mila-ai4h/AIMS.au huggingface dataset:
[8585] MODERN SLAVERY STATEMENT PAGE 2 Iron Mine Contracting was formed to provide Civil, Mining, Crushing and Screening and Indigenous partnering opportunities to the West Australian market
[8585] We and our indigenous Joint Venture partners have been delivering projects to Tier 1 Resource clients since 2013
[14984] Aside from these key off-the-shelf products for our solar panels and inverters, the majority of goods and services in our supply chain are sourced from Australian suppliers
[14984] We procure a range of other goods and services to enable our businesses to function including consumable items such as tea, coffee and catering; stationery, postage and furniture; information and technology goods and services; financial and legal services, telecommunication services, cleaning services, marketing services and recruitment agencies
[14984] Risen Energy Services core business is the operation and asset management of solar farms
[14984] Risen Energy Services supply chains consist of field and maintenance services; corporate services; consulting services
[14984] Mandatory Criteria 3: Risks of Modern Slavery Risen Energy is aware that due to the nature and prevalence of Modern Slavery, every entity has risks of Modern Slavery in its operations or supply chains
[14984] Here we identify where our higher risk areas may be, before we discuss how we have assessed and addressed those risks
[14984] Operations We understand that renewable energy industries are considered high-risk industries in relation to modern slavery
[14984] We are aware that a large percentage of the worlds polysilicon, a crucial ingredient in modern-day solar panels, comes from Xinjiang where there is the alleged link to the forced labour practices
[1973] servitude
[1973] forced marriage
[1973] forced labour
[1973] debt bondage
[1973] the worst forms of child labour; and
[1973] deceptive recruiting for labour or services
[1973] Our approach focuses on embedding our modern slavery response as a core element of the Groups values, culture and conduct
[1973] Modern Slavery Statement 05
[4128] RJ Vincent (RJV) Modern Slavery Statement 2020
[4128] Table of Contents
[4128] Introduction
[4128] Structure
[4128] Business Outline
[4128] Workforce
[4128] Supply Chain
[4128] Policies and Procedures
[8585] Our client operations we support are typically are present in gold, iron ore and oil & gas sectors
[8585] OUR COMMITMENT We are committed to social responsibility matters and recognizes the importance of human rights and opposes slavery of all forms
[8585] We recognize Modern Slavery can include slavery, servitude, human trafficking, forced marriage, child and forced labour, debt bondage and we will continue to work to understanding the Modern Slavery risks, improving awareness and taking action to positively contribute to improving the state of Modern Slavery
[8585] Our statement for the Financial Year ended 30 June 2021 is made in accordance with the Australian Modern Slavery Act 2018 that covers off our group structure as outlined in 2
[8585] Reporting Entity Overview
[8585] REPORTING ENTITY OVERVIEW This is a combined statement is made in accordance with the Australian Modern Slavery Act 2018 and applies to DCL Corp Pty Ltd (ACN 633 008 992)
[8585] Our registered office located in Mt Lawley, WA and our financial year period is 1 July 2020 to 30 June 2021
[8585] The corporate structure is outlined below and this combined statement covers all named entities
[14984] In this reporting period we noted that the United States detained large numbers of imported solar panels at the port of entry into the country on the basis that they contained components from certain area
[14984] These were not Risen Group products DocuSign Envelope ID: 9714B3FC-DE88-4657-A83C-1C0FD6AF6F64
[14984] Page 3
[14984] Page 3 of 7
[14984] and we are not aware that is any connection with any aspects of our supply chain
[14984] In the UK and Europe there is a Code of Conduct in development that aims to provide clarity on how human rights risks in renewable supply chains can be effectively managed
[1973] Our structure, operations and supply chains Supply Chain In the reporting period, the Group made payments to approximately 773 suppliers
[1973] The Groups major categories of procurement included
[1973] Flinders Port Holdings 99.97% of suppliers and contractors who provided goods and services procured by the Group during the reporting period were based in Australia
[1973] Our small number of overseas vendors used in the reporting period were predominantly Original Equipment Manufacturers and suppliers of related spare parts
[1973] % Construction/ Engineering (including repairs and maintenance) 8.91% Operations (including cleaning, security and transport services) 3.91% Business Development, Safety & Facilities Management 6.21% I.C.T
[1973] (including hardware, software and services) 3.25% Hire/Lease of Fleet & Equipment 1.18% Utilities 0.05% Travel
[1973] Modern Slavery Statement Understanding and assessing our modern slavery risk During the reporting period, the Group took steps to better understand and assess its modern slavery risks to assist with identifying any risks of modern slavery practices in the Groups operations and supply chains
[1973] Under the Modern Slavery Act, the term risks of modern slavery practices means the potential to cause, contribute to, or be directly linked to modern slavery through the operations and supply chains of the Group
[4128] Whistleblower Policy
[4128] Potential Risks
[4128] Actions
[4128] Actions Taken in FY20
[4128] Commitment
[4128] Measure of Effectiveness
[4128] Introduction Ralmana Pty Ltd trading as R.J
[4128] Vincent & Co (RJV) ABN 93009149106 and its subsidiaries, value excellence, safety, respect, effort, teamwork and accountability
[8585] For the purposes of reference across this statement, we will refer to the whole group, including DCL Corp Pty Ltd as Iron Mine Contracting
[8585] OUR OPERATIONS AND SUPPLY CHAIN NEMMS JV Pty Ltd Iron Mine Contracting Pty Ltd Nyiyaparli Engineering Mine & Maintenance Services Pty Ltd (NEMMS) IMC PKKPE JV Pty Ltd Mata Kurlu JV Pty Ltd Thardu JV Pty Ltd Goomarin JV Pty Ltd Malinyu JV Pty Ltd IMC South Pty Ltd IMC Warnapari JV Pty Ltd Iron Mine Services Pty Ltd Indigenous Partnerships Australia Pty Ltd DCL Corp Pty Ltd PKKP JV Co Pty Ltd 100% 94% 50% 50% 50% 50% 50% 50% 6%
[8585] MODERN SLAVERY STATEMENT PAGE 3 Headquartered in Bayswater, Western Australia and employs over 300 people across project and workshop operations in Western Australia
[8585] Indigenous Partnerships Australia (IPA) is an affiliate company, formed with the express purpose of partnering with Traditional Owner businesses across Australia
[8585] Through their journey our partners expand and grow their capability and their businesses towards independence, deriving tangible benefits for our partners, their businesses and their communities
[8585] Our supply chain across good and services supplied in supporting business operations across our core activities and market segments as outlined above mostly include, but not limited to
[8585] Equipment & fleet hire
[8585] Consultancy
[14984] We do not shy away from this reality and rather we acknowledge our industry has a very important role to play in identifying risks that may be present in our business and addressing same
[14984] The steps we are taking in this regard are detailed below
[14984] In relation to our own employees, direct employees in Australia are engaged either by contract or under award agreements
[14984] Our employees are free to associate with their respective union
[14984] Risen Energy also offers its employees independent financial consulting
[14984] As above, we only have a very small number of employees working in arrangements where their visa ties them to Risen Energy and so it is straightforward for us to monitor the rights and working conditions of those two staff members
[14984] We acknowledge that any company utilising recruitment agencies to hire staff is exposed to some increased risks of modern slavery as these practices can, in some cases, reduce the oversight a company has over the hiring process and employment conditions
[14984] We also acknowledge that our use of temporary workers on occasion is an area we need to monitor closely
[1973] Risks that the Group may contribute to modern slavery practices include any acts or omissions that may facilitate or incentivise modern slavery
[1973] Risks that the Group may be directly linked to modern slavery practices means the risks that the Groups operations, products or services may be connected to modern slavery through the activities of another entity that any of the Groups entities has a business relationship with (eg a supplier)
[1973] To help us to better understand where our modern slavery risks lie, we have carefully considered the Australian Governments guidance on modern slavery risk indicators in the Modern Slavery Act 2018 - Guidance for Reporting Entities
[1973] In particular, we considered: Sector & Industry risk: whether particular sectors and industries may have high modern slavery risks because of their characteristics, products and processes (eg extractives, textiles/fashion, fishing, electronics, cleaning and agriculture)
[1973] Product & Services risk: whether certain products and services procured by the Group may have high modern slavery risks because of the way that they are produced/provided/ used (eg bricks, cotton and rubber)
[1973] Geographic/location risk: whether goods/ services procured from some countries may pose a higher risk of modern slavery, including due to poor governance, weak rule of law, conflict, migration flows and poverty in those countries
[1973] Entity risks: factors such as poor governance that may contribute to some entities (ie customers or suppliers) having particular modern slavery risks
[1973] Identifying the risks of modern slavery practices 07
[4128] These values are the foundation of how we conduct ourselves and interact with each other, our clients, suppliers, contractors and other stakeholders
[4128] RJV is subject to the Modern Slavery Act 2018 that commenced operation on 1 January 2019
[4128] The Act requires reporting entities subject to the Act, to produce an annual modern slavery statement
[4128] Our first annual statement is due on the 31st March 2021
[4128] We are committed to operating our business lawfully and ethically, ensuring that all aspects of our business practices, including our supply chains and contracting networks, are free from any form of slavery
[4128] We reject any and all forms of modern slavery which can take the form of unpaid or underpaid servitude, human trafficking and forced labour
[4128] We are dedicated to implementing effective systems and controls to ensure that it does not take place within our own business and we expect our suppliers and contractors to operate in accordance with all applicable modern slavery laws including those prohibiting human slavery and slavery like practices, human trafficking and child labour
[4128] In FY20, we started a detailed analysis of the risk of Modern Slavery in RJV operations and supply chain
[8585] Equipment parts, components and spares
[8585] External labour & subcontractors
[8585] PPE
[8585] Workshop consumables and tooling
[8585] Tyres & Rims
[8585] IT equipment and consumables
[8585] Transportation services
[8585] Facilities
[14984] Supply Chains We know that businesses can contribute to or be directly linked to modern slavery practices in their own supply chains by conducting operations in a way that may facilitate or incentivise modern slavery or simply by contracting with a supplier that engaged in modern slavery practices
[14984] Risen Energy is not aware of any actual incidents of Modern Slavery cases occurring in its operations or supply chains, but we understand that does not mean there is no risk
[14984] We have described our supply chains as set out above
[14984] The areas of our supply chains that we consider to be higher risk based on the literature and expert research include suppliers of solar panels and solar panel inputs overseas such as solar cells and wafers, polysilicon and quartzite
[14984] We also consider some local suppliers may pose a higher risk such as suppliers of coffee and tea, cleaning, stationery and furniture
[14984] We note that Germany and Australia are ranked by the global slavery index as having a low prevalence of modern slavery
[14984] Whilst China have a higher prevalence rate, as detailed above a lot of our dealings in these countries are either through our own entities or through entities that we have invested in ourselves and as such this enables us to maintain a greater degree of control and oversight of the goods and services that are procured from these geographic locations
[14984] Risen Energy acknowledges that our supply chains extend beyond those that we have direct contractual relationships with
[1973] In the reporting period, we trialled a risk assessment tool that incorporated a risk assessment matrix, based on our understanding of our risk in the preceding categories, and attributing a risk rating for each of our Tier 1 suppliers (that is, suppliers who provide goods or services to us directly)
[1973] While this exercise improved our general understanding of potential risks of modern slavery practices, we acknowledge that we have work ahead of us to implement a risk assessment tool that allows us to more confidently identify modern slavery risk in our supply chain, to guide our future actions in relation to that risk
[1973] Our intention for the next reporting period is to continue to explore methods for conducting a reliable risk assessment based on the key risk indicators, and we continue to investigate alternative risk assessment tools to assist us to better understand the risks in our supply chain
[1973] Operations The Group employs most of its workforce directly
[1973] Staff are engaged on full-time, part- time and casual contracts which are either compliant with the Fair Work Act 2009 (Cth) (Fair Work Act) or Enterprise Agreements approved by the Fair Work Commission
[1973] Australias Fair Work system, the national workplace relations system created by the Fair Work Act, includes mechanisms aimed at protecting vulnerable workers and promoting better governance
[1973] In assessing and addressing the risks in our operations, we were mindful of the Australian Governments guidance which indicates that modern slavery is only used to describe serious exploitation and does not include practices like substandard working conditions or underpayment of workers
[1973] However, these practices may be an indication of serious exploitation, or may escalate into modern slavery if not addressed
[4128] While our analysis, shows that the risk is relatively low, we are implementing several initiatives to minimise the risk of Modern Slavery within our business operations
[4128] This statement reflects our commitment to respecting Human Rights and highlights key actions we are taking to address risks in our own operations, and our supply chain, including risks associated with modern slavery
[4128] We value and observe all laws regarding corporate social responsibility, environmental and workplace safety protection, staff inclusion and diversity
[4128] The statement supports the Australian governments work on modern slavery
[4128] Structure 2.1
[4128] RJV is a privately owned Western Australian company, based at 4-5 Kirke St Balcatta WA 6021
[4128] Founded in 1955 to initially provide bulldozing services in country areas of Western Australia the company has since evolved to become one of Western Australias leading and most respected Civil Engineering and Mining Services contractors
[8585] Recruitment
[8585] Office supplies and staff amenities
[8585] Fuel and heavy equipment lubricants The various categories of good and service providers utilized in our supply chain spans across over 500 suppliers, all of whom are Australian entities with whom we directly transact with however, there is offshore supply chains within their operations in provision of supply
[8585] Earthmoving construction services Ore and mineral production Sustainable Outcomes Mining Support Services CIVIL CONSTRUCTION CRUSHING SCREENING INDIGENOUS PARTNERSHIP MINING CONTRACTING MINING SITE SERVICES
[8585] MODERN SLAVERY STATEMENT PAGE 4 Whilst our direct workforce is a major and integral component of our supply chain, we believes that there is low risk of modern slavery due to our compliance with relevant employment laws, occupational health & safety laws and industrial instruments
[8585] % of our workforce resides and is employed in operations in Australia
[8585] Additionally, the Code of Ethics Policy commits all employees and those we work with, to not use forced, compulsory or child labour
[8585] The Policy further commits us to uphold fundamental Human Rights by conducting ourselves and the business in accordance with relevant human rights laws and regulations Through our General Terms and Conditions, all subcontractors including employment agencies engaged are required to act in a legal and ethical manner Outside of direct employed workforce, approximately 80% of our supply chain spend is attributed to the following categories of goods & services to support our operations: As our suppliers are Australian entities, the overall risk of modern slavery we expect is low
[14984] We intend to commence interrogating and reviewing our second and third tier suppliers in future reporting periods, such as solar cell and wafer suppliers
[14984] We also acknowledge the ongoing impact of the COVID-19 pandemic
[14984] We understand that the effects of same continue to increase the vulnerability of workers around the world and place pressure on supply chains
[14984] Mandatory Criteria 4: Actions to Assess and Address Risks Risen Energy is committed to taking efforts to assess and address the risks identified above
[14984] We have adopted a continuous improvement approach
[14984] In May 2021, Sheffield Hallam University published a comprehensive report on Uyghur Forced Labour and Global Solar Supply Chains
[14984] Following that report Risen Energy had productive and positive conversations with several tier 1 suppliers and members of The Risen Group located in China
[14984] Rather than sourcing key materials from distinct third parties, Risen Energy largely acquires solar panels from its parent company and in the previous reporting period invested in two polysilicon facilities based in Inner Mongolia
[1973] Accordingly, we seek to also assess and address the risk of these practices
[1973] From time to time, the Group uses third party labour-hire arrangements to supplement our workforce and support our operations
[1973] We recognise that we have less visibility and control over these workers and their employment terms and conditions
[1973] We take steps to manage the risk of modern slavery by engaging with licensed labour hire providers with standing agreements in place with the Group
[1973] While the Group provides port related services to foreign vessels, we do not control the operations of those vessels which limits our oversight and impact on the working conditions of the crews on board
[1973] Additionally, the Group understands that there appears to be a perception globally, as noted in modern slavery statements of overseas port operators published in other jurisdictions, that ports may provide entry points for human trafficking
[1973] However, this risk is likely reduced in the Australian context, due to our more remote geographic location
[1973] Relevantly, the Group maintains a co- operative working relationship with the relevant authorities that oversee the activities of foreign vessels, including Australian Border Force and the Australian Maritime Safety Authority which is responsible for ensuring international conventions relating Identifying the risks of modern slavery practices Flinders Port Holdings
[4128] Our Mining Services division is one of Western Australias primary Open Pit Mining contractors, with multiple years of experience and knowledge servicing the Western Australian resources sector
[4128] RJV has become a partner of choice through our diversified capability in the resources sector including gold, iron ore and mineral sands
[4128] With a highly experienced and stable leadership group we bring a knowledge base and stability rarely seen in mining
[4128] Our Civil Infrastructure division has set its foundation on being one of the Western Australia's leading Civil Infrastructure contracting companies in both the resources sector and the local domestic market
[4128] Our experience and knowledge base is unrivalled with continuing repeat clients looking to us to deliver the highest quality of work safely, on-time and to specifications
[4128] Our team from management through to operator, is vastly experienced and dedicated to safety and best practices in the field, utilising our extensive fully owned fleet of plant and equipment
[4128] RJVs People & Culture and Risk & Compliance teams have various policies in place that support our day-to-day operations and corporate governance to ensure all employees and suppliers meet our core values
[4128] Our scope of services cover
[8585] According to the Global Slavery Index 2018 (GSI), Australia has a very low prevalence of modern slavery
[8585] However, we do recognize there is the potential for modern slavery in categories above such as Tyres & Rims, Equipment Parts, Components & Spares where our suppliers direct and indirect supply chains extend into low cost country regions
[8585] Whilst not in the top 80% of our spend, categories such as PPE, IT Equipment that we do procure goods & services could also present this risk in line with the GSI 2018 highlighting electronics and garments in the top 5 categories of importing risk
[8585] RISKS OF MODERN SLAVERY IN OUR OPERATIONS AND SUPPLY CHAIN Fuel & Oils Consultants Maintenance Services Tyres & Rims Workshop Consumables & Tooling Transportation Equiptment Parts, Components & Spares Subcontractors & External Labour Equiptment & Plant Hire % of FY21 Spend 0 10 20 30 40 50% % % % % %
[8585] MODERN SLAVERY STATEMENT PAGE 5 A summary of our actions and initiatives revolved around the following key areas during FY21 undertaken by various departments across our organization: Policy, Awareness and Communications From a broader policy standpoint, we undertook a review of our corporate policies
[8585] As part of this, the Code of Ethics Policy was updated to reflect our principles and position which outlines those we work with, not use forced, compulsory or child labour
[8585] The Policy commits us and our employees to uphold fundamental Human Rights by conducting ourselves and the business in accordance with relevant human rights laws and regulations
[8585] This policy is communicated through a variety of methods including
[14984] Our close involvement with the sources of these materials means we have a much greater level of oversight regarding the operations of those suppliers
[14984] Risen Energy is also heartened by the growing awareness in Australia and notes the development of many solar farms are now being made conditional on certification that the manufacture of the panels meets defined anti- DocuSign Envelope ID: 9714B3FC-DE88-4657-A83C-1C0FD6AF6F64
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[14984] slavery standards
[14984] Around the world, international investors are increasingly tying their investment in renewable energy projects to similar human rights obligations
[1973] Modern Slavery Statement 9 to maritime safety are upheld
[1973] We also assist with facilitating and enabling the work of the Australian Seafarers Welfare Council and other associated seafarer welfare organisations that operate to support the welfare of seafarers onboard vessels using our ports
[1973] In the reporting period, we have also developed a Group Whistleblower Policy, to comply with the new Australian whistleblower regime under the Corporations Act 2001 (Cth)
[1973] The Group Whistleblower Policy is available on the Groups websites and includes instructions to enable external and internal parties to raise any concerns that may relate to our operations via the independent FairCall reporting platform, which operates 24 hours a day