mila-ai4h/AIMS.au huggingface dataset:
[11377] MODERN SLAVERY STATEMENT SECTION 3: Modern Slavery Risks in W+Ks Operations and Supply Chain In partnership with Fair Supply (a global ESG data provider and consultancy), Wotton + Kearney undertook a detailed mapping of its supply chain comprising 289 suppliers with the highest spend amounts
[11377] The analysis identified our top 50 suppliers across our top 15 risk industry categories based on spend
[11377] Risk was determined based on the industry, amount spent and the geographical location of the products or services
[11377] The overall risks of modern slavery occurring in our supply chains and operations have been assessed as being relatively low
[11377] However, Wotton + Kearney acknowledges that modern slavery risk exists across all sectors and organisations which may mean it is directly or indirectly exposed to the risk of modern slavery
[11377] The most elevated risk of modern slavery in Wotton + Kearneys operations and supply chains fall within the industries on the right
[11377] While we have not identified any instances of causing modern slavery, we have identified that through these industries there is potential for us to be directly linked to the following modern slavery risks
[11377] Forced labour restrictions of movement, intimidation, threats, including human trafficking
[991] In accordance with the UK Modern Slavery Act 2015, the following Sims UK entities are included in this statement: Reporting entity: Sims Limited Level 9 189 ORiordan Street Mascot, NSW 2020 Australia Sims Limited Sims Group UK Holdings Limited Sims Group UK Limited Sims Recycling Solutions Ireland Limited Sims Lifecycle Services BV Sims Recycling Solutions SP z.o.o
[991] Sims Metal Management Finance Limited Sims Group UK Intermediate Holdings Limited Sims Recycling Solutions Holdings, Inc
[991] Sims Recycling Solutions, Inc
[991] Sims Global Commodities Pte Ltd
[991] Sims Group Holdings 1 Pty Ltd
[991] Sims Group Holdings 2 Pty Ltd
[991] Sims Metal Management USA GP Sims Group USA Holdings Corporation Sims Group Global Trade Corporation Sims Limited Modern Slavery Statement 2020 | 3
[991] METAL RECYCLING FACILITIES ACROSS NORTH AMERICA 103 YEARS OF RECYCLING EXPERIENCE ~4,000 EMPLOYEES Our Company Founded in 1917, Sims Limited is a global leader in metal and electronics recycling, and an emerging leader in the municipal recycling and the renewable energy industries
[3708] Supplier Audits Adobe Group has a better understanding of its supply chains and risks
[3708] Vendor Risk Management Office management of program for screening and re-screening risk assessments of Adobes suppliers Adobe Group has a better understanding of its supply chains and risks
[3708] Adobe Groups Supplier Ethics & Integrity Program requiring suppliers to certify key information about their Suppliers better understand Adobe Groups expectations of business conduct
[3708] ______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 14
[3708] Type of activities Action Outcomes compliance practices and policies
[3708] Having contractual terms requiring compliance with laws and that no forced, bonded or involuntary labour used
[3708] Suppliers better understand expectations of Adobe Group in relation to modern slavery
[3708] Capacity building and awareness raising Encouraging suppliers to use RBAs Learning Academy, which includes modules on the RBA Code of Conduct
[7068] Identifying risks of modern slavery
[7068] Taking action against modern slavery
[7068] Overview
[7068] Supply chain
[7068] Measuring effectiveness
[11377] Deceptive recruitment practices workers promised certain jobs, benefits, or conditions
[11377] Child labour where children are engaged in hazardous work
[11377] Debt bondage the payment of excessive recruitment fees or associated costs, and retention of identity documents
[11377] Computer and technical services Although most of our direct suppliers are based in Australia, in the IT industry work is often sent offshore to less economically developed countries with little visibility over labour conditions
[11377] The risk of modern slavery from IT hardware arises from raw material extraction and from the manufacture of hardware and software, which often relies on low skilled, low paid and vulnerable labour
[11377] Business services Business services, such as printing companies can face risks of forced labour and child labour associated with the manufacturing of electronic goods in certain countries
[11377] In addition, outsourcing and subcontracting creates a heightened risk of vulnerability for workers because there is less visibility and control over the contractual arrangements
[11377] Recruitment services Recruitment services can pose a risk on employees by
[991] Our purpose, create a world without waste to preserve our planet, is what drives us to constantly innovate and offer new solutions in the circular economy for consumers, businesses, governments and communities around the world
[991] We work toward realising this purpose through each of our business divisions and our joint ventures
[991] Our business divisions include Sims Lifecycle Services (electronic reuse and recycling), Sims Metals (metal recycling), Sims Municipal Recycling (curbside recycling), Sims Energy (harnessing methane produced by landfills to produce renewable electricity) and the soon-to- be operational Sims Resource Renewal Pty
[991] Ltd (transforming material left over from metal recycling into useful products)
[991] Sims is an Australian company headquartered in Sydney, New South Wales and, as of 30 June 2020, has operations in 15 countries located across Asia Pacific, Europe, the UK and North America
[991] Our global workforce consists of more than 4,000 employees across more than 147 managed sites
[991] Our personnel are primarily employees, but we also utilise temporary/ short-term workers, as well as contractors
[991] We have 21 agents in Asia Pacific, Europe, South America and the Caribbean
[3708] Suppliers have a better awareness of RBA Code of Conduct expectations and understand expectations of Adobe Group in relation to modern slavery
[3708] Requiring Adobe Group employees to undertake Code of Business Conduct training Our employees better understand the expectations in the Code of Business Conduct
[3708] Supplier activities Liaising with its supplier and conducting monthly visits to review production area Increase in supplier engagement and better awareness of Adobes expectations
[3708] Policies and procedures Having the Adobe Code of Business Conduct and Adobe Business Partner Code of Conduct in place Suppliers have a better awareness of Adobe Groups expectations
[3708] Future activities
[3708] Policies and procedures Evaluate potential updates to our policies and procedures to address modern slavery risks
[3708] Updates may improve the Adobes business partners understanding of Adobes expectations
[7068] Consultation
[7068] Approval
[7068] Identifying the reporting entity Finbar Group Limited (ACN 009 113 473) is an Australian company, publicly listed on the Australian Securities Exchange (ASX: FRI), registered at Level 6, 181 Adelaide Terrace, East Perth, Western Australia, 6004
[7068] This statement has been developed in accordance with the requirements of the Modern Slavery Act 2018 (Cth) (the Act), and it sets out the actions taken by Finbar Group Limited and its wholly owned and controlled entities (referred to collectively in this statement as Finbar, the Group, the Company) to identify, assess and address modern slavery risks in its operations and supply chain
[7068] The statement was approved by the board of Finbar Group Limited on 20 December 2021 and on authority signed by Darren John Pateman, Managing Director
[7068] Structure, operations, and supply chain Structure Finbar is an Australian property development and property investment company located in Perth, Western Australia (WA)
[7068] Its core focus is developing medium to high-density residential apartments and commercial properties
[7068] Developments, project management, sales, rental and other associated functions are undertaken by fully owned subsidiaries of Finbar and Finbars joint venture entities
[11377] restricting workers freedom of movement
[11377] withholding, destroying, concealing, or denying access to their workers identification documents, passports, work permits or travel documents
[11377] requiring workers to pay recruitment fees
[11377] using wage deductions as a disciplinary measure Occupancy of premises and parking The highest risk categories include cleaning and security services
[11377] Examples of risks include
[11377] the use of foreign workers or temporary or unskilled labour; and
[11377] the procurement of uniforms and other goods potentially manufactured using cotton in countries outside of Australia and New Zealand
[11377] MODERN SLAVERY STATEMENT Understanding the impact and risk of causing, contributing to or being directly linked to modern slavery
[991] Sims holds a 50 percent interest in four active entities
[991] Sims manages two of these entities, Richmond Steel Recycling (Canada) and Rondout Iron and Metal Co (United States)
[991] The other two, SA Recycling LLC (United States) and LMS Energy Pty
[991] Ltd (Australia), are not managed by Sims
[991] These joint ventures have 124 sites located in Canada, the United States and Australia at 30 June 2020
[991] | Sims Limited Modern Slavery Statement 2020
[991] OUR LOCATIONS 29 METAL RECYCLING FACILITIES ACROSS THE UK 50 METAL RECYCLING FACILITIES ACROSS AUSTRALIA, NEW ZEALAND & PAPUA NEW GUINEA 18 ELECTRONIC LIFECYCLE SERVICES FACILITIES ACROSS 15 COUNTRIES 200+ FACILITIES OPERATING IN 15 COUNTRIES A$4.9bn SALES REVENUE IN 2020 124 JOINT VENTURE FACILITIES ACROSS NORTH AMERICA & AUSTRALIA Sims Limited Modern Slavery Statement 2020 | 5
[991] Our Supply Chain Our trade supply chain is flat, and it solely consists of metal and electronics recycling suppliers and subcontractors
[3708] This section addresses the mandatory criterion of describing the process of consultation with any entities that the reporting entity owns or controls (section 16(1)(f) Modern Slavery Act)
[3708] Given that Business Catalyst Systems Pty Ltd has no operations, consultation with this entity is not relevant
[3708] Adobe Australia has consulted with Adobe Inc., Adobe Ireland and Adobe Singapore when preparing this Statement
[3708] Consultations occurred by email communications and discussions between the entities key stakeholders
[3708] This section addresses the mandatory criterion of any other relevant information (section 16(1)(g) Modern Slavery Act)
[3708] ______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 15
[3708] Other reporting obligations
[7068] This statement is made in respect of Finbar Group Limited (ultimate holding company) and its wholly owned and controlled entities
[7068] Refer to Appendix A for a listing of the Companys wholly owned and controlled entities as at 30 June 2020
[7068] Operations Finbars operations are primarily focused on the development of residential apartments in the Perth metropolitan area
[7068] Finbar also holds residential property investments in Karratha as well as commercial property investments in Karratha, South Perth, and East Perth
[7068] At 30 June 2021, Finbar employed 31 staff engaged across its Perth and Karratha offices
[7068] All work undertaken is administrative or managerial in nature
[7068] All employees are directly employed by Finbar Group Limited
[7068] Supply Chain Finbar operates in WA with a localised immediate supply chain
[11377] Mapping our supply chain and analysing it for modern slavery risk
[11377] Developing and rolling out a modern slavery questionnaire for our suppliers
[11377] Performing risk assessments of new suppliers
[11377] Building a modern slavery risk register SECTION 4: Actions to Assess and Address Modern Slavery Risks Our efforts in the financial year ending 30 June 2022 focused on understanding risks and developing a clear policy and due diligence framework for identifying and addressing modern slavery
[11377] Our key actions are as follows: SECTION 5: Measuring the Effectiveness of our ongoing Modern Slavery Response The focus of our first year of reporting has been to map and identify potential modern slavery risks and develop appropriate steps to minimise those risks
[11377] We will monitor and track our progress through a process of reviews, oversight, and tracking KPIs
[11377] KPIs to track actions to address modern slavery include: Understanding the impact and risk of causing, contributing to or being directly linked to modern slavery
[11377] Number of modern slavery questionnaires completed
[991] Metal suppliers generally fall into three categories: casual suppliers, dealers and industrial suppliers
[991] On the electronics recycling side, corporations and original equipment manufacturers supply the majority of the electronics processed directly by us or one of our subcontractors
[991] Sims Municipal Recyclings suppliers are limited to collection service providers in each of the municipalities where we operate
[991] For our operations producing renewable energy through methane capture the trade suppliers are the landfills owners where we operate
[991] Our non-trade supply chain consists of equipment providers, transportation providers, uniform and personal protective equipment suppliers, maintenance and construction providers, and general administrative support providers, including temporary employment placement firms and recruiters
[991] Modern Slavery Risk Assessment Process PURCHASES IN HIGHER RISK COUNTRIES
[991] % APAC 8 EMEA 29 AMER 63 Number of Suppliers Per Region APAC Region PAPUA NEW GUINEA 57 suppliers for 0.1% of Total Purchases CHINA 4 suppliers for <0.1% of Total Purchases HONG KONG 20 suppliers for 0.1% of Total Purchases PAKISTAN 4 suppliers for 0.1% of Total Purchases Identified countries in which Sims Limited operates Consulted with business units and functions on internal risks and controls Obtained purchase data, including supplier location Researched multiple modern slavery risk index results for each country Assigned overall risk rating for each country Researched case studies for industries with high risk of modern slavery Consulted governmental and non-governmental sources for high-risk industries Concluded as to highest-risk countries and industries for Sims Limited 0.4% of all suppliers and 0.3% of all purchases are linked to higher risk regions 6 | Sims Limited Modern Slavery Statement 2020
[991] Areas of Risk We do business with suppliers and customers in various industries and locations and understand that the risk of modern slavery can vary across geographies and operations
[3708] Entities in the Adobe group have been subject to other jurisdictions reporting obligations
[3708] Adobe Inc has provided transparency statements under the California Transparency in Supply Chains Act of 2010
[3708] Adobe Systems Software Ireland Ltd has reported under the United Kingdom (UK) Modern Slavery Act 2015
[3708] We consider the implementation of these reporting regimes as important developments in combatting modern slavery and human trafficking around the world
[3708] Impact of COVID-19
[3708] During COVID-19, Adobe Australia has experienced an increased demand for its products and services as workplaces implemented work-from-home practices in a short period of time
[3708] We also had to divert resources to keep our people and customers safe during the pandemic
[3708] Accordingly, some of the measures which we had originally planned to help identify and address modern slavery risks have been postponed
[7068] Finbar engaged 353 suppliers over the FY21 reporting period
[7068] The majority of these suppliers a total of 336 are based in Australia
[7068] The remaining suppliers are based, or have relevant operations, in the United States, the United Kingdom, New Zealand and Israel
[7068] Most of Finbars supply chain is comprised of professional services providers, such as consultancy, legal and financial services
[7068] Finbar has also engaged a smaller number of suppliers to assist with its
[7068] operations, including business services, cleaning, hospitality, office and IT supplies, and security
[7068] Finbars remaining suppliers are largely based in the construction and real estate sectors, or have been engaged for repair and maintenance of its properties
[7068] Identifying risks of modern slavery Operations All Finbar employees are employed directly and under permanent, full time or part time contracts which significantly lowers the risk of modern slavery
[11377] Number of new and existing suppliers screened
[11377] Assigning suppliers with a risk rating following a risk assessment Reviewing our policies and procedures
[11377] Number of suppliers who have incorporated modern slavery provisions in contracts and/or our Modern Slavery Supplier Code of Conduct
[11377] Annual review of our Modern Slavery Policy and Modern Slavery Grievance Policy
[11377] Number of recorded modern slavery incidents, the type of human rights issue raised and the outcome Building staff awareness and capacity
[11377] Number and percentage of staff trained in identifying and addressing modern slavery
[11377] Number of key personnel who completed targeted training
[11377] Number of training sessions conducted (included format and topics covered) Reviewing our policies and procedures
[991] We endeavour to avoid being complicit in, or encouraging, activities that may result in human rights abuses
[991] As such, we performed a risk assessment of our operations and supply chain globally
[991] Ninety- nine percent of our 200,000 plus suppliers are located in lower risk countries as ranked by several world indices, such as the International Labour Organization Composite Score, the Prevalence Index Risk and Global Rights Index
[991] We identified three high-risk countries in which suppliers are located: Pakistan, China and Hong Kong; and one high-risk country, Papua New Guinea, in which we have both operations and suppliers
[991] On the customer side, we made sales to companies in all four of these high- risk countries, plus Egypt, which also registers as high risk based on these indices
[991] We also identified the following high-risk supplier types in our operations that are often associated with modern slavery risks of deceptive recruiting, debt bondage and forced labour
[991] Recruitment/placement agencies
[991] Contractors
[3752] Anti-Modern Slavery Statement
[3752] Financial Year 2019-2020
[3752] Our Policy St Hilliers Anti-Modern Slavery Policy is to use our best endeavours, as a socially responsible corporate group, to ensure that we maintain ethical sourcing and are not inadvertently involved through our business in facilitating modern slavery offences in breach of applicable Australian anti-modern slavery legislation
[3752] Modern slavery includes any conduct constituting a modern slavery offence under the relevant legislation and any conduct involving the use of any form of slavery, servitude or forced labour to exploit children or adults
[3752] In accordance with our Anti-Modern Slavery Program we are committed to ensuring that a high standard of ethical practices is adhered to in our supply chain, and that our contractors and suppliers are not involved in forced labour, debt bondage or any other facet of modern slavery
[3752] We seek to identify, mitigate and manage any risk to those group members to which Australian anti- modern slavery legislation applies that their normal business might involve or facilitate modern slavery practices
[3752] Our Anti- Modern Slavery Program is part of the general Compliance Program of the Group, which includes guidelines, procedures, structures and systems designed to ensure compliance with legal obligations
[3752] We are committed to a compliance culture within the St Hilliers Group and to continuous improvement in compliance performance
[7068] Finbar has implemented systems and standards to ensure that terms and conditions of engagement of labour meet or exceed legislative requirements in Western Australia
[7068] Finbar also engages several suppliers to deliver aspects of its operations
[7068] Within this group, Finbar has identified that some suppliers operate in sectors which may be vulnerable to risks of modern slavery on the basis of inherent workforce characteristics, such as migrant labour, or casual or low skilled labour
[7068] Given the widely-recognised modern slavery risks associated with certain sectors, Finbar considers that exposure to modern slavery is most likely to occur in the following areas of supply
[7068] office and IT supplies and equipment
[7068] business services, facilities management and managing office space (eg, security and cleaning services)
[7068] hospitality and catering; and
[7068] construction, repair and maintenance
[11377] Developing and implementing a Modern Slavery Policy
[11377] Developing a Modern Slavery Grievance Policy
[11377] Incorporating modern slavery provisions into new procurement contracts
[11377] Developing a Modern Slavery Supplier Code of Conduct which details the expectations of all suppliers to minimise and mitigate risks of modern slavery Building staff awareness and capacity
[11377] Launching an anti-slavery training module for all staff
[11377] Delivering tailored training to the Board
[11377] Delivering tailored training to key personnel involved in procurement and / or supplier contracts
[11377] Creating a modern slavery information page on the staff intranet with links to training, policies, and other resources
[991] Cleaning services
[991] Personal protective equipment/ uniform providers
[991] Construction
[991] Chartered vessels Supplier Risk We have identified suppliers in regions and specific industries that are at higher risk of modern slavery
[991] We have identified suppliers in Pakistan, China, Hong Kong and Papua New Guinea that present higher risks of modern slavery practices occurring based on the locations of their operations in higher risk geographies
[991] Within our non-trade supplier base, we also have identified potential modern slavery risks associated with our procurement of cleaning services, personal protective equipment and uniform providers, construction services and chartering of vessels
[991] The workers in these industries can be from vulnerable populations (not highly skilled, migrants, of low socioeconomic, culturally and linguistically diverse backgrounds)
[991] Customer Risk Our customers may present a modern slavery risk
[3752] The primary purpose of the Program is to identify, mitigate and manage (in compliance with such requirements (if any) as are specified in the relevant legislation) any risk that we may reasonably face that the provision of services might (whether inadvertently or otherwise) involve or facilitate modern slavery or that through our supply chains we might be directly linked to modern slavery
[3752] We are committed to supporting Australias international reputation as an active participant in the international movement against modern slavery
[3752] Cover photo by Shivendu Shukla, photo below by Jack Sloop, on Unsplash
[3752] St Hilliers Code of Ethical Practice [Based on the principles of the Ethical Trade Initiative Base Code and reflecting the international standards set out in the International Labour Organisation (ILO) Convention]
[3752] Suppliers and subcontractors must not use forced, bonded or involuntary labour and workers must not be obliged to surrender identity papers or pay a financial deposit as a condition of work
[3752] Workers must not be subject to physical or verbal abuse, threats or intimidation
[3752] Workers must not be required to work excessive hours and all workers should enjoy sufficient rest periods
[3752] Suppliers and subcontractors must not employ child labour and use workers under the age of 15, or the minimum legal working age in the country in question, if higher than 15