mila-ai4h/AIMS.au huggingface dataset:
[96] When required by law, Intel will file a report of violative activity to relevant government authorities
[96] Intel has established formal grievance and remedy processes that enable anyone, including employees, employees of Intels suppliers and other external stakeholders, to report ethics, human rights, compliance or safety concerns through our third-party-operated Intel Ethics and Compliance Reporting Portal
[96] We will promptly investigate allegations and pursue action to mitigate any adverse impacts
[96] Intel does not tolerate retaliation against anyone who in good faith reports possible violations of the law, Intels Code of Conduct or other policies or procedures, questions on-going or proposed conduct, or participates in an internal investigation
[96] CAHRAs, as defined by OECD, are identified by the presence of armed conflict, widespread violence, or other risks of harm to people
[96] Armed conflict may take a variety of forms, such as a conflict of international or non-international character, which may involve two or more states, or may Risk Assessment and Due Diligence Intel takes steps to evaluate, verify and address modern slavery risks in our supply chain with the intention of protecting people and eliminating these risks
[2757] Update of Ixoms procurement agreement templates to make modern slavery practices a ground for Ixom to terminate the agreement
[2757] Further clauses refer to anti-bribery and anti- corruption practices and impose limitations on the engagement of subcontractors
[2757] Modern slavery questions were added to Ixoms existing supplier desktop audit process used by its Australian and New Zealand businesses
[2757] Preparation of a supplier statement and acknowledgment of Ixoms modern slavery requirements
[2757] Risk of modern slavery practices
[2757] Key actions taken to assess and address risks 12 Key actions taken to assess and address risks 1 International Labour Organization, Walk Free Foundation and International Organization for Migration
[2757] Global estimates of modern slavery: Forced labour and forced marriage
[2757] Geneva, 2017
[5015] Reviews and assessments of all of its suppliers are undertaken on an annual basis
[5015] In the event of any adverse circumstances arising from this screening, SMBC-LF, where appropriate, will escalate the matter with the relevant supplier or law enforcement agency, subject to its obligations under law
[5015] Further, SMBC and its related body corporates operating in the United Kingdom and the European Union markets (including SMBC-LF), conduct due diligence on their suppliers, contractors, customers and any other business partners in order to address slavery and human trafficking risk in its operations and supply chain
[5015] Where a relevant counterparty is subject to the UK Act, in pursuance of SMBC EMEA Anti-Slavery Policy, SMBC-LF seeks an Anti-Slavery Statement and confirm that such party is not involved in the commission or facilitation of slavery and/ or human trafficking
[5015] SMBC-LFs due diligence processes include, but are not limited to, an assessment to determine if the relevant counterparty falls within the scope of the UK Act, an evaluation of where such third party is based and operates, an analysis of the business activities being carried out, and a detailed review of publicly available information, in order to identify instances which may give cause for concern in relation to slavery, human trafficking and other human rights issues
[5015] For those counterparties who are in Europe but not in scope of the UK Act, SMBC-LF seeks an equivalent policy, document or statement relating to their commitment to Corporate Social Responsibility (CSR), Environmental, Social, and Governance (ESG) and human rights, etc to provide reasonable assurance that they are not involved in the commission or facilitation of slavery and/ or human trafficking
[5015] Analysis is undertaken on the jurisdiction risk of the relevant counterparty having regard to its locations, operations and activities
[5015] In essence, third parties, including suppliers, are expected to undertake ethical business practices, particularly in high risk sectors such as manufacturing, construction or service industries Outsourcing SMBC and group entities within its operational control (including SMBC L-F) operate subject to an outsourcing policy which expressly addresses modern slavery risks
[9307] Building services; hospitality; tourism; catering; cleaning
[9307] Clothing; footwear mainly uniforms and merchandising
[9307] Financial services
[9307] Health services mainly health assessments and well-being providers These goods and services were directly sourced from companies located in Australia
[9307] The total expenditure within these sectors equated to 8% of Stanmores entire annual expenditure in the Reporting Period
[9307] We recognise that there may be an increased risk of modern slavery in the goods and services procured indirectly through our direct suppliers, including our mining operator
[9307] This may present a medium to high risk for modern slavery as we have less control and oversight over the indirect supply chain
[9307] ACSI Report p23; KPMG Report p13; 2 KPMG Report p12
[96] We start by setting clear expectations for suppliers2
[96] These expectations are codified in Intels Code of Conduct, Intels policies and the RBA Code (Intel Policies)
[96] Risk assessment and due diligence begin during the supplier selection process
[96] Suppliers who want to do business with Intel are expected to complete a Corporate Social Responsibility consist of wars of liberation, or insurgencies, civil wars, etc
[96] High-risk areas may include areas of political instability or repression, institutional weakness, insecurity, collapse of civil infrastructure, and widespread violence
[96] Such areas are often characterized by widespread human rights abuses and violations of national or international law
[96] Intel Expectations of Suppliers to Address the Risks of Modern Slavery Fees No levies or placement fees or costs, even if allowed by local law No fees or costs charged to workers as defined by RBA No worker debt to obtain or keep a job Fees and costs charged must be repaid within 90 days Contracts and Resignation Terms Employment contracts in native language No detrimental changes to the contract or work conditions Resignation must be voluntary Notice period cannot exceed one month Resignation notice penalty cannot exceed 60% of one months wages Worker Rights No holding workers original identification Secure personal storage must be provided Workers must have freedom of movement Control Systems Monitor recruiters and labor agents and interview foreign and migrant workers Documented policies and procedures must be in place
[96] 2019 Intel Corporation Statement on Combating Modern Slavery 4 (CSR) survey that includes questions which help us identify potential modern slavery risks
[2757] http://www.ilo.org/wcmsp5/groups/public/@dgreports/@dcomm/documents/publication/wcms_575479.pdf
[2757] 15 2020 MODERN SLAVERY STATEMENT
[2757] Assessing effectiveness 6.1 Overall assessment
[2757] The Ixom working group met to plan the initial program and during the reporting period a separate working group was tasked with various action items
[2757] These groups met regularly, and awareness of modern slavery risks increased
[2757] An annual review of the effectiveness of the work plan was conducted by Ixoms internal legal team
[2757] Ixom measured its progress by tracking suppliers who were targeted for due diligence on a case by case basis during the reporting period
[2757] Ixom is able to track the progress of the supplier from identifying any red flags noted in the completed due diligence through to any recommendations made to the business
[5015] Prior to outsourcing any relevant function to a third party, a due diligence assessment of modern slavery risk must be completed so as to confirm that the relevant third party is not engaged in modern slavery
[5015] This due diligence process includes reviewing publicly available information such as the third partys or its parent companys website in respect of its policies or positions on the protection of human rights, as well as internet searches to determine whether there is any adverse news in respect of human rights violations
[5015] Outsourcing is expressly prohibited if the due diligence reveals that the third party is engaged or involved in modern slavery or any other human rights violations
[5015] In FY2020, the SMBC Group outsourcing due diligence program was enhanced to ensure an assessment and monitoring of all vendors/service providers (regardless of whether the service is considered to be outsourcing) is undertaken at least annually
[5015] The three areas of focus include the Japanese Anti-Social Forces Screening, Anti-Bribery and Corruption Due Diligence and Modern Slavery Due Diligence
[5015] Additionally, in FY2019, in Japan, SMBC expanded the scope of its outsourcing policy to apply to service providers, vendors and certain other suppliers
[5015] SMBCs methods to assess effectiveness of actions to assess and address modern slavery risks Upon finalisation of the consultation process with SMBC branches and group entities within its operational control (including SMBC-LF) and the implementation of a modern slavery risk management framework (ie policies, control processes, training and ongoing monitoring program), it is intended that the framework and the risk control activities that have been undertaken as part of the framework (ie the results of customer, supplier and outsourcing monitoring, any internal audits or other examinations) will be regularly (and at a minimum, annually) reviewed and evaluated for effectiveness
[5015] Consistent with the assessment of other SMBC policies, effectiveness will be determined on an assessment as to
[9307] Commonwealth Guidance p44
[9307] KPMG Report p14
[9307] ACSI Report; KMPG Report p14, 17
[9307] Stanmore Resources Limited | Modern Slavery Statement 2021 TYPE OF RISK DESCRIPTION AND ANALYSIS OF RISK GEOGRAPHIC
[9307] Particular countries may have a higher prevalence of modern slavery due to factors such as poor governance, compromised rule of law, conflict zones, high migration inflows and socio- economic issues such as poverty.6 We have identified that the following countries from which we source services may present a medium risk for modern slavery according to the GSI 2018 Prevalence Index
[9307] Singapore from which we source professional services ranks 97/167
[9307] Brazil from which we source engineering services ranks 142/167
[9307] United States of America from which we source professional services ranks 158/167 We consider that the level of oversight that we have over the procurement of these services from direct suppliers and the actions we take to assess and address modern slavery risks, as detailed further below, mitigates the risks of modern slavery
[96] If selected, a contract is put in place that requires suppliers to strictly comply with Intel Policies
[96] Additionally, we send out an annual letter to suppliers reminding them of their legal obligations to comply with Intel Policies
[96] We conduct an annual assessment of critical suppliers4 using a comprehensive self- assessment questionnaire that includes questions related to recruitment, onboarding, and staffing
[96] We analyze questionnaire responses for the presence of Foreign and Migrant Workers (FMWs) and other vulnerable worker groups, as well as evaluate their practices and controls
[96] When combined with location and sector information, we determine which suppliers are higher risk
[96] We will then either ask them to complete an additional questionnaire, audit them, or take additional corrective action
[96] We regularly meet with Intels procurement leaders to discuss and review supplier performance, including any modern slavery issues that may have been identified
[96] In addition to our own policies and procedures, we also engage outside experts such as Humanity United, The FAIR Hiring Initiative, Verit, the Global Business Initiative on Human Rights and other third parties with deep knowledge of modern slavery
[2757] Ixom has started increasing awareness of modern slavery risks amongst its employees by communications and training
[2757] As a result of Ixom employee awareness on modern slavery the modern slavery avoidance, legal and compliance inboxes are being effectively used
[2757] Reporting and remediation If an Ixom employee or representative has any concerns that a supplier may be involved in modern slavery practices, these concerns along with information outlining the basis for these concerns must be reported to Ixoms Legal and Compliance Group immediately or alternatively reported in detail through Ixoms relevant communication channels
[2757] Where Red Flags are identified in relation to a supplier that Ixom uses or proposes to use these are addressed in accordance with a detailed procedure set out in Ixoms MSA Policy
[2757] Assessing effectiveness 14
[2757] 17 2020 MODERN SLAVERY STATEMENT
[2757] Consultation with Ixom entities and approvals Ixoms MSA Policy applies to all Reporting Entities and their wholly owned members
[2757] Ixom has made available the MSA Policy to personnel in all wholly owned members of Ixom
[5015] Modern slavery has been introduced in the SMBC Group global compliance risk assessment framework
[5015] Consistent with the SMBC Group global compliance risk assessment program effectiveness is determined on an assessment as to
[5015] appropriate design of relevant policies and procedures to ensure compliance and risk management
[5015] how well the control processes have operated, including timeliness and comprehensiveness
[5015] the extent of employee training that has been conducted
[5015] the outcomes from monitoring and validation procedures; and
[5015] the timeliness of remedial action taken for any issues arising
[5015] Enhancements may be made as considered necessary as a result of these assessments
[9307] The vast majority of our goods and services are procured in Australia, which is a low-risk country according to the GSI 2018
[9307] COVID 19 RISKS
[9307] The COVID-19 pandemic has significantly affected people and businesses across the globe and increased human rights and modern slavery related risks, mainly due to job losses, increased poverty and increased vulnerabilities including health risks.7 COVID-19 impacts have not been significant to Stanmore in the Reporting Period
[9307] Stanmore did not report any negative impacts on the financial statements nor triggers for any significant uncertainties with respect to events or conditions which may adversely impact Stanmore at the reporting date or subsequently as a result of the COVID-19 pandemic
[9307] Commonwealth Guidance p 44
[9307] MCA Report p4-5
[9307] Risk profile non-managed operations The Stanmore Group owns a 50% non-operating interest in the Millennium and Mavis Downs Joint Venture
[9307] This JV is operated by M Mining Pty Ltd
[96] We refer to a number of external sources, including the US Department of State Trafficking in Persons Report (TIP Report), the U.S
[96] Department of Labors List of Goods Produced by Child Labor or Forced Labor, the U.S
[96] Department of States Responsible Sourcing Tool, and publications from reputable organizations, to stay informed
[96] These sources help us identify higher-risk countries and sectors in our supply chain
[96] Critical suppliers represent a subset of Tier 1 or direct suppliers that we have significant business relationship and spends
[96] Of Intel's more than 10,000 Tier 1 suppliers, we categorize approximately 400 as critical suppliers that we engage through our capability building programs and represent more than 75% of our spends
[96] We combine insights from these reports with our own questionnaire responses, audit results, and input from experts in this area to continuously refine and strengthen our overall risk management and verification processes
[96] Using this framework, in 2019 we increased our focus in three areas: Japan, South Korea and the construction sector
[2757] Ixoms consultation process included engagement with personnel across Ixom to confirm alignment of policies, systems and processes across its businesses
[2757] This Statement was endorsed and approved by the principal governing bodies of the following
[2757] IX Infrastructure Pty Ltd on behalf of that company, Ixom Holdco Pty Ltd and Ixom Pty Ltd; and
[2757] Ixom Holdings Pty Ltd on behalf of that company, Ixom Operations Pty Ltd and Ixom International Holdings Pty Ltd This Modern Slavery Statement is approved by Matthew Pollard, Director, Ixom Holdings Pty Ltd and IX Infrastructure Pty Ltd Matthew Pollard 30 March 2021 16
[2757] Consultation with Ixom entities and approvals
[2757] Ixom Holdings Pty Ltd ACN 131 367 Ixom Pty Ltd ACN 602 723 768 Ixom HoldCo Pty Ltd ACN 602 722 547 IX Infrastructure Pty Ltd ACN 629 750 401 Ixom Operations Pty Ltd ACN 600 546 512 Ixom Finance Pty Ltd ACN 602 439 538 Bronson & Jacobs Pty Ltd ACN 000 063 249 Ixom International Holdings Pty Ltd ACN 602 439 878 Botany Industrial Park Pty Ltd ACN 083 874 962 Bronson & Jacobs (S.E
[2757] Asia) Pte Ltd Singapore Bronson & Jacobs (H.K.) Ltd Hong Kong PT Bronson & Jacobs Indonesia Indonesia Bronson & Jacobs International Company Ltd Thailand Bronson & Jacobs (Malaysia) Sdn Bhd Malaysia Bronson & Jacobs (Shanghai) International Trading Co Ltd China Ixom Finance New Zealand Limited Ixom Chemicals Trading Agency (Beijing) Co, Ltd China Central Pacific Chemicals Ltd Fiji Miex UK Limited England Ixom Chile SA Chile Ixom Watercare Inc United States Ixom Colombia Colombia Ixom Peru SA Peru Ixom Brasil Produtos Quimcos Ltda Brazil Active Chemicals Chile SA Chile Ixom Argentina SA Argentina Forbusi Importadora e Exportadora Ltda Brazil 18 2020 MODERN SLAVERY STATEMENT
[2757] 18 Annexure A Corporate Structure Key Australian entities New Zealand entities Ownership Foreign entities
[5015] SMBCs consultation process with its subsidiaries and other controlled entities SMBC and the group entities within its operational control (including SMBC L-F) operate in accordance with a compliance risk assessment framework
[5015] As a result of the consultation undertaken to prepare this statement, consideration is being given to including modern slavery risk as a new category of assessment in the compliance risk assessment framework, which would operate in conjunction with a global policy
[5015] Approval This Statement was approved by the SMBC-LF Board of Directors on 30 June 2021 and has been signed on behalf of the Board by Mr Stephen R
[5015] Perry, President of SMBC-LF
[5015] ______________________________________________ Stephen R
[5015] Perry President, SMBC Leasing and Finance, Inc
[5137] 132 312 515 ORDERS: 1300 65 88 22 FAX ORDERS: 1300 65 88 10 TEETH ORDERS: 1300 65 88 11 www.henryschein.com.au
[5137] Modern Slavery Statement The Henry Schein Regional Trust Introduction Henry Schein is committed to assessing and addressing the risks of modern slavery occurring in its operations and supply chains and is proud to make and lodge this first Modern Slavery Statement under the Modern Slavery Act 2018 (Cth)
[9307] Stanmore considers that the risk of modern slavery within the JV is similar to that within the Stanmore Group
[9307] 10 20 30 40 50 60 70 % of vendors % of spend Chemical industries Education Forestry; wood; pulp and paper * Clothing; footwear Oil and gas production; oil rening Agriculture; plantations; shing; rural sectors Consumables site office * Financial services Basic metal production Media; culture; graphical Transport equipment manufacturing Postal and telecoms Information and communications technology * Health services Mechanical and electrical engineering Utilities Professional services * Building services; hospitality; tourism; catering; cleaning Commerce Mining and quarrying Transport Construction Distribution of suppliers compared to expenditure
[9307] ACTIONS TAKEN BY THE REPORTING ENTITY AND ANY ENTITIES IT OWNS OR CONTROLS TO ASSESS AND ADDRESS MODERN SLAVERY RISKS, INCLUDING DUE DILIGENCE AND REMEDIATION PROCESSES Stanmore is committed to ensuring compliance with human rights principles, and acting ethically and with integrity in conducting our business
[9307] Governance Stanmore is committed to further enhancing governance and empowering management to address the risks of modern slavery in our operations and supply chains
[9307] A Modern Slavery Working Group was established in 2020 to help with future development training programs for employees and establish risk assessments
[9307] During the Reporting Period, the Working Group comprised the Company Secretary, Legal Counsel, General Manager Operations, and the Asset Superintendent (this position undertook a large proportion of purchasing during the Reporting Period)
[9307] The key consideration for the Working Group was the impact of modern slavery risks on purchasing activities
[96] Prompted in part by a TIP Report on worker protections in Japans Technical Intern Training Program (TITP), we came to understand that home country recruiters and agents were legally allowed to charge fees to FMWs
[96] Similarly, we learned South Korea has a comparable program where job seekers pay fees
[96] In both cases weve taken steps to ensure these practices are not used by Intel suppliers
[96] Additionally, weve also increased awareness and oversite on the construction sector which has been identified by KnowTheChain5 as the second highest-risk sector for forced labor. Minimizing the risk of modern slavery in our operations and supply chain requires overcoming two notable challenges: gaining visibility into our multi-tier supply chain and tracing multiple levels of labor agents who source FMWs
[96] To help us understand and address those challenges, weve continued our multi-year innovative project for supplier accountability
[96] This program requires approximately 50 critical suppliers to roll out our modern slavery risk prevention plan to at least three Tier 26 suppliers that employ FMWs
[96] As an alternative, critical suppliers could instead conduct a full RBA audit of the three selected suppliers; reaching about 135 Tier 2 suppliers
[96] Our work has resulted in numerous positive changes made by Tier 2 suppliers to their staffing and recruiting policies and closer engagement and expectation setting with their 5 https://knowthechain.org/knowthechain-calls-on-investors-to- address-forced-labor-risks-in-the-construction-sector/ 6 Tier 2 suppliers are companies from which Intel's Tier 1 suppliers make direct purchases
[2757] Ixom Australia 1 Nicholson St East Melbourne VIC 3002 Australia T Australia 1300 559 262 New Zealand 0800 222 277 All other locations 61 3 9906 3000 www.ixom.com For specialist advice in an emergency, call Ixoms 24 HOUR EMERGENCY RESPONSE SERVICE Australia 1800 033 111 New Zealand 0800 734 607 International +61 (0) 3 9663 2130
[2824] Our Modern Slavery Statement The super fund for Australias higher education and research sector FOR THE 2019-20 FINANCIAL YEAR
[2824] About this statement This Modern Slavery Statement (Statement) is given by UniSuper Management Pty Ltd ABN 91 006 961 799, AFSL No 235907 (USM), being an entity wholly owned by UniSuper Limited ABN 54 006 027 121, ASFL No 492806 (USL) in its capacity as trustee of the fund UniSuper ABN 91 385 943 850 (Fund), for the 2019-20 financial year
[2824] The Statement is made pursuant to the Modern Slavery Act 2018 (Cth) (Act) and has been approved by the Boards of USL in its capacity as trustee of the Fund and USM on 18 February 2021
[2824] The registered office for both USL and USM is Level 1, 385 Bourke Street, Melbourne, Victoria 3000
[2824] The reporting entities covered by the Statement are USM and the Fund where it has had consolidated revenue of at least $100 million for the relevant financial year
[2824] As the Fund takes modern slavery seriously, it chooses to prepare a Statement even where it is not a reporting entity under the Act
[2824] Except where the context otherwise requires, the Fund, USL and USM are referred to throughout the Statement as, UniSuper, we, us or our