underrepresented populations, there is still much work to be done and, as an organisation, we have a role to play
[991] By working with our employees, shareholders, supply chain and other stakeholders globally, we can drive further accountability to protect vulnerable people from harm
[991] This statement was approved by the Sims Limited Board of Directors
[991] Alistair Field CEO and Managing Director, Sims Limited Geoff Brunsdon Chairman of the Board, Sims Limited Sims Limited Modern Slavery Statement 2020 | 15
[991] Learn more: www.simsltd.com
[1033] NetApp statement on slavery and human trafficking netapp.com /us/legal/ca-senate-bill-657.aspx
[1033] December 2020 The California Transparency in Supply Chains Act of 2010, the United Kingdom Modern Slavery Act of 2015, and the Australian Commonwealth Modern Slavery Act 2018 require certain businesses to disclose efforts to prevent or otherwise eradicate slavery and human trafficking from their supply chains
[3847] Reporting entities This 2020 Modern Slavery report is prepared in accordance with the requirements of the Modern Slavery Act 2018 (Cth) for the year ending 31 December 2020
[3847] The following private, unlisted companies are the reporting entities for the purposes of this report and are referred to collectively as MACH Energy
[3847] MACH Australia Holdings Pty Ltd ACN 608 494 828 (MAH); and
[3847] MACH Energy Australia Pty Ltd ACN 608 495 441 (MEA) (a controlled subsidiary of MAH)
[3847] The principal activities of MACH Energy during the year were the operating and ongoing development of the Mt Pleasant coal mine (Mount Pleasant) in the Hunter Valley of New South Wales
[3847] The Mount Pleasant assets are owned 95% by MEA and 5% by J.C.D
[3847] Australia Pty Ltd (JCDA)
[3847] MEA and JCDA, through an unincorporated joint venture, uses two incorporated agents to conduct its business, namely
[7474] For clarity, L1 Capital is not owned or controlled by the issuer of this MSS
[7474] Other relevant information No other relevant information for this reporting period
[7474] Approval This Statement was approved and signed by Philip Gentry on behalf of the Board of Directors of ETL, the responsible entity of the Reporting Entity, on 23 December 2021
[7474] Philip Gentry Chair Date: 23 December 2021
[7474] For clients wishing to discuss this statement, please contact your client service representative
[7474] For media inquiries wishing to discuss this statement, please contact: Alicia Kokocinski, General Manager, Marketing and Communications Equity Trustees Limited Level 1, 575 Bourke Street, Melbourne, VIC 3000 Australia Telephone: +61 3 8623 5396 / +61 403 172 024 Email: akokocinski@eqt.com.au
[7474] Equity Trustees Limited ABN 46 004 031 298 AFSL 240975 and EQT Responsible Entity Services Ltd ABN 94 101 103 011 are part of the EQT Holdings Limited group (brand name Equity Trustees) which also includes Equity Trustees Wealth Services Limited ABN 33 006 132 332 AFSL 234528, Equity Trustees Superannuation Limited ABN 50 055 641 757 AFSL 229757, RSE L0001458 HTFS Nominees Pty Ltd ABN 78 000 880 553 AFSL 232500 RSE L0003216 EQT Legal Services Pty Ltd ABN 32 611 391 149
[7474] EQT Holdings Limited ABN 22 607 797 615 is a publicly listed company on the Australian Securities Exchange (ASX: EQT) with offices in Melbourne, Bendigo, Sydney, Brisbane, Perth, London and Dublin
[11820] It is a heinous crime and a morally reprehensible act that deprives a person's liberty and dignity for anothers personal or commercial gain
[11820] At Feros Care, we have a zero-tolerance approach to modern slavery and are committed to not condoning, supporting or contributing, either directly or indirectly, to Modern Slavery in our operations and supply chain
[11820] In accordance with the Modern Slavery Act 2018, Feros Care now meets the threshold requirement for Modern Day Slavery Reporting
[11820] Our first statement outlines the actions that we have taken to understand any potential modern slavery risks related to our organisation, and our commitments to assessing and reducing the risk of modern slavery within our business and supply chain
[11820] Who we are Feros Care is a charitable organisation registered under the Australian Charities and Not-for-Profit Commission Act 2012 (Cth) (ACNC)
[11820] Our mission is helping people live healthier, happier, better-connected lives
[11820] For over 30 years, weve been making it happen, both for older Australians and people living with disability
[11820] Our aged care and disability support services help through home care, residential and respite care, clever technology to make life easier, assistance in accessing community activities, coordination of local NDIS services, or one of our allied health and wellness solutions
[1033] NetApp is committed to complying with these laws and to ensuring that its employees and suppliers around the globe take appropriate steps to mitigate the risk of human trafficking and slavery in our supply chain
[1033] Our commitment to human rights, which covers topics such as forced labor, slavery, child labor, and human trafficking, is outlined in our Human Trafficking Policy and NetApps Supplier Code of Conduct
[1033] As an active member of the Responsible Business Alliance (RBA), NetApp uses the RBA Code of Conduct (RBA Code) as the basis of its Supplier Code of Conduct
[1033] The RBA Code prohibits the use of forced labor, including bonded, indentured labor or involuntary prison labor, human trafficking, and child labor
[1033] Fundamental to the RBA Code is the understanding that a business, in all of its activities, must operate in full compliance with the laws, rules, and regulations of the countries in which it operates
[1033] The RBA Code contains specific requirements covering slavery and human trafficking and encompasses a broader vision than simply the elimination of human trafficking
[1033] It includes compliance with global labor standards and applicable laws; worker health and safety; the environment; business ethics; and the management of internal systems and controls to ensure effective compliance
[1033] In addition to these actions, NetApp participates in RBA activities
[3847] MACH Mount Pleasant Operations Pty Ltd ACN 625 627 723 (a wholly owned subsidiary of MEA) for all site activities up to and including the train load out facility; and
[3847] MACH Mount Pleasant Marketing Pty Ltd ACN 625 627 965 (a wholly owned subsidiary of MEA) for logistics and sales functions
[3847] Annexure A contains an overview of the corporate structure of the group
[3847] Structure and Operations overview MACH Energy is in the business of developing and operating economical and efficient energy sources
[3847] It is the majority owner of the Mount Pleasant open cut coal mine located 4km west of Muswellbrook in the Hunter Valley of New South Wales which produces up to 8 million tonnes of thermal coal for domestic and export markets, mostly for the purposes of power generation in coal fired power plants
[3847] A large construction project is currently underway at Mount Pleasant to build a new rail loop from the main line onto the mining lease, known as the Rail 2 Project (R2P)
[3847] These works are required in order to replace the current rail loop which is built on land owned by the adjoining Bengalla mine and which needs to be removed by late 2022
[3847] R2P involves the construction of several kilometers of track as well as new materials handling infrastructure and a new train load out facility
[7476] LAKEHOUSE SMALL COMPANIES FUND MODERN SLAVERY STATEMENT FOR THE YEAR ENDED 30 JUNE 2021
[7476] Table of contents
[7476] Background 3 Structure, operations and supply chains of the reporting entity 3 Our Structure 3 About EQT 3 About Lakehouse Capital Pty Ltd 3 Operations and supply chains 4 Risks of modern slavery practices in operations and supply chains of the Lakehouse Small Companies Fund 5 Actions taken by the Lakehouse Small Companies Fund and ETL to assess and address risks, including due diligence and remediation processes