statement_id,sentence_orig_idxs,sentence,Approval,Signature,C1 (reporting entity),C2 (structure),C2 (operations),C2 (supply chains),C3 (risk description),C4 (risk mitigation),C4 (remediation),C5 (effectiveness),C6 (consultation) 61,0,"Baby Bunting Modern Slavery Statement 2020 This statement, pursuant to the Modern Slavery Act 2018 (Cth), describes the risks of modern slavery in the operations and supply chains of Baby Bunting1 and includes information about actions taken to address those risks for the financial year ended 28 June 2020",0,0,1,0,0,0,0,0,0,0,0 61,1,"Modern slavery includes trafficking in persons, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruitment for labour or services; and the worst forms of child labour",0,0,0,0,0,0,0,0,0,0,0 61,2,Modern slavery has severe consequences for its victims and often disproportionately impacts women and girls,0,0,0,0,0,0,0,0,0,0,0 61,3,"Minimising the risk of modern slavery in its supply chains and, in particular, ensuring that women and girls can exercise their own choices free from the undue influence that arises in modern slavery is a critical focus for Baby Bunting",0,0,0,0,0,0,0,0,0,0,0 61,4,This is Baby Buntings first modern slavery statement,0,0,0,0,0,0,0,0,0,0,0 61,5,"During the financial year, Baby Bunting has introduced a number of new processes intended to help it assess modern slavery risks in its supply chains and to seek to work with its suppliers to address those risks and to seek improvement in the labour, social and environmental aspects of its supply chains",0,0,0,0,0,0,0,0,0,0,0 61,6,Baby Bunting has also implemented training for its merchandise team to raise awareness of the risks of modern slavery in Baby Buntings operations,0,0,0,0,0,0,0,1,0,0,0 61,7,"In the years ahead, Baby Buntings focus will be on further developing and enhancing its ethical sourcing practices to reduce Baby Buntings exposure to modern slavery risks, as well as seeking to work with suppliers to provide appropriate remediation of modern slavery risks in the supply chain",0,0,0,0,0,0,0,1,0,1,0 2757,0,Modern Slavery Statement 2020,0,0,0,0,0,0,0,0,0,0,0 2757,1,2020 MODERN SLAVERY STATEMENT,0,0,0,0,0,0,0,0,0,0,0 2757,2,"Ixoms Modern Slavery Statement (Statement) which meets the requirements of the Australian Modern Slavery Act 2018 (Cth) (Act), describes the steps taken by IX Infrastructure Pty Ltd and its subsidiaries (collectively, Ixom) to comply with its obligations under the Act",0,0,0,0,0,0,0,0,0,0,0 2757,3,For the purpose of this Statement Ixoms reporting period is 1 October 2019 to 30 September 2020,0,0,0,0,0,0,0,0,0,0,0 2757,4,Ixom Modern Slavery Statement 2020,0,0,0,0,0,0,0,0,0,0,0 2757,5,"Introduction Modern slavery describes situations of severe exploitation and deprivation of the freedom of its victims through force, coercion, threats or deception",0,0,0,0,0,0,0,0,0,0,0 2757,6,"Broadly, the term modern slavery extends to any situations of serious exploitation where a person cannot refuse to work or leave work due to intimidation, abuse of power or violence",0,0,0,0,0,0,0,0,0,0,0 2757,7,"Further, modern slavery is used to refer to other illicit activities that have adverse effects on human rights, such as corruption and environmental damage",0,0,0,0,0,0,0,0,0,0,0 5015,0,"1 SMBC Leasing and Finance, Inc., Sydney Branch Modern Slavery Statement in accordance with the Modern Slavery Act 2018 (Commonwealth of Australia) Head office: 277 Park Avenue, New York, NY, USA Australian registered office: Level 40, The Chifley Tower, 2 Chifley Square, Sydney, New South Wales Australia Financial year ending 31 December 2020",0,0,0,1,0,0,0,0,0,0,0 5015,1,"SMBC Leasing and Finance, Inc as Reporting Entity SMBC Leasing and Finance, Inc (ARBN 602 309 366) (SMBC-LF) is the reporting entity giving this modern slavery statement (Modern Slavery Statement) in accordance with the Modern Slavery Act 2018 (Cth) (the Act)",0,0,1,0,0,0,0,0,0,0,0 5015,2,The Act requires SMBC-LF to provide disclosure concerning its efforts to assess and address the risks that modern slavery practices may be occurring in its operations and supply chain and the operations and supply chains of any entities that it owns or controls,0,0,0,0,0,0,0,0,0,0,0 5015,3,"SMBC-LFs structure, operations and supply chains SMBC-LF is an international leasing and finance company incorporated in the State of Delaware, USA",0,0,0,1,1,0,0,0,0,0,0 5015,4,"Sumitomo Mitsui Financial Group, Inc SMBC-LF is a wholly-owned indirect subsidiary of Sumitomo Mitsui Financial Group, Inc (SMFG) and is part of the SMFG group of companies (SMFG, together with its subsidiaries and affiliates are referred to as SMBC Group)",0,0,0,1,0,0,0,0,0,0,0 5015,5,SMFG is a publicly listed company,0,0,0,1,0,0,0,0,0,0,0 5015,6,SMFGs common shares are listed on the first section of the Tokyo Stock Exchange and the Nagoya Stock Exchange,0,0,0,0,0,0,0,0,0,0,0 5015,7,SMFGs American Depositary Receipts are also listed on the New York Stock Exchange,0,0,0,0,0,0,0,0,0,0,0 9307,0,STANMORE RESOURCES LIMITED | ACN 131 920 968 Modern Slavery Statement 2021,0,0,0,0,0,0,0,0,0,0,0 9307,1,"This Modern Slavery Statement 2021 (Statement) outlines progress to date to address the requirements of the Modern Slavery Act 2018 (Cth) (Act), including the actions we have taken to identify, assess and address modern slavery risks in our operations and supply chains, the development of our modern slavery frameworks and processes and our future commitments",0,0,0,0,0,0,0,0,0,0,0 9307,2,"We are committed to ensuring that we and our contractors do not engage in any conduct or omission which may contravene any modern slavery laws by the employment of any child, forced or illegal labour",0,0,0,0,0,0,0,0,0,0,0 9307,3,"Stanmore Resources Limited | Modern Slavery Statement 2021 We are committed to safety as our number one priority and to always achieving the best possible outcome Commitment We develop processes/ideas that increase productivity and company growth Innovation We do the right thing Integrity We aim to continuously enhance ourselves and our operations Continuous Improvement We display encouraging behaviour that builds and fosters lasting relationships Positive Attitude We implement the companys core values in our day-to-day operations Loyalty Company Values Genuine care for our people, their safety, the environment and the stakeholders involved with ouroperations",0,0,0,0,0,0,0,0,0,0,0 9307,4,Achieve sustainable development by,0,0,0,0,0,0,0,0,0,0,0 9307,5,Having high standards and a strong safety and healthculture,0,0,0,0,0,0,0,0,0,0,0 9307,6,Responsibly managing and maximising extraction of our resources and reserves via best-in-class miningpractices,0,0,0,0,0,0,0,0,0,0,0 9307,7,Ensuring the continuity of our business by fostering and developing growth and reserve replacementinitiatives,0,0,0,0,0,0,0,0,0,0,0 61,8,Baby Bunting means Baby Bunting Group Limited (ABN 58 128 533 693) and its wholly-owned subsidiary Baby Bunting Pty Ltd,0,0,0,1,0,0,0,0,0,0,0 61,9,Baby Bunting Pty Ltd is the operating entity of the group,0,0,0,1,0,0,0,0,0,0,0 61,10,This statement covers both Baby Bunting Group Limited and Baby Bunting Pty Ltd 1,0,0,0,0,0,0,0,0,0,0,0 61,11,"BABY BUNTINGS APPROACH TO MODERN SLAVERY RISKS IN OUR OPERATIONS AND SUPPLY CHAINS As the supply chains associated with Baby Buntings products are diverse and extend through various geographic locations, there is the potential for modern slavery risks to be present in these supply chains",0,0,0,0,0,0,1,0,0,0,0 61,12,"Ethical Sourcing Code During the financial year, Baby Bunting established an Ethical Sourcing Code that set out the minimum standards expected of Baby Buntings suppliers in areas of labour, environment and governance matters",0,0,0,0,0,0,0,1,0,0,0 61,13,"If suppliers are unable to demonstrate a commitment to comply with Baby Buntings Ethical Sourcing Code, Baby Bunting may choose to cease trading with that supplier",0,0,0,0,0,0,0,1,0,0,0 61,14,"Baby Buntings core values, which include being passionate, being considerate and being honest, are standards of behaviour that are fundamental to being who we are at Baby Bunting",0,0,0,0,0,0,0,0,0,0,0 61,15,Baby Bunting seeks to act with integrity and to use good judgement,0,0,0,0,0,0,0,0,0,0,0 2757,8,"With more than 950 employees globally, Ixom is the market leader in chemical manufacture and distribution in Australia and New Zealand",0,0,0,1,1,0,0,0,0,0,0 2757,9,"Ixom also has a growing presence in Australia, New Zealand and South East Asia through its life sciences raw materials and ingredients distribution business and in the USA and the United Kingdom through its source water technology businesses",0,0,0,0,1,0,0,0,0,0,0 2757,10,Ixom recognises the existence of modern slavery practices in some industries around the world,0,0,0,0,0,0,0,0,0,0,0 2757,11,Consistent with its corporate principals of conducting its business This Statement is a joint statement comprising the following reporting entities under the Act (Reporting Entities),0,0,1,0,0,0,0,0,0,0,0 2757,12,IX Infrastructure Pty Ltd (ACN 629 750 401),0,0,1,0,0,0,0,0,0,0,0 2757,13,Ixom HoldCo Pty Ltd (ACN 602 722 547),0,0,1,0,0,0,0,0,0,0,0 2757,14,Ixom Pty Ltd (ACN 602 723 768),0,0,1,0,0,0,0,0,0,0,0 2757,15,Ixom Holdings Pty Ltd (ACN 131 367 112),0,0,1,0,0,0,0,0,0,0,0 5015,8,"As at 31 March 2020, SMFGs capital was 2,339.9 billion yen",0,0,0,0,1,0,0,0,0,0,0 5015,9,"SMBC Group is a global financial group that develops operations in a wide range of fields including banking, leasing, securities, credit cards and consumer finance",0,0,0,0,1,0,0,0,0,0,0 5015,10,"SMBC Group is comprised of four business units: the Retail Business Unit, the Wholesale Business Unit, the International Business Unit and the Global Markets Business Unit",0,0,0,0,1,0,0,0,0,0,0 5015,11,SMBC Group's overseas network currently comprises 137 branches and offices in 40 countries and regions,0,0,0,0,1,0,0,0,0,0,0 5015,12,"As at 31 March 2020, SMBC Group had approximately 86,443 permanent employees",0,0,0,1,0,0,0,0,0,0,0 5015,13,"Further information on SMBC Groups business can be found in SMFG's annual report and financial statements, which can be accessed at: https://www.smbc.co.jp/global/",0,0,0,0,0,0,0,0,0,0,0 5015,14,"SMBC-LF operations SMBC-LF specializes in originating, structuring, arranging and investing in structured asset- based, tax efficient and accounting driven financings in the US and worldwide",0,0,0,0,1,0,0,0,0,0,0 5015,15,SMBC-LF has offices in four (4) countries with approximately 53 employees,0,0,0,1,1,0,0,0,0,0,0 9307,8,"Developing projects in the renewable energy space to support our existing businesses reducing our carbon and emissions footprint Building and fostering a culture of an agile, entrepreneurial and simple organisation",0,0,0,0,0,0,0,0,0,0,0 9307,9,Focusing on continuous improvement and operationalexcellence,0,0,0,0,0,0,0,0,0,0,0 9307,10,Mission Statements,0,0,0,0,0,0,0,0,0,0,0 9307,11,Stanmore Resources Limited | Modern Slavery Statement 2021,0,0,0,0,0,0,0,0,0,0,0 9307,12,REPORTING ENTITY This Statement is published for the purposes of the Act,0,0,0,0,0,0,0,0,0,0,0 9307,13,"It is a joint Statement given by Stanmore Resources Limited ACN 131 920 968 (SMR) on behalf of each of the following reporting entities and their owned and controlled entities (together, the Stanmore Group) during the period 1 July 2020 to 31 December 2021 (Reporting Period)",0,0,1,1,0,0,0,0,0,0,0 9307,14,Stanmore Resources Limited ACN 131 920 968,0,0,1,1,0,0,0,0,0,0,0 9307,15,Stanmore IP Coal Pty Ltd ACN 606 244 615 (Stanmore IP Coal),0,0,1,1,0,0,0,0,0,0,0 61,16,We want all our team members to think about how our actions impact others,0,0,0,0,0,0,0,0,0,0,0 61,17,"Baby Bunting provides products, services and advice to parents and parents-to-be and their families",0,0,0,0,1,0,0,0,0,0,0 61,18,"We rely on their trust, as well as the trust of the communities in which we operate, our investors and other stakeholders",0,0,0,0,0,0,0,0,0,0,0 61,19,Our suppliers play a critical role in helping Baby Bunting to meet our standards of behaviour and our values,0,0,0,0,0,0,0,0,0,0,0 61,20,Our mutual success depends on building and maintaining trust in the way each of us conducts our business,0,0,0,0,0,0,0,0,0,0,0 61,21,The minimum requirements stated in the Code are: being committed to the health and safety of our team; being committed to acting legally and ethically; being committed to respecting labour and human rights; being committed to communicating openly and honestly; being committed to environmentally sustainable practices,0,0,0,0,0,0,0,1,0,0,0 61,22,"Among other things, these requirements establish minimum standards for our suppliers that require a commitment to: providing a safe and healthy working environment and taking all practical and reasonable measures to eliminate workplace injuries and illness; complying with all applicable laws and regulations and not being involved in bribery or corruption in any form; maintaining policies and practices to allow violations, misconduct or grievances to be reported by workers and addressed without fear of retaliation; ensuring all work is freely chosen without the use of forced or compulsory labour and with a zero tolerance approach to the use of illegal child labour and respecting workers rights to lawfully and peacefully form or join trade unions of their choosing and to bargain collectively",0,0,0,0,0,0,0,1,0,0,0 61,23,"Ethical Sourcing Procedures Baby Bunting has also developed Ethical Sourcing Procedures, which are progressively being introduced as a measure to ensure that Baby Buntings ethical sourcing expectations are met",0,0,0,0,0,0,0,1,0,0,0 2757,16,Ixom Operations Pty Ltd (ACN 600 546 512); and,0,0,1,0,0,0,0,0,0,0,0 2757,17,Ixom International Holdings Pty Ltd (ACN 602 439 878),0,0,1,0,0,0,0,0,0,0,0 2757,18,"safely and with integrity, Ixom is working to identify and mitigate any risks associated with modern slavery for all of its businesses globally, and to measure the effectiveness of its actions",0,0,0,0,0,0,0,0,0,0,0 2757,19,The Act requires Ixom to prepare a report providing information on,0,0,0,0,0,0,0,0,0,0,0 2757,20,"Ixoms structure, its operations and supply chains",0,0,0,0,0,0,0,0,0,0,0 2757,21,the risks of modern slavery in Ixoms operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 2757,22,"the actions taken to assess and address those risks, including due diligence and training",0,0,0,0,0,0,0,0,0,0,0 2757,23,the effectiveness of those actions,0,0,0,0,0,0,0,0,0,0,0 5015,16,"SMBC-LF has operations in Australia, the United Kingdom, Germany and the United States of America",0,0,0,0,1,0,0,0,0,0,0 5015,17,"As a subsidiary of Sumitomo Mitsui Banking Corporation (SMBC), SMBC-LF supports an extensive global network of SMBC group entities which SMBC either owns or controls",0,0,0,1,0,0,0,0,0,0,0 5015,18,These group entities operate throughout these regions providing the financial services and credit related businesses to SMBCs global network of customers,0,0,0,0,1,0,0,0,0,0,0 5015,19,"Further information on SMBCs business, including a list of SMBCs principal domestic subsidiaries, principal overseas subsidiaries and principal affiliates and a summary of the main businesses of these companies can be found here: https://www.smbc.co.jp/global/aboutus/business; and https://www.smbc.co.jp/global/aboutus/profile/group/ As at 31 March 2020, SMBC employed 27,957 employees",0,0,0,1,0,0,0,0,0,0,0 5015,20,"SMBC-LF in Australia SMBC-LF established its presence in Australia in 2014 through its branch (ARBN 602 309 366) in Sydney, New South Wales",0,0,0,1,0,0,0,0,0,0,0 5015,21,"SMBC-LFs Australian operations are based in Sydney, New South Wales",0,0,0,0,1,0,0,0,0,0,0 5015,22,"SMBC-LFs registered office in Australia is Level 40, The Chifley Tower, 2 Chifley Square, Sydney, New South Wales Australia",0,0,0,1,0,0,0,0,0,0,0 5015,23,"In Australia, SMBC-LF provides financial advisory, lease financing, receivable purchases and asset backed debt financing for wholesale customers only",0,0,0,0,1,0,0,0,0,0,0 9307,16,Stanmore Bowen Coal Pty Ltd ACN 606 241 847,0,0,1,1,0,0,0,0,0,0,0 9307,17,Stanmore Wotonga Pty Ltd ACN 606 243 770; and,0,0,1,1,0,0,0,0,0,0,0 9307,18,"Stanmore IP South Pty Ltd ACN 625 536 094 Due to a change in the Stanmore Groups financial reporting year, the Reporting Period of this Statement is the 18 month period comprising Stanmore Groups new financial year (being 1 January 2021 to 31 December 2021) and the period 1 July 2020 to 31 December 2020 (being period following our first reporting period and previous financial year, 1 July 2019 to 30 June 2020)",0,0,1,1,0,0,0,0,0,0,0 9307,19,"References in this statement to Stanmore, we, our and us are references to the Stanmore Group",0,0,0,0,0,0,0,0,0,0,0 9307,20,"The Boards of each of the Stanmore Group entities include at least one Director of SMR, and the entities are centrally governed and managed",0,0,0,1,0,0,0,0,0,0,0 9307,21,"The Stanmore Group entities have a common registered office at Level 32, 12 Creek Street, Brisbane, Queensland",0,0,0,1,0,0,0,0,0,0,0 9307,22,This statement has been approved by the Board of SMR on 29 June 2022,1,0,0,0,0,0,0,0,0,0,0 9307,23,Stanmore Resources Limited | Modern Slavery Statement 2021 3 2.1,0,0,0,0,0,0,0,0,0,0,0 61,24,Administration of the Ethical Sourcing Procedures is undertaken by members of Baby Buntings ethical sourcing team,0,0,0,0,0,0,0,1,0,0,0 61,25,Baby Bunting has partnered with one of the worlds leading ethical trade service providers to enable suppliers and their manufacturing sites to efficiently share information with Baby Bunting to enable risk assessments to be undertaken,0,0,0,0,0,0,0,1,0,0,0 61,26,The assessment of modern slavery and ethical sourcing risk can be influenced by factors such as industry and geographic location as well as some product categories,0,0,0,0,0,0,0,0,0,0,0 61,27,The Ethical Sourcing Procedures are intended to enable Baby Bunting to direct its focus to those suppliers for whom modern slavery and ethical sourcing risks may appear to be more immediate,0,0,0,0,0,0,0,0,0,0,0 61,28,"OUR STRUCTURE, OPERATIONS AND SUPPLY CHAIN",0,0,0,0,0,0,0,0,0,0,0 61,29,Baby Buntings business is the retail supply of nursery and maternity goods and related complementary services,0,0,0,0,1,0,0,0,0,0,0 61,30,Baby Bunting operates 56 stores around Australia as well as an online store at babybunting.com.au,0,0,0,0,1,0,0,0,0,0,0 61,31,"Baby Bunting employs more than 1,270 team members in Australia, with the majority employed in Baby Buntings stores",0,0,0,1,1,0,0,0,0,0,0 2757,24,how Ixom assesses the effectiveness of those actions; and,0,0,0,0,0,0,0,0,0,0,0 2757,25,the process of consultation between Ixom and its related entities in respect of modern slavery compliance,0,0,0,0,0,0,0,0,0,0,0 2757,26,2020 MODERN SLAVERY STATEMENT,0,0,0,0,0,0,0,0,0,0,0 2757,27,4 From the CEO Ixom opposes slavery in all its forms,0,0,0,0,0,0,0,0,0,0,0 2757,28,"Operating in a global environment, Ixom is committed to transparency around our supply chains",0,0,0,0,0,0,0,0,0,0,0 2757,29,We have welcomed the introduction of modern slavery laws which target modern slavery and human trafficking and take our obligations very seriously,0,0,0,0,0,0,0,0,0,0,0 2757,30,We have undertaken a lot of work to build and launch a program around identifying and managing modern slavery risks in Ixoms supply chain for our first reporting year and to execute our first work plan,0,0,0,0,0,0,0,0,0,0,0 2757,31,"Ixom, in all of our operations, is committed to developing and implementing policies and procedures that aim to reduce the risk of modern slavery at our operations and in our supply chains",0,0,0,0,0,0,0,0,0,0,0 5015,24,The Australian operations form part of the International Business Unit of SMBC Group,0,0,0,0,1,0,0,0,0,0,0 5015,25,Further information on SMBCs global and Australian businesses can be accessed at: https://www.smbc.co.jp/global/; and https://www.smbc.co.jp/asia/australia/,0,0,0,0,0,0,0,0,0,0,0 5015,26,"SMBC supply chain As part of the SMBC group, SMBC-LF outsources a number of support services via service level agreements to the larger SMBC group entities, including SMBC Sydney Branch, in which office SMBC-LF is co-located",0,0,0,0,0,1,0,0,0,0,0 5015,27,"SMBCs business is primarily undertaken in an office environment with the majority of its suppliers providing goods and services in connection with office premises (such as stationery supplies, cleaning services and food and refreshments supplies), financial, technology and other professional services and corporate travel",0,0,0,0,0,1,0,0,0,0,0 5015,28,"Given its geographic spread, SMBCs supply chain is geographically diverse with suppliers from countries in which SMBC has operations",0,0,0,0,0,1,0,0,0,0,0 5015,29,"SMBCs suppliers range from small businesses to international organisations, operating across the developed and developing regions in which SMBC has operations",0,0,0,0,0,1,0,0,0,0,0 5015,30,"Further, SMBC is connected with many thousands more organisations across the world via the supply chains of its first tier suppliers",0,0,0,0,0,1,0,0,0,0,0 5015,31,"By way of example, the main categories of suppliers and service providers (by aggregate dollar value for the financial year ending 31 March 2020) for SMBC Sydney Branch relate to information technology equipment and software; rent; information services; market research; hospitality (including business",0,0,0,0,0,1,0,0,0,0,0 9307,24,"Our structure SMR is an Australian metallurgical coal mining, development and exploration company headquartered in Brisbane, Queensland and listed on the Australian Securities Exchange (ASX: SMR)",0,0,0,1,1,0,0,0,0,0,0 9307,25,"SMRs majority shareholder is Singapore listed entity Golden Energy and Resources Limited (GEAR) through its wholly-owned subsidiary, Golden Investments (Australia) Pte Ltd (Golden Investments)",0,0,0,1,0,0,0,0,0,0,0 9307,26,The ultimate parent company of Stanmore is Indonesian based PT Sinarindo Gerbangmas,0,0,0,1,0,0,0,0,0,0,0 9307,27,"During the Reporting Period, SMRs primary operating subsidiaries, including incorporation details, are as shown in the figure below",0,0,0,1,0,0,0,0,0,0,0 9307,28,"REPORTING ENTITYS STRUCTURE, OPERATIONS AND SUPPLY CHAINS Stanmore Resources Limited ACN 131 920 968 Other wholly owned exploration and non-operating subsidiaries",0,0,0,0,0,0,0,0,0,0,0 9307,29,Each exploration entity is a wholly-owned proprietary company holding exploration tenements in Queensland,0,0,0,1,0,0,0,0,0,0,0 9307,30,Stanmore IP South Pty Ltd ACN 625 536 094 Stanmore IP Coal Pty Ltd ACN 606 244 615 Reporting entities Non-reporting entities Stanmore Bowen Coal Pty Ltd ACN 606 241 847 (Holding company) Stanmore Wotonga Pty Ltd ACN 606 243 770 (Holding company) Dormant subsidiaries,0,0,0,1,0,0,0,0,0,0,0 9307,31,Stanmore Resources Limited | Modern Slavery Statement 2021 2.2,0,0,0,0,0,0,0,0,0,0,0 61,32,"The balance are located at Baby Buntings Store Support Office and Distribution Centre, at Dandenong South in Victoria",0,0,0,0,1,0,0,0,0,0,0 61,33,"Baby Bunting engages a small number of contractors, primarily for short-term or ad hoc roles in the Distribution Centre",0,0,0,0,0,1,0,0,0,0,0 61,34,Contractors are also engaged for specific project or specialist roles in the Store Support Office from time to time,0,0,0,0,0,1,0,0,0,0,0 61,35,"Further information about Baby Buntings business and operations, including its corporate governance arrangements, are available at babybunting.com.au/investor",0,0,0,0,0,0,0,0,0,0,0 61,36,Baby Buntings core purpose is to support new and expectant parents in the early years of parenthood,0,0,0,0,0,0,0,0,0,0,0 61,37,"Our vision is to be the most loved baby retailer for every family, everywhere",0,0,0,0,0,0,0,0,0,0,0 61,38,Baby Bunting is committed to the elimination of modern slavery and we recognise that the management of suppliers in our supply chains is critical to addressing these issues,0,0,0,0,0,0,0,0,0,0,0 61,39,"Baby Buntings principal product categories include prams, cots and nursery furniture, car safety, toys, babywear, feeding, nappies, manchester and associated accessories",0,0,0,0,1,0,0,0,0,0,0 2757,32,Our modern slavery statement recognises we are on a journey to ensuring we have a supply chain that is free of modern slavery and committed to continuous improvement,0,0,0,0,0,0,0,0,0,0,0 2757,33,David Head Managing Director and CEO,0,1,0,0,0,0,0,0,0,0,0 2757,34,Statement from the Chief Executive Officer,0,0,0,0,0,0,0,0,0,0,0 2757,35,"Structure, operations and supply chain 3.1 Structure Operations Ixoms headquarters are located in Melbourne, Australia",0,0,0,1,1,0,0,0,0,0,0 2757,36,"During the reporting period Ixom consisted of 26 registered companies, incorporated and operating in 16 countries, as set out in Annexure A (page 18)",0,0,0,1,1,0,0,0,0,0,0 2757,37,"A number of Ixom entities do not have operations, such as holding companies",0,0,0,0,1,0,0,0,0,0,0 2757,38,"During the reporting period Ixom undertook processes to divest the entities that operated its businesses in Latin America, China and Hong Kong and these divestments were successfully completed shortly after the end of the reporting period",0,0,0,0,1,0,0,0,0,0,0 2757,39,2020 MODERN SLAVERY STATEMENT,0,0,0,0,0,0,0,0,0,0,0 5015,32,travel); telecommunications; and professional advisers,0,0,0,0,0,1,0,0,0,0,0 5015,33,The arrangements SMBC Sydney Branch has with its suppliers are combination of long-term relationships with large multinational suppliers established and maintained as part of SMBCs global operations and short term relationships with smaller local suppliers,0,0,0,0,0,1,0,0,0,0,0 5015,34,This list is broadly reflective of the categories of suppliers and service providers of SMBC globally and the entities which it owns or controls,0,0,0,0,0,0,0,0,0,0,0 5015,35,"SMBC-LF and SMBCs risks of modern slavery practices in operations and supply chains SMBC-LF uses the technology, policies and procedures provided by SMBC to identify and capture risks associated with modern slavery",0,0,0,0,0,0,0,1,0,0,0 5015,36,SMBC conducts business internationally with operations spanning developed and developing countries and regions,0,0,0,0,0,0,1,0,0,0,0 5015,37,"Given the breadth of these operations, there is a potential risk that elements of the supply chain are engaging in modern slavery practices, particularly parts of the supply chain relating to the supply of goods and services",0,0,0,0,0,0,1,0,0,0,0 5015,38,The risk is increased in relation to suppliers to SMBCs operations in developing countries and regions,0,0,0,0,0,0,1,0,0,0,0 5015,39,"For example, SMBC operates in a number of jurisdictions rated as high risk for modern slavery by the Global Slavery Index",0,0,0,0,0,0,1,0,0,0,0 9307,32,Our operations SMRs operations and exploration projects are located in the Bowen and Surat Basins in Queensland and are owned through a number of wholly-owned subsidiaries,0,0,0,0,1,0,0,0,0,0,0 9307,33,"Mining and Exploration During the Reporting Period, Stanmores foundation asset was the Isaac Plains Complex in Moranbah, Queensland comprising",0,0,0,0,1,0,0,0,0,0,0 9307,34,"Isaac Plains (ceased) and Isaac Plains East, and Isaac Downs mines: These open-cut coal mines have a current product coal output of approximately 2.4Mtpa",0,0,0,0,1,0,0,0,0,0,0 9307,35,"In 2021, Stanmore transitioned existing operations to our Isaac Downs location following regulatory approval by the Queensland Government in mid-2021",0,0,0,0,1,0,0,0,0,0,0 9307,36,Isaac Plains Underground development project: A Bankable Feasibility Study has been completed for a potential underground extension in the eastern portion of the Isaac Plains mining lease,0,0,0,0,1,0,0,0,0,0,0 9307,37,The project development phase has been deferred until additional port capacity can be sourced at competitive prices,0,0,0,0,1,0,0,0,0,0,0 9307,38,"Operating Infrastructure: This includes dragline, coal handling and preparation plant, site infrastructure and train load-out facilities",0,0,0,0,1,0,0,0,0,0,0 9307,39,"During the Reporting Period, Stanmore had a principal contract arrangement with Golding Contractors Pty Ltd (Golding), responsible for the mining and coal handling and preparation plant operational activities at Isaac Plains Complex",0,0,0,0,0,1,0,0,0,0,0 61,40,"Baby Bunting sells national branded products as well as its own private label products, currently under the brands of 4baby and Bilbi",0,0,0,1,0,0,0,0,0,0,0 61,41,"There are over 6,000 unique products available in Baby Bunting stores",0,0,0,0,1,0,0,0,0,0,0 61,42,"The majority of products sold in Baby Bunting stores are purchased from distributors and suppliers based in Australia, with almost all of these products manufactured overseas",0,0,0,0,0,1,0,0,0,0,0 61,43,Baby Bunting also purchases products directly from suppliers or agents based overseas,0,0,0,0,0,1,0,0,0,0,0 61,44,"A very high proportion of these products originate from supply chains based in the Asia region, with most products manufactured from supply chains based in, or connected with, China",0,0,0,0,0,1,0,0,0,0,0 61,45,"Baby Bunting also procures a diverse range of goods and services in connection with its business operations at its retail stores, Distribution Centre and Store Support Office including office supplies (IT equipment, stationery and furniture), cleaning services (retail stores and Store Support Office and waste disposal services), store development services (store fit out) and other services (marketing, consultancy and professional services)",0,0,0,0,0,1,0,0,0,0,0 61,46,"In summary, the procedures involve the following broad steps: Information provided by suppliers through a self-assessment questionnaire is combined with industry and country-specific risk factors to arrive at an initial risk rating",0,0,0,0,0,0,0,1,0,0,0 61,47,The risk rating is assessed by Baby Buntings ethical sourcing team and where the risk rating is considered to be elevated further inquiries are undertaken,0,0,0,0,0,0,0,1,0,0,0 2757,40,"Structure, operations and supply chain Ixoms operations around the globe 6",0,0,0,0,0,0,0,0,0,0,0 2757,41,2020 MODERN SLAVERY STATEMENT,0,0,0,0,0,0,0,0,0,0,0 2757,42,"Structure, operations and supply chain Brands Our values GROW DRIVEN EXCEL ENERGISE Suppliers During the reporting period Ixom conducted operations in the following countries: Australia Colombia Peru Argentina Fiji Singapore Brazil Hong Kong Thailand Canada Indonesia United Kingdom Chile Malaysia United States of America China New Zealand 8",0,0,0,0,0,1,0,0,0,0,0 2757,43,2020 MODERN SLAVERY STATEMENT,0,0,0,0,0,0,0,0,0,0,0 2757,44,"3.2 Operations Ixoms industry segments are intertwined, supplying manufactured chemicals and services, traded chemical products and providing logistics solutions and products to the mining, oil and gas industries",0,0,0,0,1,0,0,0,0,0,0 2757,45,"Chemicals are commonly used across many industries and essential services and feature in the food we eat, the water we drink and the utilities that we enjoy and add value to our lives",0,0,0,0,0,0,0,0,0,0,0 2757,46,"Ixom supplies chemicals, raw materials, equipment and services solutions to industrial customers operating in the following end markets",0,0,0,0,1,0,0,0,0,0,0 2757,47,"Food, beverage and nutrition",0,0,0,0,1,0,0,0,0,0,0 5015,40,"In these countries, jurisdiction risk means that some local suppliers have increased modern slavery risk when compared to similar suppliers from lower risk jurisdictions, such as Australia",0,0,0,0,0,0,1,0,0,0,0 5015,41,"Using the Global Slavery Index 2018 as a source, SMBC has identified Information Technology services and software, manufacturing, agriculture, construction, mining, trade and service industries (such as hospitality and cleaning) as high risk sectors for modern slavery",0,0,0,0,0,0,1,0,0,0,0 5015,42,SMBC operates in the banking and financial services industry and primarily within an office environment and therefore it does not operate in these sectors,0,0,0,0,0,0,1,0,0,0,0 5015,43,"However, and as noted above, SMBC relies on service providers who do operate in some of these sectors, most notably in IT services (including telecommunications) and hospitality and cleaning",0,0,0,0,0,0,1,0,0,0,0 5015,44,SMBCs supply chain includes a number of products that have been linked with modern slavery,0,0,0,0,0,0,1,0,0,0,0 5015,45,"For example, according to the Global Slavery Index 2018, the number 1 product category at risk of modern slavery imported into G20 countries (by US$ value) are laptops, computers and mobile phones",0,0,0,0,0,0,1,0,0,0,0 5015,46,"SMBCs operations rely heavily on the use of laptops, computers and mobile phones",0,0,0,0,0,0,1,0,0,0,0 5015,47,"SMBC is working on further defining its supply chain risk, which is a significant undertaking given its operational footprint and the global nature of its supply chains",0,0,0,0,0,0,0,0,0,0,0 9307,40,Golding reports under the Act as part of the NRW Group joint statement,0,0,0,0,0,0,0,0,0,0,0 9307,41,"In addition to its operations and development projects, Stanmore has a portfolio of more than 2,000km2 of prospective, granted exploration tenements located in the Bowen and Surat Basins, including the following",0,0,0,0,1,0,0,0,0,0,0 9307,42,The Range,0,0,0,0,1,0,0,0,0,0,0 9307,43,Belview,0,0,0,0,1,0,0,0,0,0,0 9307,44,Lilyvale,0,0,0,0,1,0,0,0,0,0,0 9307,45,Mackenzie,0,0,0,0,1,0,0,0,0,0,0 9307,46,Clifford Our website www.stanmore.net.au provides more information on our projects and operations,0,0,0,0,1,0,0,0,0,0,0 9307,47,"During the Reporting Period, we had 33 employees consisting of 27 full-time, 4 part-time, and 2 casual employees",0,0,0,1,0,0,0,0,0,0,0 61,48,These inquiries can include the supplier providing an ethical sourcing audit report to provide further information and assurance to Baby Bunting about the supplier and its operations,0,0,0,0,0,0,0,1,0,0,0 61,49,"Where required, Baby Buntings ethical sourcing team will assess audit reports provided and consider instances of non-compliance identified in those reports",0,0,0,0,0,0,0,0,0,1,0 61,50,"Where non-compliance instances are identified, the ethical sourcing team may identify corrective actions that need to be taken and specify a time by which those actions need to be undertaken",0,0,0,0,0,0,0,0,1,0,0 61,51,"If the number or extent of non-compliance identified is critical, the Ethical Sourcing Procedures specify that Baby Bunting will not trade with that supplier",0,0,0,0,0,0,0,0,1,0,0 61,52,"Similarly, Baby Bunting may choose to end a supplier relationship where corrective actions have not been undertaken in the time requested",0,0,0,0,0,0,0,0,1,0,0 61,53,Baby Bunting recognises the importance of assisting its suppliers and others in the supply chain to continually improve their practices,0,0,0,0,0,0,0,0,0,0,0 61,54,"At times, this can result in better overall outcomes for all relevant stakeholders in the supply chain",0,0,0,0,0,0,0,0,0,0,0 61,55,"Of course, where parties have not achieved significant improvement in respect of identified issues over a period of time, the appropriate response to manage the corresponding modern slavery and ethical sourcing risks may be to cease to deal with that element of the supply chain",0,0,0,0,0,0,0,1,0,0,0 2757,48,Process cleaning technologies,0,0,0,0,1,0,0,0,0,0,0 2757,49,"Personal care, health & household",0,0,0,0,1,0,0,0,0,0,0 2757,50,Agriculture,0,0,0,0,1,0,0,0,0,0,0 2757,51,Water treatment,0,0,0,0,1,0,0,0,0,0,0 2757,52,Pulp and paper,0,0,0,0,1,0,0,0,0,0,0 2757,53,Building and construction,0,0,0,0,1,0,0,0,0,0,0 2757,54,Industrial,0,0,0,0,1,0,0,0,0,0,0 2757,55,Plastics,0,0,0,0,1,0,0,0,0,0,0 5015,48,"While SMBC (through its risk control processes; see section 4 below) aims to mitigate the risk that its suppliers are directly engaged in modern slavery, there is also a risk that suppliers have modern slavery risks in their own supply chains",0,0,0,0,0,0,1,0,0,0,0 5015,49,This risk is particularly acute for suppliers operating in markets where there is a geographic modern slavery risk,0,0,0,0,0,0,1,0,0,0,0 5015,50,"SMBC is in the process of assessing where this risk, is present given its broad operations and supply chains",0,0,0,0,0,0,0,0,0,0,0 5015,51,SMBC-LF outsources certain functions to SMBC and third party service providers,0,0,0,0,0,1,0,0,0,0,0 5015,52,"For example, SMBC-LF engages various third parties to provide services, such as information technology systems development and document archiving",0,0,0,0,0,1,1,0,0,0,0 5015,53,"There is a risk that such providers have modern slavery risks within their operations and supply chain, particularly given that most of these services are heavily reliant on IT hardware and software",0,0,0,0,0,0,1,0,0,0,0 5015,54,These entities are assessed for their approach to managing modern slavery risk,0,0,0,0,0,0,0,1,0,0,0 5015,55,SMBC continues its review of its modern slavery supply chain risk,0,0,0,0,0,0,0,1,0,0,0 9307,48,"As of 31 December 2021, Stanmore had 28 employees and a total workforce of 344, including Golding personnel and their sub-contractors",0,0,0,1,0,1,0,0,0,0,0 9307,49,All employees were employed by Australian entities under written contracts and subject to Australian labour laws,0,0,0,0,0,0,0,0,0,0,0 9307,50,"Joint ventures 2021 also saw the Stanmore Group acquire Peabody Energy Australias 50% interest in the Millennium and Mavis Downs Joint Venture, with M Resources Trading Pty Ltd holding the remaining 50% interest",0,0,0,0,1,0,0,0,0,0,0 9307,51,"A subsidiary of M Resources, M Mining Pty Ltd, is the manager and operator of the Joint Venture",0,0,0,0,0,0,0,0,0,0,0 9307,52,The acquisition was completed in July 2021,0,0,0,0,0,0,0,0,0,0,0 9307,53,Entities within the Millennium and Mavis Downs Joint Venture will be required to submit their own modern slavery statements if they meet the $100 million in annual consolidated revenue threshold specified by the Act,0,0,0,0,0,0,0,0,0,0,0 9307,54,"In Q4 2021, SMR signed a definitive share sale and purchase agreement with BHP Minerals Pty Ltd (BHP) to acquire, via a wholly-owned subsidiary, BHPs 80% interest in BHP Mitsui Coal Pty Ltd, now known as Stanmore SMC Pty Ltd (SMC)",0,0,0,0,1,0,0,0,0,0,0 9307,55,"This transaction, successfully closed on 3 May 2022, will position Stanmore among Australias largest metallurgical coal producers",0,0,0,0,1,0,0,0,0,0,0 61,56,"Governance arrangements Baby Buntings ethical sourcing team work with, but are separate from, Baby Buntings merchandise team",0,0,0,0,0,0,0,0,0,0,0 61,57,The ethical sourcing team report to the Group Legal Counsel,0,0,0,0,0,0,0,0,0,0,0 61,58,Baby Buntings Audit and Risk Committee has oversight of Baby Buntings processes to manage modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 61,59,"Training During the financial year, Baby Buntings merchandise team received training in respect of modern slavery and the risks that exist in Baby Buntings supply chains",0,0,0,0,0,0,0,1,0,0,0 61,60,Further training will be provided in the year ahead,0,0,0,0,0,0,0,1,0,0,0 61,61,"Whistleblower Protection Policy Baby Bunting has a Whistleblower Protection Policy which is intended to ensure that concerns regarding unethical or illegal practices, which includes modern slavery concerns, can be reported",0,0,0,0,0,0,0,1,0,0,0 61,62,"For the purposes of the policy, reports can be made via an independently operated whistleblower hotline",0,0,0,0,0,0,0,1,0,0,0 61,63,"Reports can be made anonymously, and Baby Buntings whistleblowing protection processes are intended to ensure that the anonymity of people making whistleblowing reports is protected as required by the Whistleblower Protection Act",0,0,0,0,0,0,0,1,0,0,0 2757,56,Mining and metals,0,0,0,0,1,0,0,0,0,0,0 2757,57,Oil and gas,0,0,0,0,1,0,0,0,0,0,0 2757,58,Ixoms chemicals and materials businesses manufacture chemical products and also procure chemicals and materials for resale with Ixom acting as distributor or reseller,0,0,0,0,1,0,0,0,0,0,0 2757,59,Supply chain,0,0,0,0,0,0,0,0,0,0,0 2757,60,"Ixoms supply chain for products and services focuses on, amongst other things, safety, reliability, quality and functionality of products and services, regulatory compliance and the ability to source and supply in the volumes required when needed",0,0,0,0,0,0,0,0,0,0,0 2757,61,"Ixoms traded chemicals, and also equipment components used in its manufacturing plants and water technology equipment, are sourced from manufacturers and resellers that meet Ixoms standards",0,0,0,0,0,0,0,0,0,0,0 2757,62,These products are in most cases imported in to the country of resale via ocean shipping,0,0,0,0,0,1,0,0,0,0,0 2757,63,"Ixoms suppliers outside Australia and New Zealand are located predominantly in North America, Asia and Europe",0,0,0,0,0,1,0,0,0,0,0 5015,56,"It continues to consult with the group entities within its operational control (including SMBC-LF), given that such entities operate in the same financial services industry as SMBC, it believes that the modern slavery risks in its operations and supply chains is representative of the risks in the operations and supply chains of such group entities",0,0,0,0,0,0,0,1,0,0,0 5015,57,It is also acknowledged that modern slavery risks can also arise through the operations and actions of SMBC-LFs customers,0,0,0,0,0,0,0,0,0,0,0 5015,58,"SMBC-LF, therefore, may be linked to such risks, as either a provider of financial services",0,0,0,0,0,0,0,0,0,0,0 5015,59,"Again, where these customers operate within jurisdictions or sectors with a high risk of modern slavery, this risk is heightened",0,0,0,0,0,0,0,0,0,0,0 5015,60,SMBC-LF and SMBCs control processes in respect of these risks are set out in section 4 below,0,0,0,0,0,0,0,0,0,0,0 5015,61,SMBC-LF and SMBCs actions to assess and address risks of modern slavery practices,0,0,0,0,0,0,0,0,0,0,0 5015,62,SMBC Groups commitment to human rights SMBC Group believes that it has an ethical responsibility to promote human rights by showing respect for human rights through its own behavior and by sharing its ethos with its customers,0,0,0,0,0,0,0,0,0,0,0 5015,63,"As a signatory to the United Nations Global Compact, the SMBC Group is committed to fulfilling the social responsibilities that are expected of it as a global financial group to create a society that is built on the utmost respect for human rights as directed by the ""Universal Declaration of Human Rights,"" the ""ILO Declaration on Fundamental Principles and Rights at Work,"" the ""ISO 26000"" guidelines on the social responsibilities of organisations, and the ""Guiding Principles on Business and Human Rights"" advocated by the UN Human Rights Council in 2011",0,0,0,0,0,0,0,1,0,0,0 9307,56,Stanmore is undergoing a transformational period for the business as a result of the acquisition of SMC and will report on these developments in the next reporting period under the Act,0,0,0,0,0,0,0,0,0,0,0 9307,57,"Our supply chains Our supply chains include procurement for the coal mining, development, and exploration operations (which accounts for the vast majority of our supply chain) and procurement for our general business operations",0,0,0,0,0,1,0,0,0,0,0 9307,58,"In the Reporting Period, Stanmores direct suppliers were predominantly located in Australia",0,0,0,0,0,1,0,0,0,0,0 9307,59,We had over 300 active suppliers with over $400 million in procurement expenditure,0,0,0,0,0,1,0,0,0,0,0 9307,60,Over 99% of expenditure was paid to suppliers registered in Australia,0,0,0,0,0,1,0,0,0,0,0 9307,61,The majority of this expenditure (58%) was to Golding as our mining and CHPP operator,0,0,0,0,0,1,0,0,0,0,0 9307,62,Stanmore Resources Limited | Modern Slavery Statement 2021,0,0,0,0,0,0,0,0,0,0,0 9307,63,"Stanmore Resources Limited | Modern Slavery Statement 2021 USA 1.0% Brazil 0.3% Singapore 0.3% Australia 98.1% Vendor numbers geographical distribution by percentage Mining, development and exploration operations supply chain Stanmore procures (directly and indirectly) services and products from a broad range of industries",0,0,0,0,0,1,0,0,0,0,0 61,64,"Where issues are investigated and substantiated, Baby Bunting will take appropriate action",0,0,0,0,0,0,0,0,1,0,0 61,65,Measuring effectiveness Baby Bunting has a focus on further developing the systems it has in place for ensuring ethical sourcing,0,0,0,0,0,0,0,0,0,0,0 61,66,"In the years ahead, Baby Bunting has a goal of expanding the range of suppliers who are complying with its ethical sourcing procedures, completing risk assessments and, where necessary, undertaking corrective actions",0,0,0,0,0,0,0,1,0,0,0 61,67,Baby Bunting acknowledges the importance of seeking to ensure that modern slavery is eliminated from our supply chains and we understand the role we can play in achieving that,0,0,0,0,0,0,0,0,0,0,0 61,68,The steps we have undertaken are the beginning of our efforts in this area,0,0,0,0,0,0,0,0,0,0,0 61,69,We are committed to the ongoing delivery of our initiatives and working with our stakeholders to contribute to the elimination of modern slavery,0,0,0,0,0,0,0,0,0,0,0 61,70,This statement was approved by the Boards of Baby Bunting Group Limited and Baby Bunting Pty Ltd,1,0,0,0,0,0,0,0,0,0,0 61,71,Signed,0,1,0,0,0,0,0,0,0,0,0 2757,64,"Structure, operations and supply chain 10",0,0,0,0,0,0,0,0,0,0,0 2757,65,13 2020 MODERN SLAVERY STATEMENT,0,0,0,0,0,0,0,0,0,0,0 2757,66,"Risk of modern slavery practices 4.1 Overview Whilst it is not aware of any modern slavery in its own operations or supply chains, Ixom wants to ensure its suppliers continue to uphold the highest standards expected of them",0,0,0,0,0,0,0,0,0,0,0 2757,67,Ixom maintains zero tolerance for slavery in its operations and supply chain,0,0,0,0,0,0,0,0,0,0,0 2757,68,"Ixoms Legal and Compliance Group, in consultation with a multidisciplinary working group including Ixoms product managers, procurement teams and other internal stakeholders, undertook a modern slavery compliance risk assessment in 2019",0,0,0,0,0,0,0,1,0,0,0 2757,69,"The process involved the analysis of cross sections of Ixoms Australian, New Zealand and South East Asian businesses to identify those parts of its operations and supply chain that carry a higher level of modern slavery risks",0,0,0,0,0,0,0,1,0,0,0 2757,70,"From this analysis, Ixom developed a set of key focus areas for modern slavery compliance and due diligence for the forthcoming 12 month period as well as a longer horizon work plan for the forthcoming 3 years",0,0,0,0,0,0,0,0,0,0,0 2757,71,"The Bowtie methodology used in this risk assessment was implemented as an important element of Ixoms risk assessment, a model generally applied to analyse and demonstrate causal relationships in specific risk scenarios",0,0,0,0,0,0,0,0,0,0,0 5015,64,Further information on SMBC Groups commitment to sustainability can be found here: https://www.smfg.co.jp/english/sustainability/group_sustainability/management/,0,0,0,0,0,0,0,0,0,0,0 5015,65,"SMFG has also published a Statement on Human Rights, which recognises the ethical responsibility of the SMBC Group to support and respect the protection of internationally proclaimed human rights and to prevent complicity on human rights violations",0,0,0,0,0,0,0,1,0,0,0 5015,66,Further information in relation to SMBC Groups commitment to human rights can be found here: https://www.smfg.co.jp/english/sustainability/group_sustainability/forrights/,0,0,0,0,0,0,0,0,0,0,0 5015,67,SMBC Group has positioned the sustainable development of society as a key issue and in October 2018 the establishment of its Corporate Sustainability Committee enables SMBC Group to better carry out related initiatives,0,0,0,0,0,0,0,1,0,0,0 5015,68,SMBC-LF and SMBC acknowledges its obligation to respect human rights and acknowledges its responsibilities in an evolving area,0,0,0,0,0,0,0,0,0,0,0 5015,69,SMBC-LF and SMBC are committed to an ongoing review and assessment of its business practices and approach to human rights in light of changing global circumstances,0,0,0,0,0,0,0,1,0,0,0 5015,70,"SMBC Group is committed to maintaining and improving systems and processes to mitigate the risk that it might be involved in the commission of slavery and human trafficking in any part of its operations, customers and supply chain (including contractors and suppliers), products, services and employee activities",0,0,0,0,0,0,0,0,0,0,0 5015,71,"SMBC-LF and SMBCs policies and procedures, including, where applicable, those relating to modern slavery risks, are reviewed on a regular basis for applicability and appropriateness",0,0,0,0,0,0,0,0,0,1,0 9307,64,The external supply chain for our mining operations is summarised as follows,0,0,0,0,0,1,0,0,0,0,0 9307,65,"Exploration specialised drilling contractors, geophysical contractors, assay laboratories, and consultants",0,0,0,0,0,1,0,0,0,0,0 9307,66,"Mining open pit mining equipment, hire and maintenance contractors, open-pit drilling & blasting contractors, fuels, lubes, and explosives suppliers",0,0,0,0,0,1,0,0,0,0,0 9307,67,"Processing grinding media, reagents, and shutdown contractors",0,0,0,0,0,1,0,0,0,0,0 9307,68,"Delivery/transport coal product transport for export by rail and ship (for export vessels are contracted by the purchasing party for FOB delivery, not by Stanmore)",0,0,0,0,0,1,0,0,0,0,0 9307,69,"For the Reporting Period, Stanmore had a principal contract arrangement with Golding, a subsidiary of NRW Holdings Limited, for the Isaac Plains Complex",0,0,0,0,0,1,0,0,0,0,0 9307,70,Golding was responsible for mining and CHPP operational activities on-site and engaged additional subcontractors to enable contract fulfilment,0,0,0,0,0,1,0,0,0,0,0 9307,71,"As a result of this arrangement, the majority of Stanmores procurement expenditure was directly with Golding",0,0,0,0,0,1,0,0,0,0,0 61,72,"CONCLUSION 4 Matt Spencer, CEO and Managing Director, Baby Bunting Group Limited, Baby Bunting Pty Ltd",0,1,0,0,0,0,0,0,0,0,0 96,0,"2019 Intel Corporation Statement on combating modern slavery May 2020 reporting for fiscal year ending December 28, 2019 Intel1 is committed to ensuring modern slavery and human trafficking play no part in our business or supply chain",0,0,0,0,0,0,0,0,0,0,0 96,1,"As part of this commitment, we continually strive to achieve the highest level of ethical, environmental, and employee-related standards within our own businesses and supply chains, making sure that employees, partners, suppliers, and others are working together to eradicate modern slavery and human trafficking",0,0,0,0,0,0,0,0,0,0,0 96,2,"The California Transparency in Supply Chains Act of 2010 (SB 657), the U.K",0,0,0,0,0,0,0,0,0,0,0 96,3,"Modern Slavery Act 2015, and the Australian Modern Slavery Act 2018 (the Acts) require certain companies to state their efforts and action taken during the financial year to ensure modern slavery and human trafficking are not taking place in their operations and supply chains",0,0,0,0,0,0,0,0,0,0,0 96,4,"Similarly, the revised Federal Acquisition Regulation (FAR) 52.222-50 (Combating Trafficking in Persons) and new FAR provision 52.222-56 (Certification Regarding Trafficking in Persons Compliance Plan) focus on eradicating modern slavery and human trafficking from the U.S",0,0,0,0,0,0,0,0,0,0,0 96,5,Federal Government contracting supply chain,0,0,0,0,0,0,0,0,0,0,0 96,6,This 2019 Intel Corporation Modern Slavery and Human Trafficking Statement (the Statement) is made pursuant to the requirements of the Acts and reflects Intels efforts to combat the conduct prohibited by the FARs anti-slavery and anti-trafficking provisions,0,0,1,0,0,0,0,0,0,0,0 2757,72,"In utilising this method, Ixom composed a visual summary of a range of plausible scenarios that could arise in relation to modern slavery and subsequent control measures to reduce or eliminate the risk of modern slavery being or becoming present within its operations and supply chain",0,0,0,0,0,0,0,0,0,0,0 2757,73,"In evaluating the potential occurrence of non-compliance, Ixom considered appropriate recovery measures and possible consequences of actions taken",0,0,0,0,0,0,0,0,0,0,0 2757,74,"Based on the outcome of this risk assessment, Ixom developed a work plan for its first reporting period which comprised of applying its modern slavery due diligence process in respect of third parties who supply the following goods and services to Ixom",0,0,0,0,0,1,0,0,0,0,0 2757,75,office and site cleaning service providers,0,0,0,0,0,1,0,0,0,0,0 2757,76,ocean shipping and freight services; and,0,0,0,0,0,1,0,0,0,0,0 2757,77,raw materials grown or extracted from the earth and supplied to Ixom with little or no refinement,0,0,0,0,0,1,0,0,0,0,0 2757,78,"Operations During the reporting period approximately 70% of Ixoms employees were based in Australia, New Zealand and the USA",0,0,0,0,1,0,0,0,0,0,0 2757,79,Ixom takes its compliance with labour laws extremely seriously,0,0,0,0,0,0,0,0,0,0,0 5015,72,Screening for connections to jurisdictions with human rights issues is conducted on an ongoing basis,0,0,0,0,0,0,0,0,0,1,0 5015,73,"SMBC subsidiary in the UK (SMBC Bank International plc, SMBC BI) implemented an Anti- Slavery Policy in 2015",0,0,0,0,0,0,0,1,0,0,0 5015,74,This was expanded in 2018 to the SMBC EMEA Anti-Slavery Policy and is applicable to all SMBC branches in the EMEA region including SMBC-LFs EMEA operations,0,0,0,0,0,0,0,1,0,0,0 5015,75,"The Policy states that in the spirit of best practice, SMBC seeks to ensure that slavery and human trafficking are not taking place in any part of its businesses or supply chains",0,0,0,0,0,0,0,0,0,0,0 5015,76,"SMBCs actions in connection with its workplace environment SMBC seeks to provide a workplace free from any type of violation of employees' human rights, including but not limited to, forced labour, harassment and discrimination without distinction of any kind such as race, gender, sexual orientation, gender identity, religion, creed, national origin, disability, family status and birth status",0,0,0,0,0,0,0,1,0,0,0 5015,77,This is reflected in SMBCs numerous public statements on its commitment to protecting human rights as well as its employee codes of conduct and policy and procedure manuals in operation across its global network,0,0,0,0,0,0,0,1,0,1,0 5015,78,"SMBC and its group entities within its operational control (including SMBC-LF) require their employees to adhere to the same high standards that it has committed to in respect of human rights, with employees agreeing as part of their employment terms to adhere to various codes of conduct and other organisational policies which require employees to comply with all applicable laws and regulations, which includes those relating to modern slavery",0,0,0,0,0,0,0,1,0,0,0 5015,79,"SMBC and the group entities which it owns or controls (including SMBC-LF) have in place a whistleblower framework that includes an alarm line to rapidly detect and rectify legal violations, violations of bank rules, and cases of abuse of power",0,0,0,0,0,0,0,1,0,0,0 9307,72,"As disclosed in NRW Groups joint statement, Goldings supply chains include primarily labour-hire, plant and equipment (including parts), concrete, quarry, asphalt, fuel, OTR tyres, and steel reinforcement",0,0,0,0,0,1,0,0,0,0,0 9307,73,"We also worked with suppliers from Brazil, Singapore and the USA, predominantly in the professional services sector",0,0,0,0,0,1,0,0,0,0,0 9307,74,"In addition to the long-term mining services agreement with Golding, we generally engaged our other suppliers with a view to creating long-standing, stable relationships, or diversifying our local engagement",0,0,0,0,0,0,0,1,0,0,0 9307,75,"Stanmore Resources Limited | Modern Slavery Statement 2021 In 2021, SMR undertook the appointment process for a new mining services contractor, and we will be transitioning to an owner-operator model for the CHPP",0,0,0,0,0,0,0,0,0,0,0 9307,76,"Mining activities under this new appointment are set to commence in Q2 2022, and we will report on this new appointment in our statement for the next reporting period",0,0,0,0,0,0,0,0,0,0,0 9307,77,General business operations supply chain The main types of goods and services that Stanmore procures for our general business operations are,0,0,0,0,0,1,0,0,0,0,0 9307,78,"Safety and other attire: This includes personal protective equipment, including safety glasses, gloves, work boots, hard hats, and high visibility vests used by our employees at our facilities",0,0,0,0,0,1,0,0,0,0,0 9307,79,"Corporate/building services: The services that we use to maintain our offices, including maintenance services, cleaning and security",0,0,0,0,0,1,0,0,0,0,0 96,7,"The statement aims to provide consumers detailed information to make better, more informed choices about the products and services they buy and the companies they support",0,0,0,0,0,0,0,0,0,0,0 96,8,"Throughout this Statement we reference modern slavery, which includes forced labor, debt bonded labor, indentured labor, involuntary labor, including prison labor, slavery, human trafficking, and child labor",0,0,0,0,0,0,0,0,0,0,0 96,9,"References to Intel, we, us our as used in this Statement refers collectively to Intel Corporation and its subsidiaries, including Intel Corporation (UK) Limited, Image Processing Techniques Limited, Intel Australia Pty, Limited, and McAfee Australia Pty, Limited",0,0,0,1,0,0,0,0,0,0,0 96,10,"Excludes Mobileye, Intels autonomous driving subsidiary based in Israel",0,0,0,1,0,0,0,0,0,0,0 96,11,Intel acquired Mobileye in 2017,0,0,0,1,0,0,0,0,0,0,0 96,12,2019 Intel Corporation Statement on Combating Modern Slavery,0,0,0,0,0,0,0,0,0,0,0 96,13,"Our Business and Supply Chain Intel is a world leader in the design and manufacturing of essential technologies that power the cloud and an increasingly smart, connected world",0,0,0,0,1,0,0,0,0,0,0 96,14,"We design and build technologies that serve as the basis for consumer products, commercial systems, and infrastructure equipment",0,0,0,0,1,0,0,0,0,0,0 2757,80,During the reporting period Ixom had robust systems in place regarding local labour law compliance in each country where it employed people,0,0,0,0,0,0,0,0,0,0,0 2757,81,"The outcome of the modern slavery compliance risk assessment demonstrates that Ixoms operations may be susceptible to the presence of modern slavery risks through its engagement of direct and indirect suppliers, and in the supply chains of indirect suppliers who provide products and services to Ixom, including cleaning, transport and shipping, (particularly in the operations of shipping companies engaged by service providers engaged by Ixom to arrange the transport of Ixoms products on Ixoms behalf)",0,0,0,0,0,0,1,0,0,0,0 2757,82,Supply chain In the reporting period Ixom chose to focus the majority of its work plan activities on the supply chains of Ixoms Australian and New Zealand businesses,0,0,0,0,0,0,0,0,0,0,0 2757,83,Those businesses are operated solely by Ixom Operations Pty Ltd and represent the majority of Ixoms revenue and earnings at a group level and also the majority of the Ixom Groups supply chain activities,0,0,0,0,0,0,0,0,0,0,0 2757,84,Ixom has identified the potential for modern slavery risks to arise in the following parts of its supply chain,0,0,0,0,0,0,1,0,0,0,0 2757,85,raw materials procured to produce goods and finished products,0,0,0,0,0,0,1,0,0,0,0 2757,86,"countries from which Ixom sources chemicals or materials where those countries have little or no human rights or worker protections, poor law enforcement or where modern slavery is widely practiced or accepted; and",0,0,0,0,0,0,1,0,0,0,0 2757,87,particular industries in which modern slavery practices or violations have been uncovered by third parties and publicly documented,0,0,0,0,0,0,1,0,0,0,0 5015,80,This extends to modern slavery concerns,0,0,0,0,0,0,0,1,0,0,0 5015,81,"SMBC in the Asia Pacific region, including Australia, has recently launched a new Whistleblowing Policy and external reporting platform in the region that enhances the confidentiality and protection of whistleblowers, including service providers and their employees, in accordance with the applicable whistleblowing legislation Employees of SMBC and those of its group entities which it owns or controls (including SMBC- LF) are encouraged to identify and report immediately via SMBC's whistleblowing framework, without any negative repercussions, any conduct that the employee knows or reasonably believes would violate legal or regulatory requirements or ethical standards, which include such requirements and standards set out in internal policies and guidance in relation to human rights and modern slavery",0,0,0,0,0,0,0,1,0,0,0 5015,82,"Additionally, in order to ensure proper understanding of the risks posed by modern slavery and human trafficking, SMBC will look to update its compliance training for its employees to include modern slavery and human trafficking risks",0,0,0,0,0,0,0,1,0,0,0 5015,83,This type of employee training would be in addition to existing training that SMBC employees are provided in respect of human rights,0,0,0,0,0,0,0,1,0,0,0 5015,84,SMBCs consultation with the group entities within its operational control (including SMBC-LF) will look to extend this training to employees of these entities,0,0,0,0,0,0,0,1,0,0,0 5015,85,SMBCs further actions in connection with its operations SMBC group entities over which SMBC has operational control (including SMBC-LF) operate subject to internal group policies which require these entities to report any breaches of law to SMBC,0,0,0,0,0,0,0,1,0,0,0 5015,86,"On this basis, they are obliged to notify SMBC of any breach of law relating to slavery and other human rights issues",0,0,0,0,0,0,0,1,0,0,0 5015,87,"Further, in accordance with applicable obligations under the Modern Slavery Act 2015 (United Kingdom) (UK Act), certain group entities within SMBCs operational control, including SMBC- LF, have published Slavery and Human Trafficking Statements, which provide disclosures concerning their respective efforts to address the issues of slavery and human trafficking",0,0,0,0,0,0,0,0,0,0,0 9307,80,"Site and office consumables: The site and office consumables for our employees, including stationery and kitchen consumables",0,0,0,0,0,1,0,0,0,0,0 9307,81,"Information and communications technology: This includes the computer hardware and software, printers, audio/visual equipment, desk phones and mobile phones our employees use",0,0,0,0,0,1,0,0,0,0,0 9307,82,Flights and accommodation: Flights and accommodation and associated costs used by employees to conduct the Stanmore business,0,0,0,0,0,1,0,0,0,0,0 9307,83,"Professional services: The professional services we procure externally include accounting, legal, insurance, and environmental consulting",0,0,0,0,0,1,0,0,0,0,0 9307,84,"In 2021, SMR undertook the appointment process for a new mining services contractor, and we will be transitioning to an owner-operator model for the CHPP",0,0,0,0,0,1,0,0,0,0,0 9307,85,"Stanmore Resources Limited | Modern Slavery Statement 2021 During the Reporting Period, Stanmore has continued to develop its framework for identifying, addressing and reducing modern slavery risks in our operations and supply chains",0,0,0,0,0,0,0,0,0,0,0 9307,86,"Risk assessment methodology We have used a risk assessment methodology that considers several indicators of modern slavery risks, including sector and industry, the type of products and services, geographical location and specific entity risk",0,0,0,0,0,0,0,1,0,0,0 9307,87,The risk factors we have identified are based on the risk indicators identified in,0,0,0,0,0,0,0,1,0,0,0 96,15,"We offer computing, networking, data storage, and communications solutions to a broad set of customers spanning multiple industries",0,0,0,0,1,0,0,0,0,0,0 96,16,"Our global supply chain includes more than 10,000 Tier 12 Suppliers in 89 countries that provide intellectual property, direct materials for our production processes, tools and machines for our factories, and logistics and packaging services, as well as software, office materials, and travel services",0,0,0,0,0,1,0,0,0,0,0 96,17,"We also rely on other companies to manufacture, assemble and test some of our components and products",0,0,0,0,0,1,0,0,0,0,0 96,18,Intels efforts in combating modern slavery require strong engagement and collaboration with our global suppliers,0,0,0,0,0,0,0,0,0,0,0 96,19,It is critical that we partner closely with them to understand and evaluate their supply chain procedures and empower them to establish programs and policies that mitigate the risk of modern slavery,0,0,0,0,0,0,0,0,0,0,0 96,20,"For additional information about Intel and its operations, refer to the 2019 Annual Report on form 10-K",0,0,0,0,0,0,0,0,0,0,0 96,21,"Our Commitment and Policies Addressing the Prevention of Modern Slavery Since our founding, uncompromising integrity and professionalism have been the cornerstone of Intels business",0,0,0,0,0,0,0,0,0,0,0 96,22,"Today Intel is not only committed to the highest standards of ethical conduct, human rights, and social and environmental responsibility, but is also committed to maintaining and improving any system or process that helps protect workers and prevent human rights violations",0,0,0,0,0,0,0,0,0,0,0 2757,88,The risks associated with modern slavery increase when these factors intersect,0,0,0,0,0,0,1,0,0,0,0 2757,89,"Ixom acknowledges that risks may also be present deep in its supply chains, such as the mining of certain minerals and the production of raw materials that are sold or resold to Ixom",0,0,0,0,0,0,1,0,0,0,0 2757,90,"Raw materials With reference to the Verisk-Maplecroft index, certain raw materials distributed by Ixom, as follows, are associated with industries that carry a higher risk of modern slavery practices: Citrus fruits Cumin Tea Fish Vanilla Coffee Cobalt Cocoa Geographic locations Ixom has identified modern slavery risks based on geographic locations of suppliers in Ixoms supply chain located in countries listed as higher risk by Transparency International and the Global Slavery Index",0,0,0,0,0,0,1,0,0,0,0 2757,91,Ixoms suppliers operating in such higher risk countries are predominantly located in China and India,0,0,0,0,0,0,1,0,0,0,0 2757,92,"Industries In consideration of the industries in which Ixom operates, the Global Estimates of Modern Slavery as developed by International Labour Organization (ILO) and the Walk Free Foundation in partnership with the International Organization for Migration1 refers to industries that carry a higher risk of modern slavery practices: Manufacturing Construction Commercial agriculture As part of Ixoms forthcoming reporting periods Ixom will utilise these learnings to focus on a selection of suppliers identified as high risk on the basis of raw materials, regions and industries, products or service sector",0,0,0,0,0,0,1,0,0,0,0 2757,93,During the reporting period Ixom undertook the following key actions to assess and address modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 2757,94,Due diligence Development of a due diligence process to assess suppliers engaged during the reporting period,0,0,0,0,0,0,0,0,0,0,0 2757,95,The process includes initial information gathering through to escalation and management of any identified modern slavery risks and involves two stages: Basic due diligence Suppliers of any products or services to any Ixom business that fit within the target categories of Ixoms modern slavery work plan must undergo basic due diligence,0,0,0,0,0,0,0,0,0,0,0 5015,88,These statements can be accessed here: SMBC: http://www.smbc.co.jp/aboutus/english/csr/ SMBCE: http://www.smbcgroup.com/emea/about-us/corporate-disclosures/#trafficking SMBC Nikko London: http://www.smbcnikko-cm.com/corporate/our-policies/slavery- trafficking.html,0,0,0,0,0,0,0,0,0,0,0 5015,89,SMBC-LF: https://www.smbcgroup.com/americas/legal/#Slavery,0,0,0,0,0,0,0,0,0,0,0 5015,90,"Customers The credit policy of SMBC Group prohibits granting credit to certain businesses and customers, which includes those who exhibit unacceptable practices from the perspective of public order and morals",0,0,0,0,0,0,0,1,0,0,0 5015,91,"There is a prohibition on the origination of loans for certain types of businesses where human rights abuses, such as child labour is, or may, be taking place or is likely to take place",0,0,0,0,0,0,0,1,0,0,0 5015,92,"In addition, by way of example, SMBC-LF, as part of its anti-money laundering compliance responsibilities, undertakes due diligence on its customers at both the on-boarding stage and at regular periods thereafter",0,0,0,0,0,0,0,1,0,0,0 5015,93,"This due diligence includes compliance specific database searches on customers in relation to adverse news, which would identify news in connection with sanctions and human rights violations",0,0,0,0,0,0,0,1,0,0,0 5015,94,"This also includes ongoing screening in respect of customers, customer associated parties and trade finance transactions for connections to jurisdictions with human rights issues",0,0,0,0,0,0,0,1,0,0,0 5015,95,"Further, SMBC has been a signatory to the Equator Principles since 23 January 2006",0,0,0,0,0,0,0,1,0,0,0 9307,88,the Commonwealth Modern Slavery Act 2018 Guidance for Reporting Entities (Commonwealth Guidance),0,0,0,0,0,0,0,0,0,0,0 9307,89,the Walk Free Foundations Global Slavery Index 2018 (GSI 2018),0,0,0,0,0,0,0,0,0,0,0 9307,90,"Australian Council of Superannuation Investors Modern Slavery Risks, Rights & Responsibilities report 2019 (ACSI Report)",0,0,0,0,0,0,0,0,0,0,0 9307,91,Minerals Council of Australia and Pillar Twos Respecting human rights - Guidance to assist mining companies in identifying and managing modern slavery risks associated with the COVID-19 pandemic October 2020 (MCA Report); and,0,0,0,0,0,0,0,1,0,0,0 9307,92,KPMG and Australian Human Rights Commission Resources Energy and modern slavery -Practical responses for managing risk to people guide 2021 (KPMG Report),0,0,0,0,0,0,0,0,0,0,0 9307,93,"Given the nature, location and source of Stanmores procurement spend, as described above, it is considered that the overall risk of Stanmore causing, contributing to or being directly linked to modern slavery is low",0,0,0,0,0,0,1,0,0,0,0 9307,94,"However, we acknowledge that mining is a high-risk sector and therefore some risk factors for modern slavery may be present",0,0,0,0,0,0,1,0,0,0,0 9307,95,"Stanmore is committed to maintaining a high standard of supply chain management and will continue working with our suppliers to identify, address and eliminate the risk of modern slavery and human trafficking from our supply chains",0,0,0,0,0,0,0,0,0,0,0 96,23,Tier 1 suppliers are companies from which Intel makes direct purchases,0,0,0,0,0,0,0,0,0,0,0 96,24,"Suppliers include vendors who provide a.) direct parts, materials or capital, b.) services and c.) staffing",0,0,0,0,0,0,0,0,0,0,0 96,25,"Intels policies and integrated approach to preventing modern slavery draw upon internationally recognized labor and human rights standards such as the UN Universal Declaration of Human Rights, the ILO International Labor Standards, the OECD Guidelines for Multinational Enterprises, and OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas",0,0,0,0,0,0,0,1,0,0,0 96,26,These standards establish our baseline expectations as well as communicate our values and commitment to ethics and uncompromising integrity,0,0,0,0,0,0,0,1,0,0,0 96,27,Intels policies include,0,0,0,0,0,0,0,0,0,0,0 96,28,"Intel Global Human Rights Principles: Human rights are the fundamental rights, freedoms, and standards of treatment to which all people are entitled",0,0,0,0,0,0,0,0,0,0,0 96,29,"Intels Human Rights Principles, adopted in 2009, formalize our commitment to respecting human rights and embody common principles laid out in multiple frameworks, including the United Nations Guiding Principles for Business and Human Rights",0,0,0,0,0,0,0,1,0,0,0 96,30,Intel Code of Conduct: Our Code of Conduct is a vital part of our company culture that provides employees and suppliers with a clear understanding of our core values and principles,0,0,0,0,0,0,0,1,0,0,0 2757,96,"Where, following completion of that due diligence, there are unresolved red flags, and Ixom still wishes to transact with the relevant supplier, the supplier will be subject to advanced due diligence",0,0,0,0,0,0,0,0,0,0,0 2757,97,Advanced due diligence The scope of the advanced due diligence for those suppliers requiring addition due diligence will be tailored based on the nature of the unresolved red flags arising from basic due diligence,0,0,0,0,0,0,0,0,0,0,0 2757,98,Advanced due diligence must be periodically repeated if Ixom has previously had to undertake advanced modern slavery due diligence over the supplier or an affiliated company of the supplier in the previous five year period,0,0,0,0,0,0,0,0,0,0,0 2757,99,"Red flag concept Ixom has developed a due diligence criterion which, if met by a supplier, would prompt a red flag in relation to modern slavery non-compliance such as presence of illegal activity, lack of controls surrounding labour law compliance and slavery, servitude, underage labour and human trafficking avoidance or failure to return or complete Ixoms modern slavery questionnaire",0,0,0,0,0,0,0,0,0,0,0 2757,100,"If after advanced due diligence red flags still exist and have not been addressed by the supplier, lxoms Modern Slavery Policy (MSA) requires lxom to suspend its use of the supplier until such time as the supplier has resolved the red flags to lxoms satisfaction",0,0,0,0,0,0,0,0,0,0,0 2757,101,Ixom has completed modern slavery due diligence of a selection of suppliers identified as part of Ixoms modern slavery work plan,0,0,0,0,0,0,0,0,0,0,0 2757,102,Policies,0,0,0,0,0,0,0,0,0,0,0 2757,103,"Preparation and implementation of an MSA Policy, which was approved by the Ixom executive leadership team",0,0,0,0,0,0,0,0,0,0,0 5015,96,The Equator Principles are a set of guidelines developed by private financial institutions for managing environmental and social risks related to financing large-scale development projects,0,0,0,0,0,0,0,0,0,0,0 5015,97,"The Equator Principles apply to project finance transactions, project-related corporate loans and bridge loans that are intended to be refinanced to project finance or corporate loans, regardless of the country or the sector",0,0,0,0,0,0,0,0,0,0,0 5015,98,The Equator Principles are based on,0,0,0,0,0,0,0,0,0,0,0 5015,99,"the environmental and social policies and guidelines of International Finance Corporation, the private sector arm of the World Bank",0,0,0,0,0,0,0,0,0,0,0 5015,100,"These policies and guidelines cover a variety of issues such as the environmental and social impact assessment process, pollution prevention, consideration of local communities and natural resources",0,0,0,0,0,0,0,0,0,0,0 5015,101,"In accordance with the Equator Principles, SMBC has established internal environmental and social guidelines and procedures, and conducts environmental and social risk assessments, including in respect of potential adverse human rights impacts",0,0,0,0,0,0,0,1,0,0,0 5015,102,"SMBC Group commissioned an independent external party (Ernst & Young ShinNihon LLC) to review a number of transactions for the year ended 31 December 2018 regarding their compliance with the Equator Principles, including",0,0,0,0,0,0,0,0,0,1,0 5015,103,Project Finance transactions closed in 2018,0,0,0,0,0,0,0,0,0,1,0 9307,96,RISKS OF MODERN SLAVERY PRACTICES IN THE OPERATIONS AND SUPPLY CHAINS OF THE REPORTING ENTITY AND ANY ENTITIES IT OWNS OR CONTROLS We acknowledge that mining is a high-risk sector and therefore some risk factors for modern slavery may be present,0,0,0,0,0,0,1,0,0,0,0 9307,97,Stanmore Resources Limited | Modern Slavery Statement 2021 Our risk profile is summarised below,0,0,0,0,0,0,0,0,0,0,0 9307,98,"Risk profile supply chain and managed operations For the Reporting Period, the results revealed that 7% of Stanmores tier-one suppliers were profiled into the overall medium risk category",0,0,0,0,0,0,1,0,0,0,0 9307,99,No suppliers were profiled in the high-risk category,0,0,0,0,0,0,1,0,0,0,0 9307,100,TYPE OF RISK DESCRIPTION AND ANALYSIS OF RISK SECTOR/ INDUSTRY,0,0,0,0,0,0,0,0,0,0,0 9307,101,The mining sector is generally considered high risk for modern slavery as the following risk factors may be present,0,0,0,0,0,0,1,0,0,0,0 9307,102,high-risk business models such as third party contracting,0,0,0,0,0,0,0,0,0,0,0 9307,103,use of migrant and base-skill workers,0,0,0,0,0,0,0,0,0,0,0 96,31,"Most importantly, it outlines high standards for ethical conduct by which Intel employees and suppliers must conduct business",0,0,0,0,0,0,0,1,0,0,0 96,32,"Responsible Business Alliance (RBA) Code of Conduct (the RBA Code): The RBA Code is a set of social, environmental and ethical industry standards that is an integral element of our Supplier Policy",0,0,0,0,0,0,0,1,0,0,0 96,33,Intel fully supports the vision and goals of the RBA within our global operations and we require our suppliers (and their supply chain) to comply with the RBA Code,0,0,0,0,0,0,0,1,0,0,0 96,34,We embed the RBA Code across our supply chain and advocate for RBA Code enhancements to improve the lives of workers,0,0,0,0,0,0,0,1,0,0,0 96,35,2019 Intel Corporation Statement on Combating Modern Slavery 3 Trafficking in Persons Federal Government Purchasing Policy: This policy requires suppliers to comply with the U.S,0,0,0,0,0,0,0,1,0,0,0 96,36,Governments Federal Acquisition Regulation on Combating Trafficking in Persons,0,0,0,0,0,0,0,1,0,0,0 96,37,"Intels Responsible Minerals program, mineral sourcing policy, and due diligence practices address minerals originating from Conflict- Affected and High-Risk Areas (CAHRAs3) and are aligned to the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High- Risk Areas (OECD Guidance)",0,0,0,0,0,0,1,1,0,0,0 96,38,We hold our employees and suppliers to high standards,0,0,0,0,0,0,0,0,0,0,0 2757,104,"Amongst other things, the MSA Policy prohibits Ixom entities from procuring goods, services or labour from any supplier that Ixom knows or suspects, based on available information, engages in modern slavery practices or human rights abuses in connection with the provision of goods, services or labour to Ixom, unless the supplier permanently eradicates slavery practices and human rights abuses from its operations in a timely manner",0,0,0,0,0,0,0,0,0,0,0 2757,105,"The development of an escalation process for dealing with any possible breaches of the MSA Policy, including the ability to make reports via Ixoms confidential Speak Up line which exists as part of Ixoms Whistleblower Protection Policy",0,0,0,0,0,0,0,0,0,0,0 2757,106,Training,0,0,0,0,0,0,0,0,0,0,0 2757,107,"Commencement and development of a training program for employees of Ixoms Australian entities who work with suppliers and/or work in supply chains, with a focus on ensuring the training of Ixoms product managers",0,0,0,0,0,0,0,0,0,0,0 2757,108,Published Ixom entity wide communications through Ixom News and Yammer to Ixom personnel to publicise the MSA Policy and Ixoms stance on modern slavery including how to report any concerns,0,0,0,0,0,0,0,0,0,0,0 2757,109,"Response team Establishment of a modern slavery working group consisting of internal lawyers, product managers, regional business managers, procurement personnel and supply chain personnel to establish a modern slavery avoidance program and to undertake a risk assessment to identify those parts of Ixoms supply chains that carry a higher modern slavery risk",0,0,0,0,0,0,0,0,0,0,0 2757,110,The outcome of this has informed the focus areas for the relevant work plan referred to in 4.1,0,0,0,0,0,0,0,0,0,0,0 2757,111,Further actions taken,0,0,0,0,0,0,0,0,0,0,0 5015,104,Project Related Corporate Loans closed in 2018; and,0,0,0,0,0,0,0,0,0,1,0 5015,105,Finance Advisory Transactions mandated in 2018,0,0,0,0,0,0,0,0,0,1,0 5015,106,"An Independent Assurance Report was issued by Ernst & Young ShinNihon LLC on 21 August 2019, wherein no adverse finding or non-compliance had been noted",0,0,0,0,0,0,0,0,0,1,0 5015,107,"A list of the transactions reviewed and assured by Ernst & Young ShinNihon LLC (under the section Transactions Subject to the Equator Principles (SMBC)), the relevant Independent Assurance Report, as well as further information on SMBCs commitment to the Equator Principles can be found here: https://www.smfg.co.jp/english/sustainability/materiality/environment/risk/equator/",0,0,0,0,0,0,0,0,0,0,0 5015,108,SMBCs actions in connection with its supply chain Suppliers and service providers SMBC will continue to consult with its offshore branches and group entities within its operational control (including SMBC-LF) with a view to determining whether the steps taken by such entities to assess and address the risk of modern slavery practices in their supply chains are appropriate having regard to the size and nature of their businesses,0,0,0,0,0,0,0,1,0,0,0 5015,109,Certain SMBC branches and group entities (including SMBC-LF) within its operational control have frameworks in place to assess and address modern slavery risk in their supply chains and operations,0,0,0,0,0,0,0,1,0,0,0 5015,110,"Part of the consultation process with these branches and group entities, will consider whether these existing frameworks could apply to SMBCs broader operations",0,0,0,0,0,0,0,1,0,0,0 5015,111,"For example, SMBC-LF conducts screening of all new suppliers in its direct supply chain, including reviewing publicly available information, in order to identify instances that may give cause for concern in relation to slavery, human trafficking and other human rights issues and name screening on local and global sanctions lists",0,0,0,0,0,0,0,1,0,0,0 9307,104,"the short term and temporary nature of some work, including construction",0,0,0,0,0,0,0,0,0,0,0 9307,105,operations in high-risk geographies; and,0,0,0,0,0,0,0,0,0,0,0 9307,106,"complex and global supply chains, particularly with risks beyond first-tier suppliers being more challenging to identify and manage.1 The types of modern slavery practices that may be present due to these risks are human trafficking, child labour, forced or unpaid work and bonded labour.2 Our suppliers within the construction, transport and mining and quarrying sectors make up less than 20% of our total suppliers",0,0,0,0,0,0,1,0,0,0,0 9307,107,"Further, the risks of modern slavery in Stanmores operations and supply chains are mitigated by the fact that our operations are based exclusively in Australia, the vast majority of our suppliers are Australian (99% by expenditure), and we have direct oversight and procedures in place to manage modern slavery risks, as detailed further below",0,0,0,0,0,0,1,0,0,0,0 9307,108,Our direct employees are all employed by Australian entities under written contracts and subject to Australian labour laws,0,0,0,0,0,0,1,0,0,0,0 9307,109,"Therefore, despite being in the mining sector, the risk of Stanmore causing, contributing to or being directly linked to modern slavery is low",0,0,0,0,0,0,1,0,0,0,0 9307,110,GOODS AND SERVICES,0,0,0,0,0,0,0,0,0,0,0 9307,111,"Certain goods and services may have a higher prevalence of modern slavery risks because of how they are produced, provided or used.3 In the mining industry, the forms of labour, transport and procurement practices may present higher modern slavery risks, particularly where visibility over the human rights practices of contractors beyond the first tier is low.4 General operations procurement, including financial, building management, cleaning, catering and security services, which may be provided by migrant workers, low skill workers or labour-hire contractors, also present higher risks of modern slavery, such as forced labour.5 Stanmore procures the following high-risk goods and services (marked with an asterisk in the chart below)",0,0,0,0,0,1,1,0,0,0,0 96,39,"Any policy violation by an Intel employee may result in disciplinary action, including termination of employment",0,0,0,0,0,0,0,0,1,0,0 96,40,Any policy violation by a supplier may disqualify the supplier from consideration for future business up to and including termination of the suppliers relationship with Intel,0,0,0,0,0,0,0,0,1,0,0 96,41,"When required by law, Intel will file a report of violative activity to relevant government authorities",0,0,0,0,0,0,0,0,1,0,0 96,42,"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",0,0,0,0,0,0,0,1,0,0,0 96,43,We will promptly investigate allegations and pursue action to mitigate any adverse impacts,0,0,0,0,0,0,0,0,1,0,0 96,44,"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",0,0,0,0,0,0,0,1,0,0,0 96,45,"CAHRAs, as defined by OECD, are identified by the presence of armed conflict, widespread violence, or other risks of harm to people",0,0,0,0,0,0,0,0,0,0,0 96,46,"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",0,0,0,0,0,0,0,0,0,0,0 2757,112,Update of Ixoms procurement agreement templates to make modern slavery practices a ground for Ixom to terminate the agreement,0,0,0,0,0,0,0,0,0,0,0 2757,113,Further clauses refer to anti-bribery and anti- corruption practices and impose limitations on the engagement of subcontractors,0,0,0,0,0,0,0,0,0,0,0 2757,114,Modern slavery questions were added to Ixoms existing supplier desktop audit process used by its Australian and New Zealand businesses,0,0,0,0,0,0,0,0,0,0,0 2757,115,Preparation of a supplier statement and acknowledgment of Ixoms modern slavery requirements,0,0,0,0,0,0,0,0,0,0,0 2757,116,Risk of modern slavery practices,0,0,0,0,0,0,0,0,0,0,0 2757,117,"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",0,0,0,0,0,0,0,0,0,0,0 2757,118,Global estimates of modern slavery: Forced labour and forced marriage,0,0,0,0,0,0,0,0,0,0,0 2757,119,"Geneva, 2017",0,0,0,0,0,0,0,0,0,0,0 5015,112,Reviews and assessments of all of its suppliers are undertaken on an annual basis,0,0,0,0,0,0,0,1,0,0,0 5015,113,"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",0,0,0,0,0,0,0,0,1,0,0 5015,114,"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",0,0,0,0,0,0,0,1,0,0,0 5015,115,"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",0,0,0,0,0,0,0,1,0,0,0 5015,116,"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",0,0,0,0,0,0,0,1,0,0,0 5015,117,"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",0,0,0,0,0,0,0,1,0,0,0 5015,118,"Analysis is undertaken on the jurisdiction risk of the relevant counterparty having regard to its locations, operations and activities",0,0,0,0,0,0,0,1,0,0,0 5015,119,"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",0,0,0,0,0,0,0,1,0,0,0 9307,112,Building services; hospitality; tourism; catering; cleaning,0,0,0,0,0,1,1,0,0,0,0 9307,113,Clothing; footwear mainly uniforms and merchandising,0,0,0,0,0,1,1,0,0,0,0 9307,114,Financial services,0,0,0,0,0,1,1,0,0,0,0 9307,115,Health services mainly health assessments and well-being providers These goods and services were directly sourced from companies located in Australia,0,0,0,0,0,1,1,0,0,0,0 9307,116,The total expenditure within these sectors equated to 8% of Stanmores entire annual expenditure in the Reporting Period,0,0,0,0,0,0,1,0,0,0,0 9307,117,"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",0,0,0,0,0,0,1,0,0,0,0 9307,118,This may present a medium to high risk for modern slavery as we have less control and oversight over the indirect supply chain,0,0,0,0,0,0,1,0,0,0,0 9307,119,ACSI Report p23; KPMG Report p13; 2 KPMG Report p12,0,0,0,0,0,0,0,0,0,0,0 96,47,We start by setting clear expectations for suppliers2,0,0,0,0,0,0,0,1,0,0,0 96,48,"These expectations are codified in Intels Code of Conduct, Intels policies and the RBA Code (Intel Policies)",0,0,0,0,0,0,0,1,0,0,0 96,49,Risk assessment and due diligence begin during the supplier selection process,0,0,0,0,0,0,0,1,0,0,0 96,50,"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",0,0,0,0,0,0,0,1,0,0,0 96,51,"High-risk areas may include areas of political instability or repression, institutional weakness, insecurity, collapse of civil infrastructure, and widespread violence",0,0,0,0,0,0,0,0,0,0,0 96,52,Such areas are often characterized by widespread human rights abuses and violations of national or international law,0,0,0,0,0,0,0,0,0,0,0 96,53,"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",0,0,0,0,0,0,0,1,0,0,0 96,54,2019 Intel Corporation Statement on Combating Modern Slavery 4 (CSR) survey that includes questions which help us identify potential modern slavery risks,0,0,0,0,0,0,0,1,0,0,0 2757,120,http://www.ilo.org/wcmsp5/groups/public/@dgreports/@dcomm/documents/publication/wcms_575479.pdf,0,0,0,0,0,0,0,0,0,0,0 2757,121,15 2020 MODERN SLAVERY STATEMENT,0,0,0,0,0,0,0,0,0,0,0 2757,122,Assessing effectiveness 6.1 Overall assessment,0,0,0,0,0,0,0,0,0,0,0 2757,123,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,0,0,0,0,0,0,0,0,0,0,0 2757,124,"These groups met regularly, and awareness of modern slavery risks increased",0,0,0,0,0,0,0,0,0,0,0 2757,125,An annual review of the effectiveness of the work plan was conducted by Ixoms internal legal team,0,0,0,0,0,0,0,0,0,1,0 2757,126,Ixom measured its progress by tracking suppliers who were targeted for due diligence on a case by case basis during the reporting period,0,0,0,0,0,0,0,0,0,1,0 2757,127,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,0,0,0,0,0,0,0,0,0,1,0 5015,120,"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",0,0,0,0,0,0,0,1,0,0,0 5015,121,"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",0,0,0,0,0,0,0,1,0,0,0 5015,122,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,0,0,0,0,0,0,0,1,0,0,0 5015,123,"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",0,0,0,0,0,0,0,1,0,0,0 5015,124,"The three areas of focus include the Japanese Anti-Social Forces Screening, Anti-Bribery and Corruption Due Diligence and Modern Slavery Due Diligence",0,0,0,0,0,0,0,1,0,0,0 5015,125,"Additionally, in FY2019, in Japan, SMBC expanded the scope of its outsourcing policy to apply to service providers, vendors and certain other suppliers",0,0,0,0,0,0,0,1,0,0,0 5015,126,"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",0,0,0,0,0,0,0,0,0,1,0 5015,127,"Consistent with the assessment of other SMBC policies, effectiveness will be determined on an assessment as to",0,0,0,0,0,0,0,0,0,1,0 9307,120,Commonwealth Guidance p44,0,0,0,0,0,0,0,0,0,0,0 9307,121,KPMG Report p14,0,0,0,0,0,0,0,0,0,0,0 9307,122,"ACSI Report; KMPG Report p14, 17",0,0,0,0,0,0,0,0,0,0,0 9307,123,Stanmore Resources Limited | Modern Slavery Statement 2021 TYPE OF RISK DESCRIPTION AND ANALYSIS OF RISK GEOGRAPHIC,0,0,0,0,0,0,0,0,0,0,0 9307,124,"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",0,0,0,0,0,1,1,0,0,0,0 9307,125,Singapore from which we source professional services ranks 97/167,0,0,0,0,0,1,1,0,0,0,0 9307,126,Brazil from which we source engineering services ranks 142/167,0,0,0,0,0,1,1,0,0,0,0 9307,127,"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",0,0,0,0,0,1,1,0,0,0,0 96,55,"If selected, a contract is put in place that requires suppliers to strictly comply with Intel Policies",0,0,0,0,0,0,0,1,0,0,0 96,56,"Additionally, we send out an annual letter to suppliers reminding them of their legal obligations to comply with Intel Policies",0,0,0,0,0,0,0,0,0,1,0 96,57,"We conduct an annual assessment of critical suppliers4 using a comprehensive self- assessment questionnaire that includes questions related to recruitment, onboarding, and staffing",0,0,0,0,0,0,0,1,0,0,0 96,58,"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",0,0,0,0,0,0,0,0,0,1,0 96,59,"When combined with location and sector information, we determine which suppliers are higher risk",0,0,0,0,0,0,0,1,0,0,0 96,60,"We will then either ask them to complete an additional questionnaire, audit them, or take additional corrective action",0,0,0,0,0,0,0,1,0,0,0 96,61,"We regularly meet with Intels procurement leaders to discuss and review supplier performance, including any modern slavery issues that may have been identified",0,0,0,0,0,0,0,0,0,1,0 96,62,"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",0,0,0,0,0,0,0,0,0,1,0 2757,128,Ixom has started increasing awareness of modern slavery risks amongst its employees by communications and training,0,0,0,0,0,0,0,1,0,0,0 2757,129,"As a result of Ixom employee awareness on modern slavery the modern slavery avoidance, legal and compliance inboxes are being effectively used",0,0,0,0,0,0,0,0,0,0,0 2757,130,"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",0,0,0,0,0,0,0,1,0,0,0 2757,131,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,0,0,0,0,0,0,0,0,0,0,0 2757,132,Assessing effectiveness 14,0,0,0,0,0,0,0,0,0,0,0 2757,133,17 2020 MODERN SLAVERY STATEMENT,0,0,0,0,0,0,0,0,0,0,0 2757,134,Consultation with Ixom entities and approvals Ixoms MSA Policy applies to all Reporting Entities and their wholly owned members,0,0,0,0,0,0,0,0,0,0,0 2757,135,Ixom has made available the MSA Policy to personnel in all wholly owned members of Ixom,0,0,0,0,0,0,0,0,0,0,0 5015,128,Modern slavery has been introduced in the SMBC Group global compliance risk assessment framework,0,0,0,0,0,0,0,0,0,0,0 5015,129,Consistent with the SMBC Group global compliance risk assessment program effectiveness is determined on an assessment as to,0,0,0,0,0,0,0,0,0,1,0 5015,130,appropriate design of relevant policies and procedures to ensure compliance and risk management,0,0,0,0,0,0,0,0,0,0,0 5015,131,"how well the control processes have operated, including timeliness and comprehensiveness",0,0,0,0,0,0,0,0,0,0,0 5015,132,the extent of employee training that has been conducted,0,0,0,0,0,0,0,0,0,0,0 5015,133,the outcomes from monitoring and validation procedures; and,0,0,0,0,0,0,0,0,0,0,0 5015,134,the timeliness of remedial action taken for any issues arising,0,0,0,0,0,0,0,0,0,0,0 5015,135,Enhancements may be made as considered necessary as a result of these assessments,0,0,0,0,0,0,0,0,0,1,0 9307,128,"The vast majority of our goods and services are procured in Australia, which is a low-risk country according to the GSI 2018",0,0,0,0,0,0,1,0,0,0,0 9307,129,COVID 19 RISKS,0,0,0,0,0,0,0,0,0,0,0 9307,130,"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",0,0,0,0,0,0,1,0,0,0,0 9307,131,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,0,0,0,0,0,0,1,0,0,0,0 9307,132,Commonwealth Guidance p 44,0,0,0,0,0,0,0,0,0,0,0 9307,133,MCA Report p4-5,0,0,0,0,0,0,0,0,0,0,0 9307,134,Risk profile non-managed operations The Stanmore Group owns a 50% non-operating interest in the Millennium and Mavis Downs Joint Venture,0,0,0,0,1,0,0,0,0,0,0 9307,135,This JV is operated by M Mining Pty Ltd,0,0,0,0,0,0,1,0,0,0,0 96,63,"We refer to a number of external sources, including the US Department of State Trafficking in Persons Report (TIP Report), the U.S",0,0,0,0,0,0,0,0,0,1,0 96,64,"Department of Labors List of Goods Produced by Child Labor or Forced Labor, the U.S",0,0,0,0,0,0,0,0,0,1,0 96,65,"Department of States Responsible Sourcing Tool, and publications from reputable organizations, to stay informed",0,0,0,0,0,0,0,0,0,1,0 96,66,These sources help us identify higher-risk countries and sectors in our supply chain,0,0,0,0,0,0,0,0,0,0,0 96,67,Critical suppliers represent a subset of Tier 1 or direct suppliers that we have significant business relationship and spends,0,0,0,0,0,0,0,0,0,0,0 96,68,"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",0,0,0,0,0,1,0,0,0,0,0 96,69,"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",0,0,0,0,0,0,0,0,0,1,0 96,70,"Using this framework, in 2019 we increased our focus in three areas: Japan, South Korea and the construction sector",0,0,0,0,0,0,0,1,0,0,0 2757,136,"Ixoms consultation process included engagement with personnel across Ixom to confirm alignment of policies, systems and processes across its businesses",0,0,0,0,0,0,0,0,0,0,1 2757,137,This Statement was endorsed and approved by the principal governing bodies of the following,1,0,0,0,0,0,0,0,0,0,0 2757,138,"IX Infrastructure Pty Ltd on behalf of that company, Ixom Holdco Pty Ltd and Ixom Pty Ltd; and",1,0,0,0,0,0,0,0,0,0,0 2757,139,"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",1,1,0,0,0,0,0,0,0,0,0 2757,140,Consultation with Ixom entities and approvals,0,0,0,0,0,0,0,0,0,0,0 2757,141,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,0,0,0,1,0,0,0,0,0,0,0 2757,142,"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",0,0,0,1,0,0,0,0,0,0,0 2757,143,18 Annexure A Corporate Structure Key Australian entities New Zealand entities Ownership Foreign entities,0,0,0,0,0,0,0,0,0,0,0 5015,136,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,0,0,0,0,0,0,0,0,0,0,1 5015,137,"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",0,0,0,0,0,0,0,0,0,0,1 5015,138,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,1,1,0,0,0,0,0,0,0,0,0 5015,139,"Perry, President of SMBC-LF",1,1,0,0,0,0,0,0,0,0,0 5015,140,______________________________________________ Stephen R,0,1,0,0,0,0,0,0,0,0,0 5015,141,"Perry President, SMBC Leasing and Finance, Inc",0,1,0,0,0,0,0,0,0,0,0 5137,0,132 312 515 ORDERS: 1300 65 88 22 FAX ORDERS: 1300 65 88 10 TEETH ORDERS: 1300 65 88 11 www.henryschein.com.au,0,0,0,0,0,0,0,0,0,0,0 5137,1,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),0,0,0,0,0,0,0,0,0,0,0 9307,136,Stanmore considers that the risk of modern slavery within the JV is similar to that within the Stanmore Group,0,0,0,0,0,0,1,0,0,0,0 9307,137,10 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,0,0,0,0,0,0,0,0,0,0,0 9307,138,Stanmore Resources Limited | Modern Slavery Statement 2021,0,0,0,0,0,0,0,0,0,0,0 9307,139,"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",0,0,0,0,0,0,0,0,0,0,0 9307,140,Governance Stanmore is committed to further enhancing governance and empowering management to address the risks of modern slavery in our operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 9307,141,A Modern Slavery Working Group was established in 2020 to help with future development training programs for employees and establish risk assessments,0,0,0,0,0,0,0,1,0,0,0 9307,142,"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)",0,0,0,0,0,0,0,1,0,0,0 9307,143,The key consideration for the Working Group was the impact of modern slavery risks on purchasing activities,0,0,0,0,0,0,0,1,0,0,0 96,71,"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",0,0,0,0,0,0,1,0,0,0,0 96,72,"Similarly, we learned South Korea has a comparable program where job seekers pay fees",0,0,0,0,0,0,1,0,0,0,0 96,73,In both cases weve taken steps to ensure these practices are not used by Intel suppliers,0,0,0,0,0,0,0,0,1,0,0 96,74,"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",0,0,0,0,0,0,1,1,0,0,0 96,75,"To help us understand and address those challenges, weve continued our multi-year innovative project for supplier accountability",0,0,0,0,0,0,0,1,0,0,0 96,76,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,0,0,0,0,0,0,0,1,0,0,0 96,77,"As an alternative, critical suppliers could instead conduct a full RBA audit of the three selected suppliers; reaching about 135 Tier 2 suppliers",0,0,0,0,0,0,0,1,0,0,0 96,78,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,0,0,0,0,0,0,0,0,0,1,0 2757,144,"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",0,0,0,0,0,0,0,0,0,0,0 2824,0,Our Modern Slavery Statement The super fund for Australias higher education and research sector FOR THE 2019-20 FINANCIAL YEAR,0,0,0,0,0,0,0,0,0,0,0 2824,1,"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",0,0,0,1,0,0,0,0,0,0,0 2824,2,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 2021,1,0,0,0,0,0,0,0,0,0,0 2824,3,"The registered office for both USL and USM is Level 1, 385 Bourke Street, Melbourne, Victoria 3000",0,0,0,1,0,0,0,0,0,0,0 2824,4,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,0,0,1,0,0,0,0,0,0,0,0 2824,5,"As the Fund takes modern slavery seriously, it chooses to prepare a Statement even where it is not a reporting entity under the Act",0,0,0,0,0,0,0,0,0,0,0 2824,6,"Except where the context otherwise requires, the Fund, USL and USM are referred to throughout the Statement as, UniSuper, we, us or our",0,0,0,0,0,0,0,0,0,0,0 5137,2,"What is modern slavery? The term ""modern slavery"" describes situations in which coercion, threats or deception are used to exploit victims and undermine their freedom",0,0,0,0,0,0,0,0,0,0,0 5137,3,"Modern slavery takes many forms including slavery, servitude, forced labour, debt bondage, deceptive recruiting for labour or services, the worst forms of child labour (where children are exploited through slavery like practices or exposed to hazardous work) and forced marriage",0,0,0,0,0,0,0,0,0,0,0 5137,4,Reporting entity For the purposes of this Modern Slavery Statement the reporting entity is The Henry Schein Regional Trust (ABN: 83 132 312 515) (Henry Schein),0,0,1,0,0,0,0,0,0,0,0 5137,5,This Modern Slavery Statement covers Henry Schein's reporting period of 1 January 2020 to 31 December 2020,0,0,0,0,0,0,0,0,0,0,0 5137,6,"Our values and commitments Henry Schein respects human rights as recognised by the principles set out in the United Nations Universal Declaration of Human Rights, the International Covenant on Economic Social and Cultural Rights, the International Covenant on Civil and Political Rights and the core labour standards set out in the International Labour Organisations Declaration on Fundamental Principles and Rights at Work",0,0,0,0,0,0,0,0,0,0,0 5137,7,Henry Schein is committed to operating our business lawfully and ethically and is committed to only working with manufacturers and suppliers that are aligned to our values,0,0,0,0,0,0,0,0,0,0,0 5137,8,We expect everyone in our supply chains to operate in accordance with all applicable modern slavery laws,0,0,0,0,0,0,0,1,0,0,0 5137,9,"We value and observe all laws regarding corporate social responsibility, environmental protection, workplace safety, staff inclusion and diversity",0,0,0,0,0,0,0,0,0,0,0 9307,144,Stanmores Audit and Risk Management Committee (ARMC) is responsible for assisting the Board with the risk of modern slavery in our operations and supply chains,0,0,0,0,0,0,0,1,0,0,0 9307,145,"During the Reporting Period, the ARMC recommended to the Board that Stanmores exposure to modern slavery risks would significantly increase as a result of the SMC acquisition due to direct interactions with many additional contractors and suppliers",0,0,0,0,0,0,0,1,0,0,0 9307,146,"In response, the Board resolved that the ARMC develop and implement a programme to ensure compliance with modern slavery requirements post-acquisition of SMC (in 2022)",0,0,0,0,0,0,0,1,0,0,0 9307,147,Modern Slavery Compliance and Action Plan We developed a Modern Slavery Compliance and Action Plan for modern slavery compliance to focus and prioritise our actions for this current Reporting Period and future reporting periods,0,0,0,0,0,0,0,1,0,0,0 9307,148,"As a result of the SMC acquisition and taking on the day- to-day operations of those assets, Stanmores exposure to modern slavery risk will significantly increase",0,0,0,0,0,0,1,0,0,0,0 9307,149,Systems to manage these risks will need to be developed and implemented,0,0,0,0,0,0,0,0,0,0,0 9307,150,We will report on the programme in our next statement,0,0,0,0,0,0,0,0,0,0,0 9307,151,Modern Slavery Policy We developed a Modern Slavery Policy for our business that establishes our commitment to addressing modern slavery risks in our business and driving accountability for ethical business practices across our operations,0,0,0,0,0,0,0,1,0,0,0 96,79,2019 Intel Corporation Statement on Combating Modern Slavery 5 recruiting agents,0,0,0,0,0,0,0,0,0,1,0 96,80,We expect completion of this project by the end of 2020,0,0,0,0,0,0,0,0,0,1,0 96,81,"In addition to these results, we have also engaged more than 25 Tier 2 and Tier 37 construction subcontractors (see Spotlight on Intel Supplier Audits section)",0,0,0,0,0,0,0,0,0,1,0 96,82,Audits and Assessment of Effectiveness We view audits as an integral part of our overall risk management process,0,0,0,0,0,0,0,1,0,0,0 96,83,"They help us identify risks and compliance gaps, determine where immediate action is needed, and ascertain the root causes that enable development of systemic solutions and improvements",0,0,0,0,0,0,0,1,0,0,0 96,84,"Audits are generally announced; however, we occasionally conduct unannounced audits when necessary",0,0,0,0,0,0,0,1,0,0,0 96,85,"At higher risk supplier facilities, we manage audits on a periodic basis",0,0,0,0,0,0,0,1,0,0,0 96,86,"To look deeper into our supply chain, we also audit higher risk Tier 2 suppliers or require our suppliers to audit them",0,0,0,0,0,0,0,1,0,0,0 2824,7,"Contents Introduction 2 Our structure, operations and supply chains 3 Risks of modern slavery practices 4 Our actions to assess and address the risks 5 How we assess the effectiveness of our actions 9 Our consultation process 10 Appendix 11 Identifying our modern slavery risks",0,0,0,0,0,0,0,0,0,0,0 2824,8,"Introduction The Modern Slavery Act 2018 requires certain businesses and entities who meet a revenue threshold (annual consolidated revenue of more than $100 million) to report on the risks of modern slavery in their operations and supply chains and the entities they own or control, the actions theyve taken to address those risks, and how theyve assessed the effectiveness of those actions",0,0,0,0,0,0,0,0,0,0,0 2824,9,UniSuper supports the Act and believes every person has the right to freedom and to be safe and respected in their day-to-day lives,0,0,0,0,0,0,0,0,0,0,0 2824,10,"The Act defines modern slavery to include eight types of serious exploitation trafficking in persons, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruiting for labour or services and the worst forms of child labour (situations where children are subjected to slavery or similar practices, or engaged in hazardous work)",0,0,0,0,0,0,0,0,0,0,0 2824,11,"Consistent with the expectations set out in the United Nations Guiding Principles on Business and Human Rights, the Australian Council of Superannuation Investors and Responsible Investment Association Australasias joint Modern Slavery Reporting Guide for Investors (November 2019) and the Australian Border Forces Commonwealth Modern Slavery Act Guidance for Reporting Entities, UniSuper recognises the importance of taking meaningful steps to identify and respond to modern slavery risks",0,0,0,0,0,0,0,0,0,0,0 2824,12,"Forced labour and related practices exist in the operations or supply chains of most businesses in every region of the world, including Australia",0,0,0,0,0,0,0,0,0,0,0 2824,13,Were deeply committed to upholding human rights across our internal operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 2824,14,Weve undertaken a long-term commitment to understand our labour supply chain risks and improve the management of these risks,0,0,0,0,0,0,0,0,0,0,0 5137,10,"Consistent with this the Henry Schein Group was recognised by Ethisphere, a global leader in defining and advancing the standards of ethical business practices, as one of the Worlds Most Ethical Companies in 2020",0,0,0,0,0,0,0,0,0,0,0 5137,11,These values and commitments are reflected in our global Mission Statement and Corporate Charter and (in relation to our supply chains specifically) in our global Supply Chain Resilience Statement in which we make clear that we support the UN Guiding Principles for Business and Human Rights and also support and comply with various existing and emerging supply chain transparency laws,0,0,0,0,0,0,0,0,0,0,0 5137,12,132 312 515 ORDERS: 1300 65 88 22 FAX ORDERS: 1300 65 88 10 TEETH ORDERS: 1300 65 88 11 www.henryschein.com.au,0,0,0,0,0,0,0,0,0,0,0 5137,13,"We are committed to ongoing engagement with our suppliers, manufacturers and stakeholders to better collaborate in assessing and addressing modern slavery risks",0,0,0,0,0,0,0,1,0,0,0 5137,14,We are also committed to undertaking work to identify and take steps to prevent modern slavery,0,0,0,0,0,0,0,0,0,0,0 5137,15,"Our structure, operations and supply chains Structure Henry Schein is a fixed unit trust, registered in New South Wales",0,0,0,1,0,0,0,0,0,0,0 5137,16,The trustee of this trust is Henry Schein Regional Pty Limited (ACN: 003 770 321),0,0,0,1,0,0,0,0,0,0,0 5137,17,"Henry Schein owns or controls two entities - Pacific Dental Specialties Pty Ltd (ABN: 37 132 562 906) and the Adaam Unit Trust (ABN 50 744 976 150), the latter of which trades as ""Adam Dental Supplies",0,0,0,1,0,0,0,0,0,0,0 9307,152,A draft Modern Slavery Policy was put to the Board for approval in 2021 and will be implemented in 2022,0,0,0,0,0,0,0,0,0,0,0 9307,153,Policy review Stanmore is committed to maintaining high standards in all aspects of reporting and corporate governance,0,0,0,0,0,0,0,0,0,0,0 9307,154,"Stanmores commitment to good governance practices, operating ethically and with integrity, is guided by our policies available to all internal and external stakeholders on our website (www.stanmore.net.au)",0,0,0,0,0,0,0,0,0,0,0 9307,155,"Stanmores approach to corporate governance is explained more fully in the Corporate Governance Statement, available from Corporate Governance | Stanmore Resources",0,0,0,0,0,0,0,0,0,0,0 9307,156,"Stanmore Resources Limited | Modern Slavery Statement 2021 Stanmores Corporate Governance Charter includes a Code of Conduct that sets out the standards that the Board, management, and employees of Stanmore must comply with when dealing with each other, shareholders, and the broader community",0,0,0,0,0,0,0,1,0,0,0 9307,157,"This required conduct extends to dealings with our business partners, customers and suppliers, who must demonstrate similar ethical and responsible business practices",0,0,0,0,0,0,0,1,0,0,0 9307,158,"During the Reporting Period, we updated our Code of Conduct to make a specific commitment to ensure that Stanmore and its contractors do not engage in modern slavery or child, forced or illegal labour",0,0,0,0,0,0,0,1,0,0,0 9307,159,"Stanmore has a Whistleblower Policy, which sets out the procedures and mechanisms for employees and third parties to anonymously report suspected or actual misconduct and illegal activity or breaches of Stanmore policies",0,0,0,0,0,0,0,1,0,0,0 96,87,We hold ourselves accountable to meet or exceed the same standards that we set for our suppliers and have the RBA conduct Validated Assessment Program (VAP) audits of our 7 Tier 3 suppliers are companies from which Intel's Tier 2 suppliers make direct purchases finished goods factories,0,0,0,0,0,0,0,1,0,0,0 96,88,"In 2020, we plan to have an RBA VAP audit of our facility in Chengdu, China",0,0,0,0,0,0,0,0,0,1,0 96,89,"Since 2017, we have assessed facilities representing at least 750,000 workers",0,0,0,0,0,0,0,0,0,1,0 96,90,Higher- risk suppliers undergo on-site audits and/or capability assessments that may use the full RBA Code or a portion of it depending on suppliers risk profile and specific compliance concerns,0,0,0,0,0,0,0,1,0,0,0 96,91,"These audits are performed by qualified, independent, third-party auditors or similarly qualified Intel auditors",0,0,0,0,0,0,0,1,0,0,0 96,92,Audits include worker interviews and document reviews,0,0,0,0,0,0,0,1,0,1,0 96,93,"Auditors meet and speak directly to workers before and during audits to detect any non-conformance by suppliers, as well as afterwards to ensure documents and monies were returned, contracts were corrected, and living conditions improved",0,0,0,0,0,0,0,1,0,1,0 96,94,"As part of an audit, our Intel forced labor lead auditors provide their business card to the workers they interview",0,0,0,0,0,0,0,1,0,0,0 2824,15,This is our first statement under the Act,0,0,0,0,0,0,0,0,0,0,0 2824,16,"Its purpose is to describe the activities weve undertaken throughout the 2019-20 financial year, and to identify, assess and address the risks of modern slavery in our internal operations and supply chains",0,0,0,0,0,0,0,0,0,0,0 2824,17,"Specifically, in providing the Statement, weve",0,0,0,0,0,0,0,0,0,0,0 2824,18,"described our structure, internal operations and supply chains (see page 3)",0,0,0,0,0,0,0,0,0,0,0 2824,19,identified the risks of modern slavery practices in our internal operations and supply chains (see page 4),0,0,0,0,0,0,0,0,0,0,0 2824,20,taken action to assess and address those risks and mapped out some of our intended actions for the future (see page 5),0,0,0,0,0,0,0,0,0,0,0 2824,21,"assessed the effectiveness of our actions (see page 9), and",0,0,0,0,0,0,0,0,0,0,0 2824,22,described the process of consultation weve engaged in within UniSuper (see page 10),0,0,0,0,0,0,0,0,0,0,0 5137,18,The operations of these entities are the same as those of Henry Schein,0,0,0,0,1,0,0,0,0,0,0 5137,19,"Henry Schein, its trustee and two other Australian Henry Schein entities (Henry Schein Australia Pty Limited - a non trading entity - and Henry Schein Australia Holdings Pty Limited - the holding company of the Australian group of Henry Schein entities) are wholly owned by Henry Schein Inc, a Fortune 500 company, a member of the S&P 500 and NASDAQ 100 Indices and the leading distributor of healthcare products and services primarily to office-based healthcare practitioners in the combined North American and European markets",0,0,0,1,1,0,0,0,0,0,0 5137,20,"Operations Henry Schein is Australias largest dental distributor, stocking a wide range of dental products and equipment including dental chairs, sterilisation instruments, consumable items (such as gloves, tissues and masks), 3D cone beam CT scanning equipment and integrated CAD/CAM solutions",0,0,0,0,1,0,0,0,0,0,0 5137,21,"In Australia, Henry Schein has over 340 employees",0,0,0,1,0,0,0,0,0,0,0 5137,22,"Our head office is in Mascot, New South Wales and we have state offices located in each capital city",0,0,0,1,1,0,0,0,0,0,0 5137,23,"Henry Schein operates distribution centres in Sydney, Perth and Auckland",0,0,0,0,1,0,0,0,0,0,0 5137,24,Supply Chains Henry Schein partners with approximately 280 suppliers and third party manufacturers,0,0,0,0,0,1,0,0,0,0,0 5137,25,Our complex supply chains include the purchase of therapeutic and non-therapeutic products and services needed for the day-to-day operation of the business,0,0,0,0,0,1,0,0,0,0,0 9307,160,An externally managed independent whistleblower service is accessible to employees and third parties with material incidents being disclosed to the Board,0,0,0,0,0,0,0,1,0,0,0 9307,161,"Training Given our central management structure and small employee base, we targeted modern slavery briefings at the Board and ARMC levels, and within the Working Group to create awareness of the issue of modern slavery and the key risks for Stanmore",0,0,0,0,0,0,0,1,0,0,0 9307,162,The SMC acquisition will result in an expanded and diversified workforce and an increased risk profile occasioning a more systematic and comprehensive training program,0,0,0,0,0,0,1,1,0,0,0 9307,163,"Risk assessment Stanmore has identified the modern slavery risk within our supply chain by undertaking desktop research to identify any key modern slavery risks that existed within our supply chains, profiling our tier-one supply base",0,0,0,0,0,0,0,1,0,0,0 9307,164,"Supplier engagement As part of engaging with suppliers and using Stanmores influence to mitigate the risk of modern slavery in the supply chain, we developed new contract clauses, which require our suppliers, service providers and customers to comply with relevant Stanmore policies and procedures, including warranting that they do not have modern slavery and human trafficking in their operations or supply chain",0,0,0,0,0,1,0,1,0,0,0 9307,165,Suppliers are also required to address modern slavery risks and compliance with the Act,0,0,0,0,0,0,0,1,0,0,0 9307,166,The new contract clauses were implemented across all new contracts post-May 2021 with suppliers via Stanmores updated suite of standard form contracts and purchase orders,0,0,0,0,0,0,0,1,0,0,0 9307,167,Anti-slavery requirements were negotiated for the new mining services contract for Isaac Plains Complex (formally signed in 2022),0,0,0,0,0,0,0,1,0,0,0 96,95,The auditors inform the workers that they can contact Intel safely and directly,0,0,0,0,0,0,0,1,0,0,0 96,96,Each year 1-2 workers contact us outside of the audit over email,0,0,0,0,0,0,0,0,0,1,0 96,97,"In these cases, we follow up and check on the status of the workers",0,0,0,0,0,0,0,0,0,1,0 96,98,Spotlight on Supplier Audits and Impact In 2019 we created a special contract addendum to address the risks of forced labor in construction subcontracting where foreign and migrant workers are present,0,0,0,0,0,0,0,1,0,0,0 96,99,It was piloted with a large general contractor to cascade to their numerous sub-contractors who we then audited,0,0,0,0,0,0,0,0,0,1,0 96,100,Through on-site audits we verified that the general contractor did waterfall these additional contractual expectations to their sub-contractors,0,0,0,0,0,0,0,0,0,1,0 96,101,"After the successful pilot, Intel led onsite audits of 25 Tier 2 and Tier 3 suppliers that included interviews with the foreign workers as well as visits to living accommodations when they were provided",0,0,0,0,0,0,0,1,0,0,0 96,102,Our audits resulted in numerous findings all of which have since been addressed,0,0,0,0,0,0,0,0,1,0,0 2824,23,We acknowledge modern slavery risk reporting in Australia is relatively new,0,0,0,0,0,0,0,0,0,0,0 2824,24,We expect our statements will evolve and demonstrate progress over time,0,0,0,0,0,0,0,0,0,0,0 2824,25,Well strive for further insights into modern slavery risks so we can,0,0,0,0,0,0,0,0,0,0,0 2824,26,continue to strengthen and refine our response to future reporting cycles,0,0,0,0,0,0,0,0,0,0,0 2824,27,better understand and improve our processes for identifying and managing modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 2824,28,"improve awareness of modern slavery among employees and key business partners, and",0,0,0,0,0,0,0,0,0,0,0 2824,29,"anticipate the evolving nature of modern slavery risks and our responsibility to respect human rights, including during times of uncertainty and challenge",0,0,0,0,0,0,0,0,0,0,0 2824,30,630 692 UNISUPER.COM.AU Signed by: Kevin OSullivan Chief Executive Officer UniSuper Management Pty Ltd Ian Martin Chairman UniSuper Limited,0,1,0,0,0,0,0,0,0,0,0 5137,26,"The non-therapeutic products and services include office supplies, logistics, building services and maintenance, IT and telecommunications infrastructure and support services and a range of professional services",0,0,0,0,0,1,0,0,0,0,0 5137,27,"Our Purchasing, Marketing, Warehousing, Finance & Administration, IT and HR/People & Culture teams have various policies in place that support our day-to-day operations to ensure all staff and suppliers meet Henry Scheins core values",0,0,0,0,0,0,0,0,0,0,0 5137,28,"We are committed to sourcing top quality dental therapeutics, equipment and instrumentation along with involved services through a resilient global and local network",0,0,0,0,0,0,0,0,0,0,0 5137,29,We rely on positive and,0,0,0,0,0,0,0,0,0,0,0 5137,30,132 312 515 ORDERS: 1300 65 88 22 FAX ORDERS: 1300 65 88 10 TEETH ORDERS: 1300 65 88 11 www.henryschein.com.au,0,0,0,0,0,0,0,0,0,0,0 5137,31,open relationships with our suppliers and manufacturers so we can continue to monitor and enhance our practices,0,0,0,0,0,0,0,0,0,0,0 5137,32,Over the relevant reporting period Henry Schein spent approximately AUD $180 million on products and services from our suppliers and third party manufacturers,0,0,0,0,0,1,0,0,0,0,0 5137,33,The main area of supplier spend was on consumable items for resale,0,0,0,0,0,1,0,0,0,0,0 9307,168,"In addition, we reviewed our existing key contracts and negotiated amendments to include anti-slavery and anti-corruption requirements where necessary",0,0,0,0,0,0,0,1,0,0,0 9307,169,Future actions Stanmore recognises that combating modern slavery is a continuous commitment,0,0,0,0,0,0,0,0,0,0,0 9307,170,In 2022 we will look to,0,0,0,0,0,0,0,1,0,0,0 9307,171,implement our new Modern Slavery Policy,0,0,0,0,0,0,0,0,0,0,0 9307,172,further develop our modern slavery framework to ensure we have robust systems and procedures in place to identify and address the risk of modern slavery in our business operations and supply chains,0,0,0,0,0,0,0,1,0,0,0 9307,173,This will include developing,0,0,0,0,0,0,0,1,0,0,0 9307,174,"an onboarding process for suppliers, including a supplier questionnaire regarding modern slavery risks and compliance; and",0,0,0,0,0,0,0,1,0,0,0 9307,175,a management and remediation program to respond to modern slavery risks and incidents safely and appropriately,0,0,0,0,0,0,0,0,0,0,0 96,103,"Our diligence continues to positively impact workers throughout the supply chain, having returned approximately $15 million in fees to more than 13,100 workers since 2014",0,0,0,0,0,0,0,0,0,1,0 96,104,"Since that time, new rigorous practices and policies also help ensure fee collection does not easily recur",0,0,0,0,0,0,0,0,0,1,0 96,105,"To date, we have improved the lives of approximately 38,000 workers through fee repayments, returned passports, amended contracts, and other improvements related to anti-slavery and human trafficking",0,0,0,0,0,0,0,0,0,1,0 96,106,"2019 Intel Corporation Statement on Combating Modern Slavery 6 If a supplier provides housing to workers, we consider them higher risk and are more likely to audit them",0,0,0,0,0,0,1,1,0,0,0 96,107,"In 2019, over 150 on-site RBA VAP and Intel led audits were conducted using the current RBA VAP Operations Manual to verify compliance to the RBA Code",0,0,0,0,0,0,0,0,0,1,0 96,108,This represented approximately 35% of our critical suppliers,0,0,0,0,0,0,0,0,0,1,0 96,109,"Suppliers are required to draft comprehensive corrective action plans (CAPs) to address audit findings, and we work closely with them to document actions taken to remedy those findings",0,0,0,0,0,0,0,0,1,0,0 96,110,We then monitor their progress until the issues are resolved,0,0,0,0,0,0,0,0,1,0,0 2824,31,"Our structure, operations and supply chains Structure USL is the incorporated trustee of the Fund",0,0,0,1,0,0,0,0,0,0,0 2824,32,It is the sole shareholder of USM in its capacity as trustee of the Fund and beneficially holds these shares on behalf of the members of the Fund,0,0,0,1,0,0,0,0,0,0,0 2824,33,USL also owns or controls a number of entities whose sole purpose is to hold particular investments of the Fund,0,0,0,1,0,0,0,0,0,0,0 2824,34,"Most of these entities have the same registered office as USL, a few have a registered office elsewhere in Australia and one has a registered office in New Zealand",0,0,0,1,0,0,0,0,0,0,0 2824,35,No people are employed by any of these entities,0,0,0,1,0,0,0,0,0,0,0 2824,36,USM provides administration and investment management services to USL,0,0,0,0,1,0,0,0,0,0,0 2824,37,USM also operates UniSuper Advice,0,0,0,0,1,0,0,0,0,0,0 2824,38,UniSuper Advice is licensed to deal in financial products and provide financial advice,0,0,0,0,1,0,0,0,0,0,0 5137,34,Risk of modern slavery practices in our operations and supply chains and in the operations and supply chains of the entities which we own or control Henry Schein recognises that the nature of its business means that it might be exposed to instances of modern slavery in its supply chains,0,0,0,0,0,0,1,0,0,0,0 5137,35,We sought guidance on how to identify risks of modern slavery in our operations and supply chains from publicly available resources to develop an understanding of our potential risk areas,0,0,0,0,0,0,0,1,0,0,0 5137,36,"While conducting our initial analysis we referred to resources such as the Global Slavery Index 2018, the Commonwealth Modern Slavery Act 2018 Guidance for Reporting Entities and materials and information on risks of modern slavery produced by the International Labour Organisation",0,0,0,0,0,0,0,1,0,0,0 5137,37,"We considered relevant risks of modern slavery practices by reference to a range of intersecting factors such as business activities, labour force structure, sector and social, political and environmental conditions in the countries in which our suppliers and manufacturers operate",0,0,0,0,0,0,0,1,0,0,0 5137,38,"Operations We procure services such as building services, cleaning, travel, security and maintenance services",0,0,0,0,0,1,0,0,0,0,0 5137,39,"Although Henry Schein recognises that these are potential high risk areas, the majority of such services are from reputable Australian based operators who comply with all applicable Australian laws",0,0,0,0,0,0,1,0,0,0,0 5137,40,Henry Schein seeks to ensure that the values and ethics of these contractors reflect those of our organisation wherever possible,0,0,0,0,0,0,0,0,0,0,0 5137,41,We partner with recruitment agencies who assist us by sourcing staff for our warehousing and distribution centres,0,0,0,0,0,1,1,0,0,0,0 9307,176,undertake due diligence activities to understand the modern slavery risks associated with our joint venture acquisition and incorporate SMC into Stanmores modern slavery framework,0,0,0,0,0,0,0,1,0,0,0 9307,177,undertake supply chain risk mapping to understand modern slavery risks across our expanded tier-one supplier base; and,0,0,0,0,0,0,0,0,0,0,0 9307,178,"expand training across Stanmore, including for senior leaders and those involved in procurement decisions",0,0,0,0,0,0,0,0,0,0,0 9307,179,Placeholder image 13 Stanmore Resources Limited | Modern Slavery Statement 2021,0,0,0,0,0,0,0,0,0,0,0 9307,180,"DESCRIPTION OF HOW THE REPORTING ENTITY ASSESSES THE EFFECTIVENESS OF THESE ACTIONS During this reporting period, our focus was to work on understanding the modern slavery risks that may be present in our operations and supply chains",0,0,0,0,0,0,0,0,0,0,0 9307,181,"At this early stage, and with a significant change in the Stanmore Groups business through the acquisition of the interest in SMC, we have not yet been able to put in processes to adequately assess the effectiveness of measures we have undertaken",0,0,0,0,0,0,0,0,0,1,0 9307,182,The table below outlines how Stanmore proposes to assess the effectiveness of its modern slavery program in the next reporting period,0,0,0,0,0,0,0,0,0,0,0 9307,183,"These may be adjusted, and methods of measurement set, to adapt to changes in its risk profile and to ensure reporting is relevant and responsive",0,0,0,0,0,0,0,0,0,0,0 96,111,"If suppliers do not make enough progress to close audit findings or their actions do not result in sustainable changes, suppliers are then placed on a get well action plan. If the get well action plan is not successful, we take additional actions, which can include ending the supplier relationship",0,0,0,0,0,0,0,0,1,0,0 96,112,"Intels Supply Chain Sustainability Management Review Committee (MRC) reviews supplier CAPs quarterly, or more frequently, as needed",0,0,0,0,0,0,0,0,0,1,0 96,113,We require an RBA Closure Audit and/or an in- person visit to confirm CAP closure including fee repayment,0,0,0,0,0,0,0,0,1,0,0 96,114,"Responsible Minerals Through our annual supply chain conflict minerals survey process, which includes the Mobileye supply chain, our suppliers have identified 227 smelting and refining facilities that may process the 3TG contained in products provided to us",0,0,0,0,0,1,1,0,0,0,0 96,115,of these smelters and refiners in our extended supply chain participate in an independent third-party assurance program,0,0,0,0,0,0,0,1,0,0,0 96,116,"Certification Intel suppliers must agree to comply with all applicable laws, regulations, and international standards, and conform to our Code of Conduct and Policies, including the RBA Code of Conduct when they enter into purchasing agreements or equivalent terms and conditions with Intel",0,0,0,0,0,0,0,1,0,0,0 96,117,"This creates legally enforceable obligations, including in cases where the law is silent or allows practices that violate Intel policies or the RBA Code",0,0,0,0,0,0,0,1,0,0,0 96,118,"Moreover, we remind suppliers of their obligation to the RBA Code in our annual supplier letter",0,0,0,0,0,0,0,1,0,0,0 2824,39,UniSuper Advice financial advisers and support staff are employees of USM,0,0,0,0,1,0,0,0,0,0,0 2824,40,The USL Board comprises 11 directors (eight representative directors and three independent/non- representative directors),0,0,0,0,0,0,0,0,0,0,0 2824,41,Further information about our directors can be found on our website,0,0,0,0,0,0,0,0,0,0,0 2824,42,"The USM Board comprises 12 directors replicating those of the USL Board, with the addition of another director who is the Chief Executive Officer of USM, Kevin OSullivan",0,0,0,0,0,0,0,0,0,0,0 2824,43,Internal operations UniSuper is the complying superannuation fund dedicated to people employed in the higher education and research sector,0,0,0,0,1,0,0,0,0,0,0 2824,44,"Were one of Australias largest industry super funds with over 450,000 members and over $80 billion in funds under management",0,0,0,0,1,0,0,0,0,0,0 2824,45,The day-to-day administration of UniSuper is managed by USM,0,0,0,0,0,0,0,0,0,0,0 2824,46,The executive leadership team is committed to achieving its purpose: providing greater retirement outcomes for our members,0,0,0,0,0,0,0,0,0,0,0 5137,42,We recognise that this is a potential risk area for modern slavery,0,0,0,0,0,0,1,0,0,0,0 5137,43,"However, we have made enquiries and have been informed that these agencies fully comply with all applicable workplace laws and pay at least minimum rates of pay",0,0,0,0,0,0,0,1,0,0,0 5137,44,Our partner recruitment agencies are currently developing their own modern slavery policies/processes (and preparing modern slavery statements) and we will aim to review these when developed/lodged,0,0,0,0,0,0,0,1,0,1,0 5137,45,"Supply Chains In preparing this statement we focused on our suppliers with whom we have a direct contractual relationship (ie ""tier 1"" suppliers)",0,0,0,0,0,0,1,0,0,0,0 5137,46,"However, we acknowledge that incidences of modern slavery can exist throughout supply chains at any level and we are committed to assessing and reporting on these risks further in future years and statements as part of our process for continuous improvement",0,0,0,0,0,0,1,0,0,0,0 5137,47,132 312 515 ORDERS: 1300 65 88 22 FAX ORDERS: 1300 65 88 10 TEETH ORDERS: 1300 65 88 11 www.henryschein.com.au,0,0,0,0,0,0,0,0,0,0,0 5137,48,Our initial risk assessment consisted of a desktop review of our suppliers and a review of what peers and competitors have undertaken in this space,0,0,0,0,0,0,0,1,0,0,0 5137,49,This assessment indicated that there are certain risk factors present in our supply chains which may increase the potential for risks of modern slavery practices occurring in them,0,0,0,0,0,0,1,0,0,0,0 9307,184,COMPONENT METRIC,0,0,0,0,0,0,0,0,0,0,0 9307,185,FRAMEWORK,0,0,0,0,0,0,0,0,0,0,0 9307,186,Annual review of Modern Slavery Compliance and Action Plan,0,0,0,0,0,0,0,0,0,1,0 9307,187,"Development, implementation and periodic review of Modern Slavery Policy and complementary policies to take into account modern slavery risks",0,0,0,0,0,0,0,1,0,1,0 9307,188,Annual review of the role of the Modern Slavery Working Group and extent of cross-functional participation,0,0,0,0,0,0,0,0,0,1,0 9307,189,TRAINING,0,0,0,0,0,0,0,0,0,0,0 9307,190,Number and proportion of employees and contractors enrolled to complete modern slavery training,0,0,0,0,0,0,0,0,0,1,0 9307,191,The training completion rate for employees and contractors,0,0,0,0,0,0,0,0,0,1,0 96,119,"Internal Accountability Each year, our CEO communicates with employees and senior managers about the importance of ethics and legal compliance",0,0,0,0,0,0,0,1,0,0,0 96,120,Our CEO also regularly reminds employees and managers that nothing is worth doing if its not done with integrity,0,0,0,0,0,0,0,1,0,0,0 96,121,"This tone from the top, reiterated by our senior leadership team, is further cascaded throughout the company with the following activities: an annual ethics and compliance training, regular ethics & compliance communications, periodic company-wide ethics culture surveys, awareness trainings, annual ethics and compliance summits, and educational resources on our company intranet site",0,0,0,0,0,0,0,1,0,0,0 96,122,"Together, these activities help to create and maintain an ethical and legally compliant culture",0,0,0,0,0,0,0,0,0,0,0 96,123,"Through Intels Code of Conduct, we seek to promote honest and ethical conduct, deter wrongdoing, and support compliance with applicable laws and regulations",0,0,0,0,0,0,0,0,0,0,0 96,124,"The principles embodied in the Code of Conduct reflect our policies in such areas as slavery, human trafficking, conflicts of interest, nondiscrimination, antitrust, anti-bribery, and anti-corruption, and serve to protect our companys assets and reputation",0,0,0,0,0,0,0,0,0,0,0 96,125,The Code of Conduct directs employees to consider both short-term and long-term impacts on human rights when making business decisions and to report potential issues as soon as they are identified,0,0,0,0,0,0,0,1,0,0,0 96,126,All employees are expected to complete training on the Code of Conduct when they join the company and annually thereafter,0,0,0,0,0,0,0,1,0,0,0 2824,47,The team operate in line with annual performance objectives and report to the USL Board,0,0,0,0,0,0,0,0,0,0,0 2824,48,More information is outlined in our annual report and is available on our website,0,0,0,0,0,0,0,0,0,0,0 2824,49,"We have a national presence with more than 800 employees working in Melbourne, Sydney, Adelaide, Brisbane, Canberra and Perth, either in one of the UniSuper offices or on-campus at one of our university- based employers",0,0,0,1,1,0,0,0,0,0,0 2824,50,"Our internal operations include operating superannuation products, administering all products internally, providing inbuilt benefits and offering external insurance to members, providing general and personal financial product advice to members and spouses via UniSuper Advice, managing a substantial proportion of UniSupers investments internally, and selecting, monitoring and allocating funds to our external investment managers",0,0,0,0,1,0,1,0,0,0,0 2824,51,Further details about our internal operations (including our internally managed investments) can be found in the Appendix,0,0,0,0,0,0,0,0,0,0,0 2824,52,"Supply chains Our supply chains include our externally managed investments and goods and services generally supplied to us, including to support our internal operations",0,0,0,0,0,1,0,0,0,0,0 2824,53,Further details about our supply chains can be found in the Appendix,0,0,0,0,0,0,0,0,0,0,0 2824,54,"COVID-19 impact We acknowledge the social and economic impacts of the COVID-19 pandemic have been globally profound and may lead to an increased risk of modern slavery practices within the financial services industry, as well as our suppliers operations and supply chains",0,0,0,0,0,0,1,0,0,0,0 5137,50,The potential risks which we have identified in our supply chains are set out in the paragraphs below,0,0,0,0,0,0,1,0,0,0,0 5137,51,"Henry Schein engages with third party manufacturing plants in Asia which produce Henry Schein branded products including gloves, masks, tissues and various other consumable items",0,0,0,0,0,1,0,0,0,0,0 5137,52,"We are aware that these manufacturing plants carry potential risks of forced labour, child labour and human trafficking due to the industry's high labour intensity and reliance on migrant workers, the relatively low skill levels of workers and low level of regulation in these geographical locations generally",0,0,0,0,0,0,1,0,0,0,0 5137,53,"However, Henry Schein (globally) has an audit team based in Shanghai (linked to Henry Schein's global sourcing team) which has the ability to monitor and audit these third party manufacturing plants",0,0,0,0,0,0,0,1,0,1,0 5137,54,"We recognise that purchasing practices such as short production windows and last-minute or short- term orders may increase modern slavery risks for workers in our supply chains, hence we engage with suppliers to consider options to support vulnerable workers",0,0,0,0,0,0,1,0,0,0,0 5137,55,"We seek suppliers information on steps they have taken to protect their workers from COVID-19, such as providing workers with protective equipment, providing sick leave or carers leave, and increasing cleaning in premises to minimise the risk of infection",0,0,0,0,0,0,0,0,0,0,0 5137,56,As part of our aim for continuous improvement we are committed to further examining and assessing our supply chains,0,0,0,0,0,0,0,0,0,0,0 5137,57,We also recognise the potential for instances of modern slavery practices to occur further down our supply chains (ie beyond tier 1) and we will strive to analyse and report on lower levels of our supply chains in our next modern slavery statement,0,0,0,0,0,0,1,0,0,0,0 9307,192,The extent to which modern slavery training is made available to suppliers,0,0,0,0,0,0,0,0,0,1,0 9307,193,Annual review of relevance and currency of training material,0,0,0,0,0,0,0,0,0,1,0 9307,194,SUPPLIER ENGAGEMENT,0,0,0,0,0,0,0,0,0,0,0 9307,195,The extent to which suppliers are required to comply with Stanmores anti-slavery standards,0,0,0,0,0,0,0,0,0,1,0 9307,196,The extent to which standard supplier contracts contain modern slavery and whistleblowing clauses,0,0,0,0,0,0,0,0,0,1,0 9307,197,RISK ASSESSMENT AND REMEDIATION,0,0,0,0,0,0,0,0,0,0,0 9307,198,Annual risk assessment of operations for modern slavery risk,0,0,0,0,0,0,0,1,0,0,0 9307,199,The extent to which suppliers are profiled for modern slavery risk,0,0,0,0,0,0,0,0,0,1,0 96,127,"The Code of Conduct is available in 14 languages, and employee training sessions incorporate real case scenarios",0,0,0,0,0,0,0,1,0,0,0 96,128,Employees are encouraged to raise ethical questions and,0,0,0,0,0,0,0,1,0,0,0 96,129,"2019 Intel Corporation Statement on Combating Modern Slavery 7 concerns and have multiple channels to do so, anonymously if they prefer, as permitted by law",0,0,0,0,0,0,0,1,0,0,0 96,130,Intel employees are required to comply with the Code of Conduct,0,0,0,0,0,0,0,1,0,0,0 96,131,"Employee violations of the Code of Conduct may result in discipline, including termination and/or report of the misconduct to the relevant government authorities",0,0,0,0,0,0,0,1,0,0,0 96,132,"Intels Ethics & Compliance Oversight Committee (ECOC), which is chartered by and reports to the Audit Committee of the Board of Directors, is responsible for maintaining Intels Code of Conduct",0,0,0,0,0,0,0,1,0,0,0 96,133,The ECOC includes senior representatives from across the company and is co-chaired by Intels Chief Compliance Officer and Director of Internal Audit,0,0,0,0,0,0,0,1,0,0,0 96,134,"Each year, Intels ECOC invites various Intel organizations to assess and report on ethics and compliance in their respective businesses or sites and reviews risk topics across the company",0,0,0,0,0,0,0,0,0,1,0 2824,55,"Since the outbreak, we have complied with workplace health and safety requirements in Australia and carry out our identification and assessment activities to identify risks of modern slavery practices within our internal operations and supply chains",0,0,0,0,0,0,0,0,0,0,0 2824,56,Weve also continued our direct engagement with companies to discuss human rights and supply chain risks,0,0,0,0,0,0,0,0,0,1,0 2824,57,Risks of modern slavery practices Modern slavery focuses on risk as it relates to people,0,0,0,0,0,0,0,0,0,0,0 2824,58,"Risk to people incorporates concepts of severity of modern slavery practices, likelihood of occurrence, as well as the extent of the effect, in terms of the number of people affected and over what time period",0,0,0,0,0,0,0,0,0,0,0 2824,59,Internal operations Were strongly committed to ensuring compliance with all workplace health and safety requirements applicable to our places of work,0,0,0,0,0,0,0,0,0,0,0 2824,60,"We recognise our responsibilities are to provide, so far as is reasonably practicable, a safe working environment to our people without risks to health, in accordance with the applicable statutory requirements",0,0,0,0,0,0,0,0,0,0,0 2824,61,Were committed to,0,0,0,0,0,0,0,0,0,0,0 2824,62,working safely,0,0,0,0,0,0,0,0,0,0,0 5137,58,Actions taken by Henry Schein and the entities which Henry Schein owns or controls to assess and address modern slavery risks Actions Over the reporting period Henry Schein has taken steps to assess and address the risks of modern slavery practices occurring in our operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 5137,59,"For example, Henry Schein (at the US parent level) produced a document for internal use called the ""Australian Modern Slavery Act Due Diligence Survey."" This document highlighted areas of our business to consider in terms of potential for modern slavery risks (including particular country, sector, transaction and business partnership related risks) and provided guidance on how to prepare a compliant modern slavery statement",0,0,0,0,0,0,0,1,0,0,0 5137,60,This document was shared internally and utilised by Henry Schein in its modern slavery due diligence process and in preparing this statement,0,0,0,0,0,0,0,1,0,0,0 5137,61,"We have continued to use and make reference to our Global Supplier Code of Conduct which sets out our expectations in the areas of business integrity, labour practices, employee health and safety",0,0,0,0,0,0,0,1,0,0,0 5137,62,132 312 515 ORDERS: 1300 65 88 22 FAX ORDERS: 1300 65 88 10 TEETH ORDERS: 1300 65 88 11 www.henryschein.com.au,0,0,0,0,0,0,0,0,0,0,0 5137,63,and environmental management,0,0,0,0,0,0,0,1,0,0,0 5137,64,The Supplier Code of Conduct is made available to all of our suppliers at the outset of our relationship as part of the on boarding process,0,0,0,0,0,0,0,1,0,0,0 5137,65,"In accordance with the Code, we require our suppliers to conduct their business responsibly, with integrity and honesty and importantly, to comply with, all applicable laws and regulations",0,0,0,0,0,0,0,1,0,0,0 9307,200,"Number and proportion of suppliers identified as having a high, medium and low risk of modern slavery",0,0,0,0,0,0,0,0,0,1,0 9307,201,The extent to which due diligence questionnaires are issued to suppliers,0,0,0,0,0,0,0,0,0,1,0 9307,202,The response rate of suppliers to the due diligence questionnaire,0,0,0,0,0,0,0,0,0,1,0 9307,203,MONITORING,0,0,0,0,0,0,0,0,0,0,0 9307,204,Types of remediation actions taken,0,0,0,0,0,0,0,0,0,1,0 9307,205,The extent to which Stanmores whistleblower program is available and publicised,0,0,0,0,0,0,0,0,0,1,0 9307,206,The number of reports of conduct posing a modern slavery risk,0,0,0,0,0,0,0,0,0,1,0 9307,207,Audit program of operations and steps taken by suppliers in response to remedial actions,0,0,0,0,0,0,0,0,0,1,0 96,135,The Intel Board of Directors' Corporate Governance and Nominating (CGN) Committee has primary responsibility for oversight of corporate responsibility issues at Intel,0,0,0,0,0,0,0,1,0,0,0 96,136,"Management provides formal updates to the CGN Committee at least twice each year and at least annually to the full Board on the company's corporate responsibility performance and disclosure, including human rights issues",0,0,0,0,0,0,0,1,0,0,0 96,137,The annual Intel Modern Slavery and Human Trafficking Statement is reviewed and approved by the CGN Committee and the full board,0,0,0,0,0,0,0,0,0,0,0 96,138,Training Intel provides employees with direct responsibility for supply chain management and U.S,0,0,0,0,0,0,0,1,0,0,0 96,139,"Federal contracts with training on slavery and human trafficking, particularly with respect to mitigating risks within our product supply chain",0,0,0,0,0,0,0,1,0,0,0 96,140,"We educate suppliers about our expectations through webinars, workshops, our supplier website and our annual expectations letter, sent to our direct suppliers",0,0,0,0,0,0,0,1,0,0,0 96,141,Intel provides annual targeted training and workshops for suppliers operating in geographical regions where we conclude there is an elevated risk of slavery and human trafficking,0,0,0,0,0,0,0,1,0,0,0 96,142,Each year we also deliver our expectations of combating slavery and human trafficking risks in a webinar,0,0,0,0,0,0,0,1,0,0,0 2824,63,"providing a workplace free from harassment, discrimination and bullying",0,0,0,0,0,0,0,0,0,0,0 2824,64,acting ethically and lawfully in all business conduct,0,0,0,0,0,0,0,0,0,0,0 2824,65,"engaging with stakeholders respectfully and honestly, and",0,0,0,0,0,0,0,0,0,0,0 2824,66,"building sustainable communities through providing local jobs, developing local skills and local business opportunities",0,0,0,0,0,0,0,0,0,0,0 2824,67,Our work is guided by our UniSuper values which are an integral part of the way we do things and a framework for our shared expectations,0,0,0,0,0,0,0,0,0,0,0 2824,68,They can be found on our website,0,0,0,0,0,0,0,0,0,0,0 2824,69,"Our values are: were better together, we can be counted on, we strive for excellence, we take initiative, and we genuinely care for our members",0,0,0,0,0,0,0,0,0,0,0 2824,70,We consider our potential exposure to modern slavery risk in respect of internal operations to be low,0,0,0,0,0,0,1,0,0,0,0 5137,66,The Code of Conduct makes specific reference to our expectation that suppliers will (among other things),0,0,0,0,0,0,0,1,0,0,0 5137,67,"treat employees fairly including with respect to wages, working hours and benefits",0,0,0,0,0,0,0,1,0,0,0 5137,68,provide safe and healthy working conditions in their operations,0,0,0,0,0,0,0,1,0,0,0 5137,69,maintain and promote fundamental human rights; and,0,0,0,0,0,0,0,1,0,0,0 5137,70,prohibit any use of child labour in their operations,0,0,0,0,0,0,0,1,0,0,0 5137,71,In October 2019 the Henry Schein Group implemented an online training programme (called the Henry Schein Global Compliance Learning) which all employees (globally) were required to complete,0,0,0,0,0,0,0,1,0,0,0 5137,72,This mandatory training included information and guidance on how to identify modern slavery and human rights issues including by providing participants with a definition of modern slavery and running through examples of modern slavery (using specific scenario based videos/training methods) which employees might encounter in the course of their work,0,0,0,0,0,0,0,1,0,0,0 5137,73,The training was rolled out again for all employees in 2020 and the decision has been made to implement it on an annual basis going forward,0,0,0,0,0,0,0,1,0,0,0 9307,208,Stanmore Resources Limited | Modern Slavery Statement 2021,0,0,0,0,0,0,0,0,0,0,0 9307,209,"DESCRIPTION OF THE PROCESS OF CONSULTATION WITH ANY ENTITIES THE REPORTING ENTITY OWNS OR CONTROLS During the preparation and finalisation of this Statement, this Statement was provided to each member of the Stanmore Group, including each reporting entity, for review and comment",0,0,0,0,0,0,0,0,0,0,1 9307,210,The Stanmore Group entities are centrally governed and managed by common Directors across the companies,0,0,0,0,0,0,0,0,0,0,1 9307,211,"With its small number of employees and simple management structure primarily based in Brisbane, information sharing and consultation occurred organically across the Stanmore Group",0,0,0,0,0,0,0,0,0,0,1 9307,212,"During the Reporting Period, the formal vehicles for consultation were the ARMC (which included a Director sitting on each of the Stanmore Group companies Boards) to inform and contribute to the direction on modern slavery risk, and development of the Statement",0,0,0,0,0,0,0,0,0,0,1 9307,213,"In addition, the Modern Slavery Working Group convened to discuss the reporting requirements under the Act, gap analysis findings, and actions to address modern slavery risk",0,0,0,0,0,0,0,0,0,0,1 9307,214,"This Statement was prepared by Stanmore Legal with input from the Finance, Procurement, Payroll, and HR teams",0,0,0,0,0,0,0,0,0,0,0 9307,215,"Before being put to the Board of SMR for review and approval, this Statement was reviewed by the CEO, CFO, General Manager Technical, General Manager Supply, General Counsel, and Corporate Governance and Risk Manager",0,0,0,0,0,0,0,0,0,0,0 96,143,"We record the webinar, which is then available on-demand for our suppliers anywhere in the world",0,0,0,0,0,0,0,1,0,0,0 96,144,As part of our multi-year work with 50 critical suppliers we created resource materials and held a series of webinars to educate them and the Tier 2 suppliers on the risks of modern slavery,0,0,0,0,0,0,0,1,0,0,0 96,145,"In June and July 2019, we worked with HP Enterprise, HP Inc., Seagate, and Western Digital to provide in-person training to over 200 suppliers and their recruiting agents in Malaysia, Singapore, Taiwan, and Thailand",0,0,0,0,0,0,0,1,0,0,0 96,146,"of these were Intel suppliers, representing approximately 20% of our critical suppliers",0,0,0,0,0,0,0,1,0,0,0 96,147,Environmental Resources Management (ERM) led the workshops,0,0,0,0,0,0,0,1,0,0,0 96,148,"Since we began annual training and webinars in 2014, we estimate that we have trained over 50% of our critical suppliers",0,0,0,0,0,0,0,0,0,1,0 96,149,"Outreach We continue to make every effort to educate other companies and professionals about our work in this area to foster collective learning, growth, and progress",0,0,0,0,0,0,0,0,0,0,0 96,150,"In 2019, we shared insights into Intels journey to combat modern slavery with various media outlets, journal articles, podcasts, webinar panels, external conferences, and training sessions",0,0,0,0,0,0,0,1,0,0,0 2824,71,"However, we recognise our internally managed investments is an area of focus in respect of modern slavery",0,0,0,0,0,0,1,0,0,0,0 2824,72,Further details about the areas of modern slavery risks identified in our internal operations (including our general approach to managing modern slavery risks in our internally managed investments) for the 2019-20 financial year can be found in the Appendix,0,0,0,0,0,0,0,0,0,0,0 2824,73,Supply chains We consider our overall exposure to modern slavery risk in respect of our supply chains to be of generally lower risk,0,0,0,0,0,0,1,0,0,0,0 2824,74,"However, we recognise some aspects of our supply chains may be subject to a higher risk of modern slavery",0,0,0,0,0,0,1,0,0,0,0 2824,75,Further details about the areas of modern slavery risks identified in our supply chains (including our understanding of how our external investment managers are managing modern slavery risk in our externally managed investments) for the 2019-20 financial year can be found in the Appendix,0,0,0,0,0,0,0,0,0,0,0 2824,76,630 692 UNISUPER.COM.AU,0,0,0,0,0,0,0,0,0,0,0 2824,77,Our actions to assess and address the risks,0,0,0,0,0,0,0,0,0,0,0 2824,78,1800 630 692 UNISUPER.COM.AU 6 Supply chains,0,0,0,0,0,0,0,0,0,0,0 5137,74,"We have continued to use our Distribution and Supply Agreement which requires all our suppliers to confirm that they will (and that their directors, employees, and agents will) comply with all applicable laws in relation to the supply of products under the Agreement",0,0,0,0,0,0,0,1,0,0,0 5137,75,Henry Schein in Australia sold a glove range which is manufactured by companies located in South East Asia,0,0,0,0,1,1,0,0,0,0,0 5137,76,"In August 2020 we became aware of a decision by the US Customs and Border Protection to impose a detention order on these companies ""based on reasonable evidence of forced labour in the manufacturing process including debt bondage, excessive overtime, retention of identification documents, and abusive working and living conditions",0,0,0,0,0,0,1,0,0,0,0 5137,77,"Upon Henry Schein becoming aware of the decision of the US Customs and Border Protection we immediately suspended our dealings with the manufacturer while we considered the matter, sought guidance and advice and also took inventory of our relevant saleable stock",0,0,0,0,0,0,0,0,1,0,0 5137,78,"Ultimately, we took the decision to cease the sale of the relevant products and to cease trading with any of the associated companies of the manufacturer",0,0,0,0,0,0,0,0,1,0,0 5137,79,Remediation processes Henry Schein is committed to investigating any report of potential incidences of modern slavery occurring anywhere in our operations or supply chains,0,0,0,0,0,0,0,0,1,0,0 5137,80,In line with our values and commitments we confirm that we would take all appropriate steps to rectify any confirmed incidences of modern slavery in our operations or supply chains,0,0,0,0,0,0,0,0,1,0,0 5137,81,Henry Schein,0,0,0,0,0,0,0,0,1,0,0 9307,216,The Stanmore Group entities are centrally governed and managed by common Directors across the companies,0,0,0,0,0,0,0,0,0,0,0 9307,217,Stanmore Resources Limited | Modern Slavery Statement 2021,0,0,0,0,0,0,0,0,0,0,0 9307,218,OTHER RELEVANT INFORMATION 7.1,0,0,0,0,0,0,0,0,0,0,0 9307,219,COVID-19 Stanmore has assessed the impact of the COVID-19 pandemic on its practices and risks to modern slavery,0,0,0,0,0,0,0,1,0,0,0 9307,220,"We worked collaboratively with suppliers to manage inventory and lengthened delivery and lead times, and are developing a COVID-19 response plan for implementation in 2022",0,0,0,0,0,0,0,1,0,0,0 9307,221,"Consistent with other companies in the mining industry, there has been an increase in absenteeism in early 2022 due to COVID-19 cases",0,0,0,0,0,0,0,0,0,0,0 9307,222,We managed the operational impacts of COVID-19 in early 2022 by segregating staff with short term absentees absorbed,0,0,0,0,0,0,0,0,0,0,0 9307,223,There was no replacement of workers or short-term hires,0,0,0,0,0,0,0,0,0,0,0 96,151,Weve also met with governments and have attended offered trainings to stay fresh on issues,0,0,0,0,0,0,0,1,0,0,0 96,152,Leadership We believe that collaboration is key to addressing this complex issue,0,0,0,0,0,0,0,0,0,0,0 96,153,"Intel co-founded the multi-industry, multi-stakeholder Responsible Labor Initiative (RLI), which works to protect and promote the rights of vulnerable workers",0,0,0,0,0,0,0,1,0,0,0 96,154,In 2019 Intel served as a member of the RLI Steering Committee and the RLI Working Group,0,0,0,0,0,0,0,1,0,0,0 96,155,"The RLI has established a number of programs and tools, including the following",0,0,0,0,0,0,0,0,0,1,0 96,156,"May 14, 2020",0,0,0,0,0,0,0,0,0,0,0 136,0,Autosports Group Limited MODERN SLAVERY STATEMENT 2020,0,0,1,0,0,0,0,0,0,0,0 136,1,Introduction Autosports Group Limited and its subsidiaries (Autosports Group) oppose slavery in all its forms,0,0,0,0,0,0,0,0,0,0,0 2824,79,Engaging with our external investment managers We requested all our external investment managers (across all geographies and asset classes) to complete our modern slavery questionnaire and held subsequent discussions to gain a better understanding of their processes for identifying and assessing risk when managing our investments,0,0,0,0,0,0,0,1,0,0,0 2824,80,This was done as part of our regular due diligence on managers ESG performance and processes as well as specific requests focussing on their modern slavery risk management,0,0,0,0,0,0,0,1,0,0,0 2824,81,Performing a supplier risk identification assessment and engaging with our higher risk suppliers We identified 38 suppliers with a higher risk of modern slavery in their operations or supply chains (see the Appendix for the enterprise- wide assessment process undertaken),0,0,0,0,0,0,1,0,0,0,0 2824,82,"We then prioritised modern slavery risk engagement activities with these higher risk suppliers, including commencing a due diligence process",0,0,0,0,0,0,0,0,0,1,0 2824,83,"As part of the process, these higher risk suppliers were encouraged to complete our supplier survey to help inform our future engagement with these suppliers in respect of modern slavery risks",0,0,0,0,0,0,0,1,0,1,0 2824,84,Developing contractual provisions We commenced developing modern slavery risk provisions into our standard contract templates,0,0,0,0,0,0,0,1,0,0,0 2824,85,These provisions will be incorporated into our contracts with higher risk suppliers,0,0,0,0,0,0,0,1,0,0,0 2824,86,Internal operations,0,0,0,0,0,0,0,0,0,0,0 5137,82,132 312 515 ORDERS: 1300 65 88 22 FAX ORDERS: 1300 65 88 10 TEETH ORDERS: 1300 65 88 11 www.henryschein.com.au,0,0,0,0,0,0,0,0,0,0,0 5137,83,"would work collaboratively with its suppliers and, if necessary, their suppliers, to achieve these goals",0,0,0,0,0,0,0,0,1,0,0 5137,84,"If, for any reason, progress in this regard was not possible, Henry Schein would take steps to sever its connections to the offending supplier or sub-supplier",0,0,0,0,0,0,0,0,1,0,0 5137,85,"Assessing the effectiveness of actions taken to assess and address modern slavery risks As outlined above, Henry Schein requires all employees globally to undertake and complete online training modules which include training, guidance and information on modern slavery and human rights issues",0,0,0,0,0,0,0,1,0,0,0 5137,86,At the end of each training session each employee must complete an assessment to demonstrate that they have understood the content of the training,0,0,0,0,0,0,0,0,0,1,0 5137,87,This is one way that we assess the effectiveness of the training sessions,0,0,0,0,0,0,0,0,0,0,0 5137,88,"In addition, Henry Schein aims to set up processes to discuss and review engagement and feedback between key areas of its business in relation to modern slavery",0,0,0,0,0,0,0,0,0,1,0 5137,89,Consultation Henry Schein's group structure (including entities which are owned and controlled by Henry Schein) is set out earlier in this statement,0,0,0,0,0,0,0,0,0,0,0 9307,224,We will continue to work with our contractors on protocols to minimise the spread and impacts on operations,0,0,0,0,0,0,0,0,0,0,0 9307,225,The greatest risk remains widespread COVID-19 infections in-camp,0,0,0,0,0,0,0,0,0,0,0 9307,226,Key statutory roles were accommodated in Moranbah rather than at camp to reduce the exposure risk,0,0,0,0,0,0,0,0,0,0,0 9307,227,The accommodation plan for key statutory roles has been extended to the end of October 2022 and will be reviewed again at that time,0,0,0,0,0,0,0,0,0,0,0 9307,228,Directors Statement This Statement was approved by the Board of Directors of Stanmore Resources Limited in their capacity as the principal governing body of Stanmore Resources Limited and as the parent entity for each other reporting entity on 29 June 2022,1,0,0,0,0,0,0,0,0,0,0 9307,229,This statement is signed by Marcelo Matos in his role as Chief Executive Officer and Director of Stanmore Resources Limited on 29 June 2022,0,1,0,0,0,0,0,0,0,0,0 9307,230,Marcelo Matos Chief Executive Officer and Director of Stanmore Resources Limited 29 June 2022,0,1,0,0,0,0,0,0,0,0,0 9313,0,Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 136,2,This statement describes the steps we took during the financial year ending 30 June 2020 to seek to minimise the risk of modern slavery occurring in our business and supply chains,0,0,0,0,0,0,0,0,0,0,0 136,3,"Our Structure, Operations and Supply Chains Autosports Group is an Australian business specialising in the sale of luxury motor vehicles, vehicle servicing and repairs, parts retailing and wholesaling and collision repair",0,0,0,0,1,0,0,0,0,0,0 136,4,Autosports Group was established in 2006 and listed on the Australian Securities Exchange in 2016,0,0,0,0,0,0,0,0,0,0,0 136,5,"Autosports Group comprises 16 wholly-owned subsidiaries which operate 50 businesses across Queensland, New South Wales and Victoria",0,0,0,1,0,0,0,0,0,0,0 136,6,"Our supply chains include the following goods and services: vehicles and parts, consumables such as oil, fuel, paint and lubricants, logistics and transport services, car washing and detailing services, sublet, recruitment services, marketing and printing services, cleaning, storage and waste disposal services, professional services, finance products, insurance, property rental and vehicle storage, information technology, telecommunication products and services, coffee, food and beverage, gift hampers and office supplies",0,0,0,0,0,1,0,0,0,0,0 136,7,Overview of the Australian Automotive Dealership Industry,0,0,0,0,0,0,0,0,0,0,0 136,8,Approach to modern slavery,0,0,0,0,0,0,0,0,0,0,0 136,9,The Board approved a Modern Slavery Plan in respect of the FY20 reporting period to focus the Group's enquiries and engagement with its stakeholders,0,0,0,0,0,0,0,1,0,0,0 2824,87,"Establishment of a Modern Slavery Working Group We established a modern slavery working group (MSWG) comprising members of our risk and compliance, finance (procurement & facilities), investments and legal departments",0,0,0,0,0,0,0,1,0,0,0 2824,88,The working groups responsibility was to oversee and monitor initial compliance with the Act,0,0,0,0,0,0,0,1,0,0,0 2824,89,"Training and culture Members of our MSWG along with employees in our procurement, compliance and legal functions successfully completed modern slavery risk training provided by an external compliance and risk specialist to better understand our legislative obligations",0,0,0,0,0,0,0,1,0,0,0 2824,90,Further training will be provided to relevant employees in the future,0,0,0,0,0,0,0,1,0,0,0 2824,91,"Incorporating modern slavery into our ESG processes We integrated modern slavery risk analysis into the existing Environmental, Social and Governance (ESG) risk processes for our internally managed portfolios",0,0,0,0,0,0,0,1,0,0,0 2824,92,These assessment processes allowed us to focus on due diligence with higher risk suppliers and prioritise modern slavery engagement activities,0,0,0,0,0,0,0,1,0,0,0 2824,93,Engaging directly with companies we invest in Engaging directly with companies to discuss human rights and supply chain risks,0,0,0,0,0,0,0,0,0,1,0 2824,94,"These discussions include a focus on their approach to identifying potential areas of risk, investigations undertaken to follow up possible issues in their supply chain and processes for early detection and monitoring of risks",0,0,0,0,0,0,0,0,0,1,0 5137,90,Henry Schein is a well-integrated business,0,0,0,0,0,0,0,0,0,0,1 5137,91,"The same practices and procedures regarding responsible business, ethics and compliance apply to the affiliates in our group at a global and local level",0,0,0,0,0,0,0,0,0,0,1 5137,92,We have communicated with entities which we own and control regarding this statement and our approach to modern slavery noting they are subject to the same policies and processes as set out in this statement,0,0,0,0,0,0,0,0,0,0,1 5137,93,Other relevant information Henry Schein is committed to working to improve its assessment and addressing of modern slavery risks and is committed to implementing the following measures in our next reporting period,0,0,0,0,0,0,0,1,0,0,0 5137,94,the drafting and implementation of a standalone modern slavery policy,0,0,0,0,0,0,0,1,0,0,0 5137,95,conducting an information session on our first modern slavery statement,0,0,0,0,0,0,0,1,0,0,0 5137,96,setting up processes to discuss and review engagement and feedback between key areas of the business in relation to modern slavery risks; and,0,0,0,0,0,0,0,0,0,1,0 5137,97,"updating template supplier contracts to include modern slavery specific clauses including warranties and covenants, commitments to eradicate modern slavery in operations and supply chains, commitments to comply with our Supplier Code of Conduct, audit rights, suspension and termination rights and indemnities",0,0,0,0,0,0,0,1,0,0,0 9313,1,Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 9313,2,Introduction 3,0,0,0,0,0,0,0,0,0,0,0 9313,3,"Reporting Entities structure, Operations and Supply chains 4",0,0,0,0,0,0,0,0,0,0,0 9313,4,Risks of modern slavery 6,0,0,0,0,0,0,0,0,0,0,0 9313,5,Actions to assess and address the risks 8,0,0,0,0,0,0,0,0,0,0,0 9313,6,Assessing the effectiveness of actions 9,0,0,0,0,0,0,0,0,0,0,0 9313,7,Process of consultation 9,0,0,0,0,0,0,0,0,0,0,0 9313,8,Approval 9 Contents,0,0,0,0,0,0,0,0,0,0,0 136,10,Management reported to the Audit & Risk Committee throughout the year in relation to the Group's progress with the Modern Slavery Plan,0,0,0,0,0,0,0,1,0,0,0 136,11,The Board was responsible for approving modern slavery-related policies such as the Supplier Code of Conduct and this statement,0,0,0,0,0,0,0,1,0,0,0 136,12,FY20 Modern Slavery Plan,0,0,0,0,0,0,0,0,0,0,0 136,13,The key steps of our modern slavery plan are set out below,0,0,0,0,0,0,0,0,0,0,0 136,14,"Legal, People and Cuture and Operations Audit and Risk Committee ASG Board",0,0,0,0,0,0,0,0,0,0,0 136,15,Map and review our supply chains,0,0,0,0,0,0,0,0,0,0,0 136,16,Identify risks in our supply chains,0,0,0,0,0,0,0,0,0,0,0 136,17,Conduct due diligence,0,0,0,0,0,0,0,0,0,0,0 2824,95,Contributing to and engaging with investor groups Collaborating with various investor groups such as the Australian Council of Superannuation Investors (ACSI) and United Nations Principles for Responsible Investment (PRI),0,0,0,0,0,0,0,1,0,0,0 2824,96,"We are active members of these and other collaborative bodies and participate in various forums in which companies, affected workers, industry bodies and other relevant experts discuss modern slavery and supply chain issues",0,0,0,0,0,0,0,1,0,0,0 2824,97,FY 2020 We took a proactive approach to assess and address modern slavery risks within our internal operations and supply chains during the 2019-20 financial year,0,0,0,0,0,0,0,0,0,0,0 2824,98,The actions we took include,0,0,0,0,0,0,0,0,0,0,0 2824,99,Supply chains,0,0,0,0,0,0,0,0,0,0,0 2824,100,Supplier awareness and due diligence We plan to undertake further analysis of the supplier survey responses received in our investments and procurement functions for the 2019-20 financial year,0,0,0,0,0,0,0,1,0,1,0 2824,101,"Where higher risk suppliers have undertaken actions to address modern slavery risks, well work with them to monitor progress",0,0,0,0,0,0,0,0,0,1,0 2824,102,"Additionally, well use survey data to engage and manage higher risk suppliers",0,0,0,0,0,0,0,0,0,1,0 5137,98,Impact of Covid 19,0,0,0,0,0,0,0,0,0,0,0 5137,99,132 312 515 ORDERS: 1300 65 88 22 FAX ORDERS: 1300 65 88 10 TEETH ORDERS: 1300 65 88 11 www.henryschein.com.au,0,0,0,0,0,0,0,0,0,0,0 5137,100,The COVID-19 pandemic increased the urgency and necessity for the sourcing and supply of medical products and PPE to medical professionals,0,0,0,0,0,0,0,0,0,0,0 5137,101,"Accordingly, Henry Schein's focus over its reporting period was on facilitating this sourcing and supply",0,0,0,0,0,0,0,0,0,0,0 5137,102,"As a result, Henry Schein's coordination of a detailed modern slavery response over the relevant reporting period (including the drafting of this statement) was impacted",0,0,0,0,0,0,0,0,0,0,0 5137,103,"However, in our next reporting period we intend to divert more time and resources to taking actions to assess and address modern slavery risks in our operations and supply chains (as outlined in more detail above)",0,0,0,0,0,0,0,0,0,0,0 5137,104,Approval This Modern Slavery Statement is made in accordance with section 13 of the Modern Slavery Act 2018 (Cth),0,0,0,0,0,0,0,0,0,0,0 5137,105,This statement was approved by the Board of Directors of Henry Schein Regional Pty Limited acting in its capacity as trustee for The Henry Schein Regional Trust on 14 July 2021,1,0,0,0,0,0,0,0,0,0,0 9313,9,"Modern Slavery Statement This is a modern slavery statement for a single reporting entity, made by Green Light Contractors PTY LTD (ABN 83 168 435 658)",0,0,1,0,0,0,0,0,0,0,0 9313,10,This statement is published as part of Green Light Contractors obligations under the Modern Slavery Act (Cth) 2018,0,0,0,0,0,0,0,0,0,0,0 9313,11,For the reporting period 1 January 2021 to 31 December 2021 (2021 Calendar Year),0,0,0,0,0,0,0,0,0,0,0 9313,12,"This is the first Modern Slavery Statement published by Green Light Contractors, the company having a consolidated revenue of at least $100million for the first time in the reporting period",0,0,0,0,0,0,0,0,0,0,0 9313,13,This statement describes activities initiated through the reporting period to strengthen Green Light Contractors processes and identify risks of modern slavery in Green Light Contractors operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 9313,14,Our company values at Green Light Contractors outlines our commitment to focusing on providing a safe environment for all,0,0,0,0,0,0,0,0,0,0,0 9313,15,We are focused on people and their safety,0,0,0,0,0,0,0,0,0,0,0 9313,16,We are committed to creating trust with our suppliers and customers,0,0,0,0,0,0,0,0,0,0,0 136,18,Develop policies and processes,0,0,0,0,0,0,0,0,0,0,0 136,19,Educate and Train,0,0,0,0,0,0,0,0,0,0,0 136,20,"Review and Monitor Representatives from Legal, People and Culture and Operation are responsible for formulating and managing the implementation of our Modern Slavery Plan",0,0,0,0,0,0,0,1,0,0,0 136,21,This Group is Spearheaded by Head of Legal,0,0,0,0,0,0,0,1,0,0,0 136,22,"They identify, manage and report on modern slavery risks, conduct due diligence activities and manage our reporting obligations",0,0,0,0,0,0,0,1,0,0,0 136,23,The Head of Legal presents our Modern Slavery Plan to the Audit and Risk Committee,0,0,0,0,0,0,0,1,0,0,0 136,24,The Audit and Risk Committee oversees the processes and procedures undertaken,0,0,0,0,0,0,0,0,0,1,0 136,25,The Head of Legal reports to the Audit and Risk Committee on the progress of our Modern Slavery Plan and identified risks,0,0,0,0,0,0,0,0,0,1,0 2824,103,Ongoing monitoring and assessment Well continue to review suppliers with a higher risk of modern slavery practices in their operations or supply chains,0,0,0,0,0,0,0,0,0,1,0 2824,104,Well also continue to engage with high risk suppliers,0,0,0,0,0,0,0,0,0,1,0 2824,105,Well analyse responses to better understand the extent of modern slavery practices within our suppliers operations and supply chains,0,0,0,0,0,0,0,0,0,1,0 2824,106,Modern slavery contract provisions Well incorporate modern slavery risk provisions in our contract templates and look to incorporate these provisions in contracts with higher risk suppliers,0,0,0,0,0,0,0,1,0,0,0 2824,107,"Remediation If we become aware of potential modern slavery practices occurring in our operations or supply chains, we will take appropriate steps to ensure the matter is addressed and, where necessary, remediated",0,0,0,0,0,0,0,0,1,0,0 2824,108,The remedial action we take will depend on the circumstances,0,0,0,0,0,0,0,0,1,0,0 2824,109,Internal operations,0,0,0,0,0,0,0,0,0,0,0 2824,110,"Monitor and manage the risks of modern slavery in the Financial Risk & Assurance Committee (FRAC) Well incorporate monitoring and managing the risks of modern slavery in our Financial Risk & Assurance Committee and facilitate engagement and feedback between key areas of our operations (such as risk and compliance, finance (procurement & facilities), investments and legal)",0,0,0,0,0,0,0,0,0,1,0 5137,106,"Signed for and on behalf of Henry Schein Regional Pty Limited in its capacity as trustee for The Henry Schein Regional Trust Maurie Stang Director, Henry Schein Regional Pty Limited",0,1,0,0,0,0,0,0,0,0,0 5169,0,Lead Document Controller (RSG) Page 1 of 7,0,0,0,0,0,0,0,0,0,0,0 5169,1,Modern Slavery Voluntary Statement This statement is published by Resolute Mining Limited (Resolute or Company) in accordance with the requirements of the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018 and details our approach in addressing human rights and modern slavery risks across our business and supply chains,0,0,1,0,0,0,0,0,0,0,0 5169,2,This statement covers Resolutes first reporting period for the year ending in 31 December 2020,0,0,0,0,0,0,0,0,0,0,0 5169,3,This statement was developed by the Resolute sustainability team and approved by the Board of Directors,1,0,0,0,0,0,0,0,0,0,0 5169,4,"About Resolute Resolute is a successful gold miner with more than 30 years of experience as an explorer, developer and operator of gold mines in Australia and Africa which have collectively produced more than 8 million ounces of gold",0,0,0,0,1,0,0,0,0,0,0 5169,5,Resolute is dual listed on the Australian Securities Exchange (ASX:RSG) and the London Stock Exchange (LSE:RSG),0,0,0,0,0,0,0,0,0,0,0 5169,6,"The Company currently operates two mines, the Syama Gold Mine in Mali (Syama) and the Mako Gold Mine in Senegal (Mako), and is one of the largest gold producers listed on the Australian Securities Exchange",0,0,0,0,1,0,0,0,0,0,0 9313,17,"We are a responsible organisation that prides ourselves on our respect, integrity, and ethics",0,0,0,0,0,0,0,0,0,0,0 9313,18,We aim to be a people centric business generating shared value and sustainability,0,0,0,0,0,0,0,0,0,0,0 9313,19,Introduction,0,0,0,0,0,0,0,0,0,0,0 9313,20,Modern Slavery Statement Entity structure Green Light Contractors is a wholly owned and controlled subsidiary of Elecnor Australia PTY LTD (90 164 831 930),0,0,0,1,0,0,0,0,0,0,0 9313,21,What we do Green Light Contractors is primarily involved in the renewable energy industry and the projects that we undertake mainly comprise of electricity & electricity generation,0,0,0,0,1,0,0,0,0,0,0 9313,22,"Reporting Entities structure, Operations and Supply chains Operations locations Green Light Contractors has projects broadly spread across Australia",0,0,0,0,1,0,0,0,0,0,0 9313,23,Our principal office locations and projects and set out below,0,0,0,0,0,0,0,0,0,0,0 9313,24,Green Light Contractors has 160 employees,0,0,0,1,0,0,0,0,0,0,0 136,26,The Audit and Risk Committee presents the Modern Slavery Plan to the Board for approval,0,0,0,0,0,0,0,1,0,0,0 136,27,The Modern Slavery Plan is reviewed and approved by the Board annually,0,0,0,0,0,0,0,0,0,0,0 136,28,The Audit and Risk Committee reports to the Board on the progress of our Modern Slavery Plan and identified risks,0,0,0,0,0,0,0,0,0,1,0 136,29,Potential Risks of Modern Slavery in our Supply Chains,0,0,0,0,0,0,0,0,0,0,0 136,30,"The risks of modern slavery practices means the potential for an entity to cause, contribute to, or be directly linked to modern slavery through its operations and supply chains in other words the risk that an entity may be involved in modern slavery",0,0,0,0,0,0,0,0,0,0,0 136,31,Our risk profile indicates that risks of modern slavery are more likely to occur further down the supply chain at Autosports Group,0,0,0,0,0,0,1,0,0,0,0 136,32,"Our focus in FY20 was on our highest value suppliers, namely our vehicle manufacturers (OEMs) and higher risk sectors such as cleaners, car washers and detailers",0,0,0,0,0,1,0,0,0,0,0 136,33,"In the case of OEMs, the risk of modern slavery is likely to occur in subsequent tiers of supply, however, this risk is mitigated by OEMs having their own anti-slavery policies and procedures in place",0,0,0,0,0,0,1,0,0,0,0 2824,111,"Develop and update our frameworks, policies and procedures We assess the effectiveness of our engagement activities and compliance with our policies and procedures regularly",0,0,0,0,0,0,0,0,0,0,0 2824,112,"As a result, we plan to review our existing risk management framework and associated policies to further embed modern slavery risk management into existing operational systems and processes (we receive independent assurance via an internal audit program on the adequacy and effectiveness of our risk management framework, and have internal controls in place to manage risk)",0,0,0,0,0,0,0,0,0,1,0 2824,113,The framework will be accompanied by a Modern Slavery Policy,0,0,0,0,0,0,0,1,0,0,0 2824,114,"Well also update any other relevant policies and procedures to help identify, assess and address modern slavery risks",0,0,0,0,0,0,0,1,0,0,0 2824,115,Training and culture In order to manage modern slavery risks well review training needs for all relevant employees and monitor compliance,0,0,0,0,0,0,0,0,0,1,0 2824,116,"Well also promote a confidential whistle-blower reporting hotline for employees, contractors and suppliers so they can freely raise concerns regarding suspected modern slavery practices",0,0,0,0,0,0,0,1,0,0,0 2824,117,Our modern slavery statement OUR ACTIONS TO ASSESS AND ADDRESS THE RISKS FY 2021 Actions undertaken to assess and address modern slavery risks within our internal operations and supply chains after 30 June 2020 will feature in our next statement (for the 2020-21 financial year),0,0,0,0,0,0,0,0,0,0,0 2824,118,Were committed to undertaking the following actions in the 2020-21 financial year,0,0,0,0,0,0,0,0,0,0,0 5169,7,The Companys Global Mineral Resource base comprises over 13.3 million ounces of gold,0,0,0,0,1,0,0,0,0,0,0 5169,8,"Resolutes flagship Syama Gold Mine is a world class long-life asset capable of producing more than 300,000 ounces of gold per annum",0,0,0,0,1,0,0,0,0,0,0 5169,9,The move to underground mining will continue the assets history of strong cash generation and extend the mine life to beyond 2032,0,0,0,0,1,0,0,0,0,0,0 5169,10,Resolute acquired the Mako Gold Mine in 2019,0,0,0,0,1,0,0,0,0,0,0 5169,11,"Mako is a high quality, low cost, open pit gold mine which hosts a Mineral Resource of 1.224Moz grading 1.89g/t Au, and an Ore Reserve of 928koz grading 2.05g/t Au",0,0,0,0,1,0,0,0,0,0,0 5169,12,"Resolute is targeting annual average production from Mako of 140,000 ounces",0,0,0,0,1,0,0,0,0,0,0 5169,13,"In Q3 2020, Makos life of mine was extended to 2027",0,0,0,0,1,0,0,0,0,0,0 5169,14,"In addition, Resolute is engaging in active exploration drilling campaigns across its African portfolio with a particular focus on Mali, Senegal, Cte dIvoire and Guinea",0,0,0,0,1,0,0,0,0,0,0 9313,25,"Registered office location Melbourne Offices in Sydney & Brisbane Project sites Port Augusta, Goyder, Queanbeyan, Flyers Creek, Uralla In Australia our four main operating departments are Transmission Lines, Solar, Wind and Energy",0,0,0,1,1,0,0,0,0,0,0 9313,26,"For the reporting period, Green Light Contractors employed approximately 160 people across its operations in Australia",0,0,0,1,0,1,0,0,0,0,0 9313,27,Modern Slavery Statement Supply chains Green Light Contractors supply chain is spread across the globe,0,0,0,0,0,1,0,0,0,0,0 9313,28,Our network of suppliers provides us with services and goods for our specialised projects across Australia,0,0,0,0,0,1,0,0,0,0,0 9313,29,"For the reporting period, the top 5 countries from which Green Light Contractors procured materials and equipment were as follows: 100.00% Total 21.81% China 10.56% USA 0.03% Italy 0.31% Spain 67.28% Australia Our top spend categories for goods and materials are: Photovoltaic Modules PV Inverter Stations PV Tracker System 33 kV Cable and Bare Earth Power Transformers Top 5 spend locations 10.56% USA 21.81% China 67.28% Australia 0.31% Spain 0.03% Italy",0,0,0,0,0,1,0,0,0,0,0 9313,30,Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 9313,31,Risks of modern slavery In the reporting period there were no incidents of actual or potential modern slavery identified in Green Light Contractors operations or supply chain,0,0,0,0,0,0,1,0,0,0,0 9313,32,Green Light Contractors acknowledges that each country in which it operates and from which it obtains materials and equipment carries with it the potential risk of situation of exploitation falling within the above definition of modern slavery,0,0,0,0,0,0,1,0,0,0,0 136,34,"Cleaners, car washers and detailers work in a high-risk sector that can often involve the use of unskilled and temporary labour and foreign workers",0,0,0,0,0,0,1,0,0,0,0 136,35,The COVID-19 pandemic has increased the risk of modern slavery due to business closures and suppliers to those businesses not being required (if not on a fixed contract) and changes in working hours with some workers being required to work more than usual,0,0,0,0,0,0,1,0,0,0,0 136,36,Due Diligence and Remediation During the reporting period we undertook several due diligence enquiries,0,0,0,0,0,0,0,0,0,0,0 136,37,"Through a consultation process with various managers, the Groups supply chains were mapped",0,0,0,0,0,0,0,1,0,0,0 136,38,We reviewed existing contracts and asked our suppliers in the focus areas to complete a due diligence questionnaire,0,0,0,0,0,0,0,1,0,0,0 136,39,The questionnaire asked questions about the suppliers awareness and procedures in relation to modern slavery risks,0,0,0,0,0,0,0,1,0,0,0 136,40,"For larger suppliers, we collected copies of modern slavery statements they prepared",0,0,0,0,0,0,0,1,0,0,0 136,41,We also checked our payroll records for instances of multiple employees living at the same address,0,0,0,0,0,0,0,1,0,0,0 2824,119,"FY 2022 and beyond For the 2021-22 financial year and beyond, were considering the following actions to assess and address modern slavery risks within our internal operations and supply chains",0,0,0,0,0,0,0,0,0,0,0 2824,120,"Review and where appropriate improve our due diligence, risk management, training and supplier engagement systems and processes to ensure modern slavery risks are effectively managed and mitigated",0,0,0,0,0,0,0,0,0,1,0 2824,121,establish and implement specific supplier monitoring programs for our higher risk suppliers,0,0,0,0,0,0,0,0,0,0,0 2824,122,"work with our higher risk suppliers who have their own suppliers to map the next tier of suppliers against geographic, commodity and industry modern slavery risk indicators",0,0,0,0,0,0,0,1,0,0,0 2824,123,"review the actions taken to identify, assess and address modern slavery risks and incorporate outcomes-focused performance indicators into review processes; and",0,0,0,0,0,0,0,0,0,1,0 2824,124,explore remedy pathways based on peer benchmarks and advocate for an industry approach,0,0,0,0,0,0,0,1,0,0,0 2824,125,630 692 UNISUPER.COM.AU,0,0,0,0,0,0,0,0,0,0,0 2824,126,How we assess the effectiveness of our actions Were committed to assessing the effectiveness of our actions in addressing the risks of modern slavery practices,0,0,0,0,0,0,0,0,0,0,0 5169,15,"Resolute is headquartered in Perth, Australia, with a corporate office in London, UK",0,0,0,1,1,0,0,0,0,0,0 5169,16,"Resolute employs approximately 1,146 employees and 3,189 contractors",0,0,0,1,0,0,0,0,0,0,0 5169,17,"Our Commitment Resolute is committed to respecting and protecting the human rights of all employees, contractors, suppliers, business partners and the communities that we interact with through the course of our business activities, and this includes eliminating all forms of modern slavery",0,0,0,0,0,0,0,0,0,0,0 5169,18,"We view this responsibility as not just an essential ethical business practice, but also key to ensuring we create long-term value for our shareholders, to promoting sustainable development in our host countries, and integral to maintaining our licence to operate",0,0,0,0,0,0,0,0,0,0,0 5169,19,"As an international mining company, we are cognisant that the risk of modern slavery exists within our business and supply chain, due to the nature and location of our activities, and the broader socio-political environments in which we operate",0,0,0,0,0,0,1,0,0,0,0 5169,20,"As a maturing company, we are committed to implementing and enforcing effective internal processes that aim to eliminate the risk of modern slavery both within our business and our supply chain",0,0,0,0,0,0,0,0,0,0,0 5169,21,"We understand that identifying instances of modern slavery, especially in areas where business relationships are further from core operations, will be complex, and that working collaboratively with governments and civil society can drive long lasting sustainable solutions",0,0,0,0,0,0,0,0,0,0,0 5169,22,Document Owner: Lead Document Controller (RSG) Page 2 of 7 Document Number: ADM-ADM-TMP-0022 Revision 1.02 Issue Date: 7/06/2021 Next Review:12 months Modern Slavery Voluntary Statement,0,0,0,0,0,0,0,0,0,0,0 9313,33,"The number of people recorded to be living in modern slavery per a global survey consists of: China Estimated 2.77 people living in modern slavery per 1000 - High Risk Italy - Estimated 2.43 people living in modern slavery per 1000 High Risk Spain - Estimated 2.27 people living in modern slavery per 1000 High Risk USA Estimated 1.26 people living in modern slavery per 1000 Medium Risk Australia - Estimated 0.65 people living in modern slavery per 1000 Low Risk https://www.globalslaveryindex.org/2018/data/ maps/#prevalence In our operations Green Light Contractors has assessed the risk of modern slavery in its direct operations as low, by virtue of its operations occurring solely in Australia, a country with a high standard and public expectation of corporate governance",0,0,0,0,0,0,1,0,0,0,0 9313,34,Green Light Contractors recognises however that incidences of modern slavery can and do still occur in Australia,0,0,0,0,0,0,0,0,0,0,0 9313,35,Green Light Contractors has strict employment processes in place to ensure the eradication of modern slavery in its workforce,0,0,0,0,0,0,0,0,0,0,0 9313,36,"Green Light Contractors ensures that all employees meet the National Employment Standards under Australian Law, additionally we review employee remuneration annually to ensure compliance with all applicable legislation",0,0,0,0,0,0,0,1,0,1,0 9313,37,Modern Slavery Statement The Green Light Contractors Human Resources Department regularly reviews the operational procedures and working conditions to ensure adherence to applicable standards and laws,0,0,0,0,0,0,0,0,0,1,0 9313,38,Green Light Contractors will from time to time engage with labour hire agencies in the Australian market,0,0,0,0,0,1,0,0,0,0,0 9313,39,These agencies are required to operate in compliance with all relevant legislation and laws,0,0,0,0,0,0,0,1,0,0,0 9313,40,This is enforced through Green Light Contractors agreements with recruitment and labour hire agencies,0,0,0,0,0,0,0,1,0,0,0 136,42,"Autosports Group provides employees, suppliers and their families with a confidential, independent whistleblowing service that is accessible 24/7, 365 days which can be used to report suspected cases of modern slavery",0,0,0,0,0,0,0,1,0,0,0 136,43,We adopted remediation guidelines that set out how Autosports Group will respond to a suspected case of modern slavery,0,0,0,0,0,0,0,0,1,0,0 136,44,The guidelines acknowledge that there is no one size fits all approach to remediation as each matter is unique and should be handled in a way that is proportionate to the harm and puts the victim first,0,0,0,0,0,0,0,0,1,0,0 136,45,Autosports Group has appointed a Modern Slavery Team responsible for handling complaints or suspected instances of modern slavery,0,0,0,0,0,0,0,0,1,0,0 136,46,Our policies and procedures Autosports Group developed a Supplier Code of Conduct which is available on our website and intended to set the minimum standards expected of our suppliers,0,0,0,0,0,0,0,1,0,0,0 136,47,Our legal team has developed a suite of contract clauses which can be used when contracting with new suppliers,0,0,0,0,0,0,0,1,0,0,0 136,48,We have developed a supplier on-boarding questionnaire to help assess the risks or issues associated with the supplier prior to contracting with them,0,0,0,0,0,0,0,1,0,0,0 136,49,This process will be rolled out in FY21,0,0,0,0,0,0,0,1,0,0,0 2824,127,"During the 2019-20 financial year we focused on actions that established our framework for identifying, assessing and reacting to modern slavery risks going forward",0,0,0,0,0,0,0,0,0,0,0 2824,128,"As identified by the actions weve taken to assess and address the risks detailed on pages 5 to 8, we established a modern slavery working group to oversee and monitor initial compliance with the Act",0,0,0,0,0,0,0,1,0,1,0 2824,129,"The ongoing function of monitoring and management of the risks will be carried out through the Financial Risk & Assurance Committee (FRAC), and integrated into policies and procedures which will be regularly reviewed",0,0,0,0,0,0,0,1,0,1,0 2824,130,Members of our modern slavery working group and other key employees successfully completed training on understanding and identifying modern slavery risks and practices,0,0,0,0,0,0,0,1,0,0,0 2824,131,The training facilitated the framework established by the working group which has provided the foundation for our ongoing modern slavery related compliance obligations,0,0,0,0,0,0,0,0,0,0,0 2824,132,Further training will be provided to relevant employees in the future,0,0,0,0,0,0,0,0,0,0,0 2824,133,"From an investment perspective, were confident with our approach to addressing modern slavery risks in our investments",0,0,0,0,0,0,0,0,0,0,0 2824,134,Stakeholder engagement is the centrepiece of our approach to ESG,0,0,0,0,0,0,0,0,0,0,0 5169,23,"Our Supply Chain Resolute works across the whole spectrum of the gold mining value chain including exploration, development, mining, processing, rehabilitation and closure",0,0,0,0,0,0,0,0,0,0,0 5169,24,"We partner with a range of suppliers and contractors that provide mining plant, infrastructure, spare parts, consumables, specialist services, security, catering and related services",0,0,0,0,0,1,0,0,0,0,0 5169,25,Many of the critical goods and services required to operate a mine are highly specialised and may only be available from international suppliers,0,0,0,0,0,1,0,0,0,0,0 5169,26,"Subject to availability, we source goods and services from national suppliers and where possible from the local regions in which we operate",0,0,0,0,0,1,0,0,0,0,0 5169,27,The procurement of goods and services is performed at both corporate and site level,0,0,0,0,0,1,0,0,0,0,0 5169,28,Our Approach Resolute is a maturing organisation and recognises the need to review its internal processes to ensure modern slavery risks are effectively identified and mitigated,0,0,0,0,0,0,0,0,0,0,0 5169,29,"Resolutes approach to addressing the risks caused by modern slavery in its business and supply chain will be founded on its capacity to establish robust systems for corporate governance, policies & procedures, risk identification and management, training and awareness, stakeholder engagement, and performance review",0,0,0,0,0,0,0,0,0,0,0 5169,30,Human Rights is a Strategic Priority Area under the Governance & Integrity Pillar of Resolutes Sustainability Strategy,0,0,0,0,0,0,0,0,0,0,0 9313,41,In supply chains Green Light Contractors operates in the energy sector,0,0,0,0,1,0,0,0,0,0,0 9313,42,Due to the complex nature of the energy supply chain there may be risks that Green Light Contractors is linked to exploitative worker relationships indirectly via its supply chain,0,0,0,0,0,0,1,0,0,0,0 9313,43,Modern Slavery Statement Green Light Contractors has a framework in place to mitigate the risk of Modern Slavery in its operations and supply chain,0,0,0,0,0,0,0,0,0,0,0 9313,44,"Green Light Contractors Polices and Standards Green Light Contractors has policies and standards in place that require the workforce, sub-contractors and suppliers to act ethically at all times",0,0,0,0,0,0,0,1,0,0,0 9313,45,"Special mention is made of its Code of Ethics and Conduct for Suppliers, Subcontractors and Collaborators, that constitutes an essential tool to encourage its suppliers, subcontractors and collaborators to conduct their professional pursuits in accordance with only the best business practices and the highest ethical standards, particularly in the fields of ethics and integrity, respect for human, social and labour rights, health and safety, environment protection and quality",0,0,0,0,0,0,0,1,0,0,0 9313,46,"Apart from this code, these polices and standards include",0,0,0,0,0,0,0,1,0,0,0 9313,47,Code of Conduct and Ethics,0,0,0,0,0,0,0,1,0,0,0 9313,48,Diversity and Equal Opportunity Policy,0,0,0,0,0,0,0,1,0,0,0 136,50,Our employee on-boarding procedures were updated to flag potential modern slavery risks,0,0,0,0,0,0,0,1,0,0,0 136,51,Autosports Group maintains a number of policies that support the Groups efforts in addressing modern slavery risks,0,0,0,0,0,0,0,1,0,0,0 136,52,"Our Whistleblower Policy, Grievance Policy, Code of",0,0,0,0,0,0,0,1,0,0,0 136,53,Conduct and Communications Policy were all updated to address modern slavery risks,0,0,0,0,0,0,0,1,0,0,0 136,54,These amendments were reviewed and approved by the Board,0,0,0,0,0,0,0,1,0,0,0 136,55,Education and training Our legal team provided training to managers across the business that are involved in procurement,0,0,0,0,0,0,0,1,0,0,0 136,56,A consultation process with our wholly owned subsidiary businesses was undertaken to draft this statement,0,0,0,0,0,0,0,0,0,0,1 136,57,Autosports Group businesses have adopted a risk-based approach to modern slavery due diligence and have primarily focused its modern slavery compliance obligations in regard to its direct employees and tier one supply chains,0,0,0,0,0,0,0,1,0,0,0 2824,135,Weve found Stakeholder engagement is the centrepiece of our approach to ESG,0,0,0,0,0,0,0,0,0,0,0 2824,136,that companies are generally very responsive to constructive feedback on their ESG approach,0,0,0,0,0,0,0,0,0,0,0 2824,137,"Some of the ESG improvements include climate change (improved disclosure and measurement of emissions, implementing emission reduction practices and technologies, more ambitious targets), remuneration practices (lower quantum, better alignment of incentives to performance) and board composition (greater gender balance, skills assessment, independence)",0,0,0,0,0,0,0,0,0,0,0 2824,138,We believe that modern slavery risk is evolving in a similar way,0,0,0,0,0,0,0,0,0,0,0 2824,139,The mandatory reporting regime in the UK provided focus for investors with UK exposure,0,0,0,0,0,0,0,0,0,0,0 2824,140,Australias new reporting requirements make it compulsory for ASX listed companies and their investors to address these issues,0,0,0,0,0,0,0,0,0,0,0 2824,141,"As knowledge improves over time, company practices will evolve, disclosure will increase, and investor focus will grow",0,0,0,0,0,0,0,0,0,0,0 2824,142,"Like other ESG issues, we expect variation in practices will be revealed, leading to greater investor attention to improve overall practices",0,0,0,0,0,0,0,0,0,0,0 5169,31,Corporate Governance Resolute has a strong corporate governance framework that ensures an efficient oversight of all business operations,0,0,0,0,0,0,0,1,0,0,0 5169,32,The Board has ultimate responsibility for ensuring that material risks faced by the Company are identified and that appropriate control and monitoring systems are in place,0,0,0,0,0,0,0,1,0,0,0 5169,33,The Audit and Risk Committee is mandated by the Board to provide risk management oversight across material risks,0,0,0,0,0,0,0,1,0,0,0 5169,34,"The Audit and Risk Committee works closely with management in relation to the assessment, monitoring and ongoing management of business risk across all time horizons and to carry out assessments of internal controls and processes for improvement",0,0,0,0,0,0,0,1,0,0,0 5169,35,"In support of this, the Audit and Risk Committee receives reports from management on new and emerging sources of risk, related controls and mitigation measures that management have implemented",0,0,0,0,0,0,0,1,0,1,0 5169,36,Document Owner: Lead Document Controller (RSG) Page 3 of 7 Document Number: ADM-ADM-TMP-0022 Revision 1.02 Issue Date: 7/06/2021 Next Review:12 months Modern Slavery Voluntary Statement The governance and oversight responsibility for our sustainability strategy is assigned to the Sustainability Committee,0,0,0,0,0,0,0,1,0,0,0 5169,37,"The Committee is chaired by the CEO and consists of several non-executive directors who each have diverse knowledge, skills and experience within the remit of the Committee",0,0,0,0,0,0,0,1,0,0,0 5169,38,"The focus of the Committee is guided by the Sustainability Committee Charter which broadly covers all health, safety, security, environment and community (HSSEC) and people matters",0,0,0,0,0,0,0,0,0,0,0 9313,49,Human Rights Policy,0,0,0,0,0,0,0,1,0,0,0 9313,50,Modern Slavery Policy We require all subcontractors and suppliers to comply with the Green Light Contractors policies in our subcontractor and supplier agreements,0,0,0,0,0,0,0,1,0,0,0 9313,51,"Green Light Contractors encourages disclosures of any potential or suspected unethical, illegal, or unsatisfactory conduct that involves any of the business activities including human rights violations",0,0,0,0,0,0,0,1,0,0,0 9313,52,We encourage disclosures of misconduct through our whistle blower policy,0,0,0,0,0,0,0,1,0,0,0 9313,53,Green Light Contractors has in place a Whistleblower Policy to ensure concerns can be raised anonymously,0,0,0,0,0,0,0,1,0,0,0 9313,54,Green Light Contractors is committed to engaging in continuous improvement and awareness around Modern Slavery Practices,0,0,0,0,0,0,0,0,0,0,0 9313,55,Actions to assess and address the risks,0,0,0,0,0,0,0,0,0,0,0 9313,56,Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 136,58,Autosports Group has assessed the effectiveness of its actions in FY20 by reference to stakeholder awareness,0,0,0,0,0,0,0,0,0,1,0 136,59,Autosports Groups manager training and due diligence questionnaires were particularly effective at raising awareness of modern slavery risks amongst our managers and suppliers within the selected focus areas,0,0,0,0,0,0,0,0,0,1,0 136,60,Next steps The Board has adopted a Modern Slavery Plan for FY21 which will build on the work done in FY20,0,0,0,0,0,0,0,0,0,0,0 136,61,This Modern Slavery Statement was approved by the Board on 27 August 2020,1,0,0,0,0,0,0,0,0,0,0 136,62,______________________ ______________________ Thomas (Tom) Pockett Nicholas Pagent Chairman Chief Executive Officer,0,1,0,0,0,0,0,0,0,0,0 241,0,MODERN SLAVERY STATEMENT 2020,0,0,0,0,0,0,0,0,0,0,0 241,1,SEPTEMBER 2020,0,0,0,0,0,0,0,0,0,0,0 241,2,SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 1 An Opportunity for All: Removing Slavery from the Supply Chain,0,0,0,0,0,0,0,0,0,0,0 2824,143,USM developed this Statement in consultation with USL as trustee of the Fund and many of the entities that USL as trustee of the Fund owns or controls,0,0,0,0,0,0,0,0,0,0,1 2824,144,A list of the entities that USL owns or controls is contained in the Funds full audited accounts for the 2019-20 financial year,0,0,0,0,0,0,0,0,0,0,0 2824,145,You can request a copy of this by calling 1800 331 685,0,0,0,0,0,0,0,0,0,0,0 2824,146,"Our consultation process Were committed to developing and maintaining a robust, group-wide response to modern slavery",0,0,0,0,0,0,0,0,0,0,0 2824,147,"630 692 UNISUPER.COM.AU In preparing this Statement, the relevant directors and officers of USL, USM and many of the entities USL owns or controls were consulted and provided with an opportunity to review the Statement prior to approval",0,0,0,0,0,0,0,0,0,0,1 2824,148,Our modern slavery statement APPENDIX Appendix Identifying our modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 2824,149,1800 630 692 UNISUPER.COM.AU AREA MODERN SLAVERY RISKS IDENTIFIED Internal operations Internal investments Over two-thirds of our funds under management are managed internally,0,0,0,0,1,0,0,0,0,0,0 2824,150,"On an overarching thematic review, our internally managed investment portfolio includes both active and passive investments in equity markets, property, private equity and infrastructure across numerous countries",0,0,0,0,1,0,0,0,0,0,0 5169,39,This includes the adequacy of all systems in place to effectively manage ESG and regulatory risk and opportunity across the Company,0,0,0,0,0,0,0,0,0,0,0 5169,40,"In 2020, the Charter was updated with specific reference made to diversity and inclusion, climate change and human rights governance",0,0,0,0,0,0,0,1,0,0,0 5169,41,"Resolutes corporate governance framework enables Board and executive action so that human rights and modern slavery risks in the business and supply chains are promptly identified, addressed and remediated to ensure human rights are respected and protected across all operations and projects",0,0,0,0,0,0,0,0,0,0,0 5169,42,The Sustainability Committee guides the Remuneration Committee in the setting of short and long-term sustainability targets and assists with assessments of performance against these metrics,0,0,0,0,0,0,0,0,0,1,0 5169,43,The Committee recommends to the Board the adoption of initiatives to drive continual improvement in sustainability performance at Resolute,0,0,0,0,0,0,0,0,0,1,0 5169,44,Sustainability considerations have been incorporated into both short-term and long-term incentive plans and are linked to assessments of executive performance at Resolute in 2021 going forward,0,0,0,0,0,0,0,0,0,1,0 5169,45,"Resolutes executive team report performance on sustainability matter, including human rights, to the Committee at each of its four meetings per year",0,0,0,0,0,0,0,0,0,1,0 5169,46,Policies & Procedures Resolute is committed to being a responsible corporate citizen and to creating a culture of ethical behaviour as set in its Code of Conduct,0,0,0,0,0,0,0,0,0,0,0 9313,57,Assessing the effectiveness of actions,0,0,0,0,0,0,0,0,0,0,0 9313,58,Process of consultation,0,0,0,0,0,0,0,0,0,0,0 9313,59,"Approval As part of this reporting period, Green Light Contractors concentrated on the risks of modern slavery within its supply chain and improved its understanding of them",0,0,0,0,0,0,0,0,0,0,0 9313,60,"To reduce slavery risks in its operations and supply chain, Green Light Contractors analysed risks and used its processes",0,0,0,0,0,0,0,0,0,0,0 9313,61,"By using these measures, Green Light Contractors can identify suppliers and subcontractors who may be subject to modern slavery and advise prior to engaging with suppliers that modern slavery is unacceptable",0,0,0,0,0,0,0,0,0,0,0 9313,62,"This Statement was prepared in consultation with Green Light Contractors Human Resources, Finance and Quality / Environment teams",0,0,0,0,0,0,0,0,0,0,0 9313,63,"In accordance with section 13 of the Modern Slavery Act, this statement was approved by the Board of Green Light Contractors Pty Ltd on 29 June 2022",1,0,0,0,0,0,0,0,0,0,0 9313,64,"Additionally, Green Light Contractors are building more effective tools to measure the effectiveness of the mitigation measures used, in addition to continuing to improve detection, escalation, and other mitigation capabilities",0,0,0,0,0,0,0,0,0,0,0 241,3,"SRG Global Limited (SRG) opposes the oppression and abuse of human rights, including the use of forced labour and slavery",0,0,0,0,0,0,0,0,0,0,0 241,4,This statement has been prepared and approved by the Board of Directors of SRG Global Limited (Australian registered Company Number 104 662 259)1 and on behalf of its related body corporate in accordance with the Commonwealth of Australias Modern Slavery Act 2018 and provides our commitment to continuously review and implement steps to eradicate human rights abuses from all aspects of our supply chain,1,0,1,0,0,0,0,0,0,0,0 241,5,"Described as the severe exploitation of people for personal or commercial gain, Modern Slavery entraps more than 175 million2 victims in global supply chains where they are exposed to unacceptable working conditions",0,0,0,0,0,0,0,0,0,0,0 241,6,"Importantly, the term Modern Slavery is not limited to physical restrictions",0,0,0,0,0,0,0,0,0,0,0 241,7,"Increasingly, circumstances of debt bondage, abuse of minimum wage payments, discriminatory employment practices, coercion, threats and deception are other further examples of exploitation methods used by those profiteering through oppressive circumstances",0,0,0,0,0,0,0,0,0,0,0 241,8,"SRG recognises that as an organisation we have a responsibility to diligently identify and address exposures within our Supply Chain, importantly however, we understand this issue cannot be addressed solely by our actions but rather through the support of and engagement with Governments, Business and through Social Dialogue with key stakeholders,: Governments set policy and laws, such as the Modern Slavery Act 2018 (Cth), which provides actions to guide and support businesses in the eradication of slavery practices within their operations and supply chains",0,0,0,0,0,0,0,0,0,0,0 241,9,Business holds a responsibility to remain diligent to ensure all aspects of their operations and supply chain is free from slavery practices,0,0,0,0,0,0,0,0,0,0,0 241,10,"Social Dialogue including engagement with stakeholders, the community and industry bodies",0,0,0,0,0,0,0,0,0,0,0 2824,151,There are a wide range of investment related activities that can vary on a day to day basis,0,0,0,0,1,0,0,0,0,0,0 2824,152,These activities include,0,0,0,0,1,0,0,0,0,0,0 2824,153,the formulation and monitoring of investment objectives and strategies,0,0,0,0,1,0,0,0,0,0,0 2824,154,"the selection, appointment and ongoing management of investment managers, custodians and other service providers",0,0,0,0,1,0,0,0,0,0,0 2824,155,the selection and ongoing management of direct investments,0,0,0,0,1,0,0,0,0,0,0 2824,156,"the calculation and analysis of investment returns, and",0,0,0,0,1,0,0,0,0,0,0 2824,157,the production and verification of investment information before release to members,0,0,0,0,1,0,0,0,0,0,0 2824,158,"Our Core Investment Governance and Risk Framework document outlines and refers to the various systems, structures, policies, processes and personnel in relation to investment-related activities, including the generation of returns to meet investment objectives and the monitoring and management of investment risk",0,0,0,0,0,0,0,1,0,0,0 5169,47,"The Code of Conduct ensures that all personnel comply with legal and ethical standards, and promote the principles of integrity, honesty and respect in the performance of their duties",0,0,0,0,0,0,0,1,0,0,0 5169,48,"All contractors and suppliers are also bound by the Code of Conduct, as included in Resolutes standard contractual terms and conditions, ensuring comparable business practices and workplace standards are maintained",0,0,0,0,0,0,0,1,0,0,0 5169,49,Its application is strengthened by a Whistleblower Policy that provides reporting channels for employees and contractors to report inappropriate conduct,0,0,0,0,0,0,0,1,0,0,0 5169,50,"These policies are central to creating a business environment where human rights are respected, and where modern slavery practices are systematically identified and mitigated",0,0,0,0,0,0,0,0,0,0,0 5169,51,"Resolutes policies and procedures are reviewed annually, approved by the Board and are consistent with principles of equal opportunity and fair treatment",0,0,0,0,0,0,0,0,0,1,0 5169,52,"All personnel must adhere to the Equal Employment Opportunity Anti- Discrimination, Anti-Bullying and Anti-Harassment Procedure and the responsibility it places on employees to respect the rights of individuals",0,0,0,0,0,0,0,0,0,0,0 5169,53,Personnel are responsible for upholding this procedure and eliminating any practices and,0,0,0,0,0,0,0,0,0,0,0 5169,54,"Document Owner: Lead Document Controller (RSG) Page 4 of 7 Document Number: ADM-ADM-TMP-0022 Revision 1.02 Issue Date: 7/06/2021 Next Review:12 months Modern Slavery Voluntary Statement behaviour which are discriminatory, or which could lead to discrimination, workplace bullying or harassment in the workplace",0,0,0,0,0,0,0,0,0,0,0 9313,65,Samuel Basanta Lopez - Operations Director,0,1,0,0,0,0,0,0,0,0,0 10291,0,Modern Slavery Statement FY22,0,0,0,0,0,0,0,0,0,0,0 10291,1,"Atturra Modern Slavery Statement FY22 About this statement This joint Modern Slavery Statement (Statement) has been prepared and approved pursuant to Section 14 of the Modern Slavery Act 2018 (Cth) (the Act), by Atturra Limited (ACN 654 662 638) (Atturra we, us and our)",0,0,1,0,0,0,0,0,0,0,0 10291,2,This Statement covers the financial year reporting period from 1 July 2021 to 30 June 2022 (Reporting Period),0,0,0,0,0,0,0,0,0,0,0 10291,3,This is our first statement in relation to modern slavery,0,0,0,0,0,0,0,0,0,0,0 10291,4,"This statement sets out the process taken by Atturra to identify, assess and address the risks of modern slavery in our operations and supply chains as defined by the Act",0,0,0,0,0,0,0,0,0,0,0 10291,5,Atturra is listed on the Australian Securities Exchange (ASX code: ATA) with headquarters in Sydney,0,0,0,1,0,0,0,0,0,0,0 10291,6,"For further information, please visit www.atturra.com",0,0,0,0,0,0,0,0,0,0,0 241,11,"Core to the success of any practices implemented by organisations is that the practices both align with, and are supported by, the broader community",0,0,0,0,0,0,0,0,0,0,0 241,12,This statement sets our policy and governance framework for the detection and abolishment of these practices within SRGs operations or supply chains,0,0,0,0,0,0,0,0,0,0,0 241,13,This statement was approved by the Board of SRG Global Limited on 15 December 2020,1,0,0,0,0,0,0,0,0,0,0 241,14,Peter McMorrow Chairman SRG Global Limited,0,1,0,0,0,0,0,0,0,0,0 241,15,SRG Global Limited (ACN: 104 662 259) is the ultimate holding company of the SRG Global Group of companies as listed in Appendix A of this Statement,0,0,0,1,0,0,0,0,0,0,0 241,16,"Statistics taken from 2019 8.7 Alliance Report Ending child labour, forced labour and human trafficking in global supply chains Social Engagement Business Government",0,0,0,0,0,0,0,0,0,0,0 241,17,"SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 2 About SRG SRG was born out of Australias greatest ever engineering and construction challenge, the Snowy Mountains Hydro-electric Scheme, in 1961",0,0,0,0,0,0,0,0,0,0,0 241,18,"Today, SRG (ACN 104 662 259) is a public company listed on the Australian Stock Exchange with a diversified operations base comprising of",0,0,0,1,0,0,0,0,0,0,0 2824,159,"As a responsible investor, we assess ESG factors across every investment we make",0,0,0,0,0,0,0,0,0,0,0 2824,160,We seek to understand the ESG issues of our investments to gain greater insights into our investment decisions and understand the risks and opportunities of our investments,0,0,0,0,0,0,0,0,0,0,0 2824,161,"One of our priority ESG themes is workforce issues, incorporating modern slavery and supply chains",0,0,0,0,0,0,0,0,0,0,0 2824,162,"Weve adopted a risk-based approach, using both geographic and sectoral exposures of our investments",0,0,0,0,0,0,0,1,0,0,0 2824,163,"During the 2019-20 financial year, we undertook a high-level thematic review of our internally managed investment portfolio and suppliers to identify general areas of modern slavery risk",0,0,0,0,0,0,0,1,0,0,0 2824,164,"Generally, our investments are mainly in developed markets, dominated by Australia",0,0,0,0,0,0,1,0,0,0,0 2824,165,"Our international holdings are mainly in listed equities and fixed interest domiciled in developed countries, with low exposure to developing countries (mainly Asia)",0,0,0,0,0,0,1,0,0,0,0 2824,166,"While our geographic exposure to high risk countries is therefore low, we also consider our exposure to industries with higher risks of modern slavery",0,0,0,0,0,0,1,0,0,0,0 5169,55,"At Syama and Mako, we have employee representative committees whose members have been elected by the workforce to represent them in discussions and negotiations with site management",0,0,0,0,0,0,0,1,0,0,0 5169,56,All employees also have access to a grievance mechanism should they wish to file a complaint,0,0,0,0,0,0,0,1,0,0,0 5169,57,"Significant progress was made in 2020 to ensure Resolutes corporate policy framework establishes a clear and consistent pathway for improved sustainability performance commensurate with the World Gold Councils Responsible Gold Mining Principles, company strategy and stakeholder expectations",0,0,0,0,0,0,0,1,0,0,0 5169,58,All existing sustainability polices were updated and published on Resolute's website,0,0,0,0,0,0,0,1,0,0,0 5169,59,"These include a new Human Rights Policy, and a Diversity & Inclusion Policy",0,0,0,0,0,0,0,1,0,0,0 5169,60,"In addition, an updated Community Complaints & Grievance Procedure was issued to include a human rights flag, and provides the pathway for any human rights related complaint to be escalated to the Executive Committee",0,0,0,0,0,0,0,1,0,0,0 5169,61,This renewed policy framework has been developed to guide our approach to responsible mining across all levels of the Company and enable the achievement of our sustainability strategy,0,0,0,0,0,0,0,1,0,0,0 5169,62,"In 2021, we are updating all relevant corporate level policies to align with the UN Guiding Principles on Business and Human Rights, the Voluntary Principles of Security & Human Rights and other leading Human Rights frameworks",0,0,0,0,0,0,0,1,0,0,0 10291,7,"As at 30 June 2022, Atturra comprised of 33 controlled entities",0,0,0,1,0,0,0,0,0,0,0 10291,8,The ultimate parent entity of Atturra is Atturra Limited,0,0,0,1,0,0,0,0,0,0,0 10291,9,"The entities that sit below Atturra Limited are the individual business lines, each an incorporated entity, and which together comprise of Atturra",0,0,0,1,0,0,0,0,0,0,0 10291,10,Please see Figure 1 for Atturras Corporate Structure,0,0,0,0,0,0,0,0,0,0,0 10291,11,All entities within Atturra are required to comply with the same policies and processes and the same suppliers are often shared,0,0,0,0,0,0,0,0,0,0,0 10291,12,"However, each entity comprises unique characteristics in its operations and supply chain",0,0,0,0,0,0,0,0,0,0,0 10291,13,The procedures and processes for onboarding new suppliers is the same across all entities,0,0,0,0,0,0,0,0,0,0,0 10291,14,Atturra consulted the relevant companies it owns or controls in the development of this Statement,0,0,0,0,0,0,0,0,0,0,1 241,19,ASSET SERVICES Sustaining complex infrastructure SPECIALIST MAINTENANCE Highly skilled specialist maintenance services ACCESS SOLUTIONS Comprehensive structural and technical access solutions,0,0,0,0,0,0,0,0,0,0,0 241,20,MINING SERVICES Comprehensive ground solutions PRODUCTION DRILL & BLAST Integrated range of complementary production drill & blast services SPECIALIST GEOTECH Highly technical specialist ground and slope stabilisation services,0,0,0,0,1,0,0,0,0,0,0 241,21,"CONSTRUCTION Constructing complex infrastructure CIVIL & ENGINEERING Specialist engineering, post tensioning and construction services SPECIALIST BUILDING Specialist faade and structural construction and remediation services",0,0,0,0,0,0,0,0,0,0,0 241,22,"Our specialist technical capabilities, diversified services and global experience working on iconic skyscrapers, bridges, dams, structures, transport infrastructure, mining and oil and gas projects, means there is no complex challenge we cannot resolve",0,0,0,0,1,0,0,0,0,0,0 241,23,"Working across the entire asset lifecycle, we provide bespoke Engineer, Construct and Sustain solutions, our team incorporating every discipline and skill required to meet the challenges our customers set",0,0,0,0,0,0,0,0,0,0,0 241,24,SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 3,0,0,0,0,0,0,0,0,0,0,0 241,25,"Headquartered in Perth, Western Australia, our unique and diverse skillset has driven us to a global footprint with current operations located in Australia, New Zealand, the United States of America3, the United Arab Emirates, Oman Bahrain, Qatar, South Africa and the United Kingdom employing more than 2000 people worldwide",0,0,0,1,1,0,0,0,0,0,0 241,26,"As of the date of this statement, SRGs operations in the United States of America will be conducted remotely from Australia in conjunction with our local partner",0,0,0,0,1,0,0,0,0,0,0 2824,167,"In relation to assessing our investments, we focussed on ASX listed companies in the consumer staples, consumer discretionary and transportation sectors, and included meetings with executives or board members",0,0,0,0,0,0,0,1,0,0,0 2824,168,"We covered issues such as underpayments of employees, supply chain monitoring (particularly in the horticulture sector), audit outcomes and disclosure",0,0,0,0,0,0,0,1,0,0,0 2824,169,Investor engagement has resulted in improvements with,0,0,0,0,0,0,0,1,0,0,0 2824,170,more structured oversight and reporting of employee conditions in franchising companies,0,0,0,0,0,0,0,1,0,0,0 2824,171,"supermarket chains raising the bar for their horticultural suppliers by setting clear expectations on the use of labour-hire providers, and",0,0,0,0,0,0,0,1,0,0,0 2824,172,the introduction of regular auditing programs and improved whistleblowing systems to support ongoing compliance,0,0,0,0,0,0,0,1,0,0,0 2824,173,"Our modern slavery statement APPENDIX AREA MODERN SLAVERY RISKS IDENTIFIED Internal operations Other investment service providers (eg custodians, brokers, data providers, valuers) We did not consider the potential modern slavery risks within this area to be high",0,0,0,0,0,0,1,0,0,0,0 2824,174,They involve the provision of specialised professional services and are provided predominately from Australia,0,0,0,0,0,0,1,0,0,0,0 5169,63,Risk Identification & Management Resolute adopts a consistent approach to both corporate and asset-level risk management,0,0,0,0,0,0,0,1,0,0,0 5169,64,Significant residual operational risks are integrated into our Enterprise Risk Management Framework (ERMF) which is reviewed regularly by the Resolute executive team and overseen by the Audit and Risk Committee of the Board,0,0,0,0,0,0,0,1,0,1,0 5169,65,"The ERMF prescribes the methodology, minimum performance standards and risk appetite applicable to the assessment and treatment of strategic, corporate, operational, ESG and project risk and opportunity",0,0,0,0,0,0,0,0,0,0,0 5169,66,The Committee provides oversight and guidance to the assessment and treatment of actual and emerging ESG risks and opportunities across the Company,0,0,0,0,0,0,0,0,0,1,0 5169,67,"In 2020, the Charter was updated to include specific reference to human rights",0,0,0,0,0,0,0,1,0,0,0 5169,68,"ESG risks and opportunities are discussed as a standing agenda item at all meetings of the Committee, with key actual or emerging risks escalated to the Board as required",0,0,0,0,0,0,0,0,0,1,0 5169,69,The below figure outlines Resolutes ERMF,0,0,0,0,0,0,0,0,0,1,0 5169,70,Document Owner: Lead Document Controller (RSG) Page 5 of 7 Document Number: ADM-ADM-TMP-0022 Revision 1.02 Issue Date: 7/06/2021 Next Review:12 months Modern Slavery Voluntary Statement,0,0,0,0,0,0,0,0,0,0,0 10291,15,"For clarification, each of Atturras controlled entities are covered under this joint Statement and when referring to Atturra in this Statement, it includes all the entities set out under Figure 1 (collectively referred to as Atturra)",0,0,0,0,0,0,0,0,0,0,0 10291,16,"The consolidation of the revenue of the entities owned by Atturra Limited triggers the requirement under the Act of entities over a $100 million annual consolidated revenue threshold that are either classed as an Australian entity or a foreign entity carrying on business in Australia during the reporting period, to prepare and publish an annual Modern Slavery Statement",0,0,0,0,0,0,0,0,0,0,0 10291,17,We are proud to share with our stakeholders our commitment to addressing modern slavery and we recognise that we will require a culture of continuous improvement over a number of years,0,0,0,0,0,0,0,0,0,0,0 10291,18,We intend to work in partnership with our stakeholders to promote ethical practices to reduce the risks of modern slavery in our operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 10291,19,"Our structure, operations and supply chain Structure Atturra is an ASX-listed technology services business",0,0,0,0,1,0,0,0,0,0,0 10291,20,"Atturra is a leader in designing, implementing, and maintaining IT solutions for many of Australias largest private and public entities",0,0,0,0,1,0,0,0,0,0,0 10291,21,"Atturra offers consulting, IT services and technology solutions to accelerate digital transformation in the growing Australian IT services market",0,0,0,0,1,0,0,0,0,0,0 10291,22,Atturra Limited is the parent of several other Australian com- panies that ultimately form the Atturra business,0,0,0,1,0,0,0,0,0,0,0 241,27,"SRG has completed previous campaign projects in Hong Kong, Indonesia, Ireland, Lesotho, Malaysia, Panama, Papua New Guinea, Singapore, Sudan, Thailand and Zambia",0,0,0,0,1,0,0,0,0,0,0 241,28,No current or permanent locations are in these territories,0,0,0,0,1,0,0,0,0,0,0 241,29,SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 4 Managing the Risk of Modern Slavery at SRG Global Governance and Policies SRG recognises the importance of developing a clear structure for the management of its businesses to protect human rights and the abolishment of slavery practices,0,0,0,0,0,0,0,0,0,0,0 241,30,"Pursuant to our 2020 Corporate Governance Statement, our Board has developed a framework for the management of SRG Global including the adoption of corporate governance practices, the implementation of internal controls and risk management processes",0,0,0,0,0,0,0,0,0,0,0 241,31,The SRG Boards role is to represent and serve the interests of shareholders and the expectations of our stakeholders through the oversight and appraisal of SRGs operations,0,0,0,0,0,0,0,0,0,0,0 241,32,This includes the setting and review of compliance systems commensurate to our values and governance framework,0,0,0,0,0,0,0,0,0,0,0 241,33,"Delegation of SRGs management is passed to our Managing Director, who in association with SRGs Officers implement the strategic objectives and plans as approved by the Board",0,0,0,1,0,0,0,0,0,0,0 241,34,"Through the Managing Director, SRGs Executive Leadership Team is accountable for the implementation and delivery of the Organisations strategic directions",0,0,0,1,0,0,0,0,0,0,0 2824,175,We will look to assess and address any possible risks in a future reporting year,0,0,0,0,0,0,1,0,0,0,0 2824,176,Operating superannuation (accumulation and pension) products We did not consider the potential modern slavery risks within this area to be high,0,0,0,0,0,0,0,0,0,0,0 2824,177,We will look to assess and address any possible risks in a future reporting year,0,0,0,0,0,0,0,0,0,0,0 2824,178,Administering all superannuation (accumulation and pension) products We did not consider the potential modern slavery risks within this area to be high,0,0,0,0,0,0,0,0,0,0,0 2824,179,We will look to assess and address any possible risks in a future reporting year,0,0,0,0,0,0,0,0,0,0,0 2824,180,Providing inbuilt benefits and offering external insurance to members We did not consider the potential modern slavery risks within this area to be high,0,0,0,0,0,0,0,0,0,0,0 2824,181,We will look to assess and address any possible risks in a future reporting year,0,0,0,0,0,0,0,0,0,0,0 2824,182,Providing general and personal financial product advice to members and their families via UniSuper Advice We did not consider the potential modern slavery risks within this area to be high,0,0,0,0,0,0,0,0,0,0,0 5169,71,Resolute considers human rights compliance to be a material issue and human rights and associated modern slavery risks feature prominently in Resolutes risk management processes,0,0,0,0,0,0,0,0,0,0,0 5169,72,"The level of risk depends on key intersecting factors including geography, services and employment practices and supplier capacity",0,0,0,0,0,0,0,1,0,0,0 5169,73,These are outlined in further detail below,0,0,0,0,0,0,0,1,0,0,0 5169,74,"Geography Exposure to modern slavery risks will be correlated to the social, political and environmental conditions in the countries in which Resolute and its suppliers operate",0,0,0,0,0,0,0,0,0,0,0 5169,75,"Using indicators to assess prevalence, vulnerability and the effectiveness of government responses to address modern slavery in these countries will be central to understanding the level of risk and to prioritising interventions",0,0,0,0,0,0,0,1,0,0,0 5169,76,"Country Global prevalence index ranking Estimated number of people living in modern slavery Vulnerability to modern slavery Estimated proportion of the population living in modern slavery Government response rating Australia 163/167 15,000 4.27/100 0.65/1000 BBB United Kingdom 132/167 136,000 11.13/100 2.08/1000 BBB* Mali 95/167 62,000 55.88/100 3.7/1000 CCC Senegal 109/167 43,000 46.20/100 2.87/1000 B Ghana 71/167 133,000 51.16/100 4.84/1000 CC Cote dIvoire 56/167 137,000 57.20/100 5.91/1000 B Guinea 28/167 94,000 66.33/100 7.80/1000 C *The lower the score in the global prevalence index ranking, the higher the prevalence of modern slavery Prevalence of modern slavery in the countries in which Resolute operates (Global Slavery Index 2018, Walk Free Foundation)",0,0,0,0,0,0,1,0,0,0,0 5169,77,"Document Owner: Lead Document Controller (RSG) Page 6 of 7 Document Number: ADM-ADM-TMP-0022 Revision 1.02 Issue Date: 7/06/2021 Next Review:12 months Modern Slavery Voluntary Statement In both Senegal and Mali, we have actively established links between our international suppliers and local distributors thus enabling Resolute to source goods onshore and in so doing, strengthen the local supply chain which will facilitate the identification of human rights and modern slavery risks",0,0,0,0,0,0,0,1,0,0,0 5169,78,Services & Employment Practices Exposure to modern slavery risk is also specific to the production of certain goods and services due to sector specific pressures and labour force structures,0,0,0,0,0,0,0,0,0,0,0 10291,23,"Our mission is to become a leading Australian IT solutions provider with high engagement across industries, employees and clients",0,0,0,0,0,0,0,0,0,0,0 10291,24,"Atturras registered office is Level 33, 88 Phillips Street, Sydney NSW 2000",0,0,0,1,0,0,0,0,0,0,0 10291,25,"Introduction Atturra Limited (Atturra) is a leading Australian technology services business, providing expertise across a broad range of specialist, in-demand IT areas",0,0,0,0,1,0,0,0,0,0,0 10291,26,"At Atturra, we understand that modern slavery is a complex issue and acknowledge that the nature of our business means we are exposed to potential modern slavery risks across our operations and supply chain",0,0,0,0,0,0,0,0,0,0,0 10291,27,"We are committed to developing our understanding of the modern slavery risks in our business and taking action in responding to this problem by working with our business, subsidiaries, stakeholders, business partners and suppliers to limit modern slavery risks",0,0,0,0,0,0,0,0,0,0,0 10291,28,Atturra Modern Slavery Statement FY22 Figure 1: Atturra Corporate Structure ACN 654 662 638 Atturra Limited ACN 132 368 104 Atturra Holdings Pty Ltd 46% NZ Company No 3566154 Kettering NZ Limited Incorporated in NZ ACN 104 218 804 FTS PHC Pty Ltd 100% ACN 627 989 584 Galaxy 42 Group Pty Ltd ACN 626 386 132 ESAM Consultants Pty Ltd ACN 167 654 382 Galaxy 42 Pty Ltd Trading as Atturra Business Applications - Education Trading as Atturra Business Applications ACN 133 375 112 Chartsmart Consulting Pty Ltd Trading as Atturra Business Applications - Government ACN 114 612 001 Kettering Professional Services Pty Ltd Trading as Atturra Business Applications - Manufacturing 100% 100% 100% 100% ACN 654 045 557 Atturra Operations Pty Ltd 100% ACN 652 098 489 Atturra Personnel Pty Ltd 100% ACN 101 129 588 Foundation Technology Services Pty Ltd 100% ACN 126 566 336 FTS Data & AI ACN 616 447 397 FTSG Pty Ltd 100% SINGAPORE COMPANY NO,0,0,0,1,0,0,0,0,0,0,0 10291,29,E Anatas Pte Ltd Incorporated in Singapore 100% ACN 133 185 458 Anatas Pty Ltd 100% ACN 169 127 824 Hayes Information Systems and Communications Pty Ltd 100% NZ Company No 8177133 Anatas Pty Ltd (NZ) Overseas ASIC company operating in NZ NZ Company No 7852799 Hayes Information Systems & Communications Pty Ltd (NZ) SINGAPORE ENTITY Hayes Information Systems Pte Ltd Overseas ASIC company operating in NZ Trading as Atturra Data & Integration ACN 106 981 560 SME Gateway Pty Ltd 100% ACN 105 421 976 Kobold Group Pty Ltd Trading as Atturra Management Control Solutions ACN 156 123 723 Mentum Systems Pty Ltd Trading as Atturra MCS 100% 100% ACN 149 193 519 FTS Nominees Pty Ltd 100% ACN 133 048 290 FTS Resourcing Pty Ltd 100% ACN 166 492 575 FTS VHC Pty Ltd 100% ACN 166 493 394 Veritec Pty Ltd 100% 100% ACN 105 196 423 Connexxion Pty Ltd Trading as Atturra Cloud Business Solutions ACN 133 185 547 Cubic Consulting Pty Ltd 100% NZ Company No 8228600 Cubic Consulting Pty Ltd (NZ) Overseas ASIC company operating in NZ Trading as Atturra Change & Adoption 25% 55% ACN 646 747 113 FTS NHC Pty Ltd 100% ACN 117 643 240 Noetic Group Pty Ltd ACN 098 132 024 Noetic Solutions Pty Ltd Trading as Atturra Advisory 100% 54%,0,0,0,1,0,0,0,0,0,0,0 10291,30,Atturra Modern Slavery Statement FY22 Operations Atturra provides a broad range and flexible suite of integrated solutions across the main business service segments including,0,0,0,0,1,0,0,0,0,0,0 241,35,"Our Framework Our Code of Conduct sets the foundation for the minimum expectations and behaviours to which we hold ourselves, our employees, service providers and suppliers to account",0,0,0,0,0,0,0,1,0,0,0 241,36,Collectively these expectations and behaviours establish the values to which we as a Company hold ourselves to account,0,0,0,0,0,0,0,1,0,0,0 241,37,"Supporting our Code is our risk management system comprising of our Policies and Procedures that provide the structure for how we deliver on these values and the Code, delivered through our Integrated Management System (IMS)",0,0,0,0,0,0,0,1,0,0,0 241,38,"Our Diversity & Inclusion Policy outlines our commitment to ensuring the fair and equitable treatment of local suppliers and workers without discrimination on the basis of aspects such as gender, race, ethnicity or religious views",0,0,0,0,0,0,0,0,0,0,0 241,39,"We are committed to creating a diverse and inclusive workforce through sourcing, selecting, developing and recognising our own people and those of our stakeholders",0,0,0,0,0,0,0,0,0,0,0 241,40,Supporting our Diversity & Inclusion policy is our Sustainability Policy,0,0,0,0,0,0,0,0,0,0,0 241,41,"This sets our commitment to develop an operational model to manage the economic, environmental and social risks and opportunities encountered across our operations",0,0,0,0,0,0,0,0,0,0,0 241,42,"SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 5 Assessing our risk to Modern Slavery Practices As a global Company, we procure goods and services from both domestic and international suppliers and as such, our framework is designed to support our operations in the identification and eradication of slavery practices",0,0,0,0,0,1,0,0,0,0,0 2824,183,We will look to assess and address any possible risks in a future reporting year,0,0,0,0,0,0,0,0,0,0,0 2824,184,"AREA MODERN SLAVERY RISKS IDENTIFIED Supply chains Goods and services In the assessment of our supply chains pertaining to products or services provided to us by suppliers, all goods and services procured by UniSuper were considered via tier one of the supply chain that provides the goods or services",0,0,0,0,0,0,0,0,0,0,0 2824,185,The vast majority of the reporting entities suppliers of goods and services are not suppliers at higher risk of involvement with modern slavery,0,0,0,0,0,0,1,0,0,0,0 2824,186,"Overall, on a headcount basis, 94% of our tier one suppliers of goods and services were located or carrying on an enterprise in Australia, 3% in the United States and the remainder elsewhere",0,0,0,0,0,1,0,0,0,0,0 2824,187,Our suppliers (and types of services obtained) include,0,0,0,0,0,1,0,0,0,0,0 2824,188,"custodians, brokers, research providers and external investment managers (investment services)",0,0,0,0,0,1,0,0,0,0,0 2824,189,"professional services firms (accounting, audit, advisory)",0,0,0,0,0,1,0,0,0,0,0 2824,190,marketing of branded goods,0,0,0,0,0,1,0,0,0,0,0 5169,79,"The services sector and those business models engaging migrant workers, entry-level workers or outsourcing are especially at risk",0,0,0,0,0,0,0,0,0,0,0 5169,80,"For Resolute, key supplier categories presenting a higher risk include transport and logistics, construction, consumer goods, electronics, catering and cleaning, maintenance and security",0,0,0,0,0,0,1,0,0,0,0 5169,81,"Resolute will prioritise evaluating the employment practices of these suppliers, especially if their operations are in a high-risk country, in order to assess the supply chain modern slavery risks",0,0,0,0,0,0,0,1,0,0,0 5169,82,"Resolute is developing a tool to facilitate the identification of suppliers most at risk based on the types of goods and services provided, and their sourcing geography",0,0,0,0,0,0,0,1,0,0,0 5169,83,"Supplier Capacity Identified high-risk suppliers will be evaluated on the strength of their internal governance, processes and practices to ensure they have strong operational safeguards in place to eradicate human rights violations and modern slavery from their operations",0,0,0,0,0,0,0,1,0,0,0 5169,84,To support this process we are developing a Supplier Standard for Sustainability and Due Diligence Questionnaire that will identify suppliers needing to improve their safeguards,0,0,0,0,0,0,0,1,0,0,0 5169,85,Training & Awareness Resolute supports training and awareness raising across its workforce,0,0,0,0,0,0,0,0,0,0,0 5169,86,"Currently, all employees and contractors receive mandatory induction training on the application of key policies when joining the Company, including the Code of Conduct and Whistleblower Policy",0,0,0,0,0,0,0,1,0,0,0 10291,31,Advisory and Consulting,0,0,0,0,1,0,0,0,0,0,0 10291,32,Business Applications,0,0,0,0,1,0,0,0,0,0,0 10291,33,Data and Integration,0,0,0,0,1,0,0,0,0,0,0 10291,34,Cloud Services,0,0,0,0,1,0,0,0,0,0,0 10291,35,Change Management and Adoption,0,0,0,0,1,0,0,0,0,0,0 10291,36,Management Control Solutions,0,0,0,0,1,0,0,0,0,0,0 10291,37,"Industry Engagement Atturra currently engages over 600 consultants, IT and support personnel in Sydney, Melbourne, Brisbane, Canberra, Adelaide, Perth, New Zealand and Singapore",0,0,0,1,1,0,0,0,0,0,0 10291,38,"Atturra monitors its opera- tional activities carefully, including staff and contractors, and has determined that there is very low risk of modern slavery practices occurring",0,0,0,0,0,0,1,0,0,0,0 241,43,To this end SRG recognises that its greatest exposure to modern slavery related issues exists within the companies purchasing and distribution supply chain,0,0,0,0,0,0,1,0,0,0,0 241,44,"To address the exposures of modern slavery within our operations, in consultation with the Executive Leadership Team, a review of SRGs operations was undertaken",0,0,0,0,0,0,0,1,0,0,0 241,45,"This focussed on: Areas of exposure; Existing methods of treatment; and Areas of improvement In consultation with representatives from each business unit, including input from the commercial, finance, procurement, human resources, quality, health & safety and risk and communications teams, a strategic review was undertaken on the existing supply chains within the Company",0,0,0,0,0,0,0,1,0,0,0 241,46,This heatmap4 below provides a graphical summary of exposure to modern slavery practices,0,0,0,0,0,0,0,0,0,0,0 241,47,Heat Map taken from the Minderoo Foundation 2018 Global Slavery Index Report,0,0,0,0,0,0,0,0,0,0,0 241,48,"SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 6 Supplementing the review on our supply chain, an analysis was also undertaken on our operations considered high risk in terms of either; exposure to modern slavery or having the potential to influencing decision making within the SRG supply chain",0,0,0,0,0,0,0,0,0,0,0 241,49,"The influencing factors identified include: Supply Chain Risks: Identification, Action and Treatment As a result of the assessments completed to identify the territorial and operational risks above, we recognise that a vast array of circumstances may affect our suppliers, leading to changes in their manufacturing and distribution practices and subsequently may increase our exposure to modern slavery practices",0,0,0,0,0,0,0,0,0,0,0 241,50,"To combat these risks, we are committed to undertaking the necessary steps with the aim of preventing and removing any risk we may have to modern slavery conditions",0,0,0,0,0,0,0,0,0,0,0 2824,191,"telecommunications (internet, telephone, computing, data storage)",0,0,0,0,0,1,0,0,0,0,0 2824,192,facilities and premises (real estate),0,0,0,0,0,1,0,0,0,0,0 2824,193,logistics and freight suppliers (postage and couriers),0,0,0,0,0,1,0,0,0,0,0 2824,194,"industry and professional organisations (subscriptions, memberships)",0,0,0,0,0,1,0,0,0,0,0 2824,195,"information technology companies (software, data services, technical services)",0,0,0,0,0,1,0,0,0,0,0 2824,196,recruitment and human resources firms (human resources); and,0,0,0,0,0,1,0,0,0,0,0 2824,197,"office-related suppliers (cleaning, catering, stationary)",0,0,0,0,0,1,0,0,0,0,0 2824,198,"In determining which aspects of our supply chains were at a higher risk of modern slavery, an enterprise wide assessment of spend and supplier data for the 2019 calendar year was conducted alongside consideration of",0,0,0,0,0,0,0,1,0,0,0 5169,87,Regular awareness raising campaigns on selected material topics are also delivered,0,0,0,0,0,0,0,1,0,0,0 5169,88,These existing approaches will be essential in ensuring that human rights and modern slavery considerations are embedded in its operations,0,0,0,0,0,0,0,0,0,0,0 5169,89,The Company will continue to refine and improve its training and awareness programs relative to human rights and modern slavery and is developing a standalone trainings that will become a mandatory requirement for all employees in 2021,0,0,0,0,0,0,0,1,0,0,0 5169,90,"Stakeholder Engagement As a responsible corporate citizen Resolute understands its role in raising awareness and strengthening the capacity of institutions, in the countries in which it operates, to address human rights and modern slavery both locally and nationally",0,0,0,0,0,0,0,0,0,0,0 5169,91,"Resolute engages with its key stakeholders in all countries of operation, regarding business activities, performance, risk identification and management",0,0,0,0,0,0,0,0,0,1,0 5169,92,"Resolute is working to implement a stakeholder engagement framework to further develop its networks with governments, civil society, industry bodies, host communities and suppliers",0,0,0,0,0,0,0,0,0,1,0 5169,93,"Increased engagement will contribute to the elimination of modern slavery through the sharing of information, resources and the early identification of risks",0,0,0,0,0,0,0,0,0,1,0 5169,94,"Performance Review Resolute regularly commissions asset-level audits of established processes, management systems and operations to review performance",0,0,0,0,0,0,0,0,0,1,0 10291,39,"Atturra ensures that all employees are legally entitled to work in the relevant jurisdiction and complies with all applicable laws, including providing employees with appropriate employment conditions such as hours of work, fair remuneration and wages and access to employment benefits",0,0,0,0,0,0,0,1,0,0,0 10291,40,"In the event that recruitment agencies are engaged to source personnel in jurisdictions outside Australia such as New Zealand and Singapore, Atturra ensures the rate (if any) charged to the individual is reasonable and that all local employment laws are followed",0,0,0,0,0,0,0,1,0,0,0 10291,41,"At the time of this Statement, Atturra does not employ any contractors or subcontractors in jurisdictions outside Australia",0,0,0,0,0,1,0,0,0,0,0 10291,42,"Supply Chain Atturras supply chain consists of more than 800 suppliers, the vast majority of which are companies based in Australia",0,0,0,0,0,1,0,0,0,0,0 10291,43,"Atturra engages a very small number of suppliers outside Australia, including from suppliers based in India and Singapore",0,0,0,0,0,1,0,0,0,0,0 10291,44,These arrangements with overseas suppliers are considered low risk and the suppliers are engaged on a short-term or ad-hoc basis,0,0,0,0,0,0,1,0,0,0,0 10291,45,Atturras substantial and material contractual relationships are with suppliers based in Australia,0,0,0,0,0,1,0,0,0,0,0 10291,46,Atturra contracts with its higher value and strategic suppliers by way of a Supplier Services Agreement or Contractor Agreement depending on commercial terms,0,0,0,0,0,1,0,0,0,0,0 241,51,"This includes a process of identification, buying locally and education and treatment",0,0,0,0,0,0,0,0,0,0,0 241,52,A Process of Identification The management of supply chain risks forms part of SRGs wider corporate risk management framework and practices,0,0,0,0,0,0,0,0,0,0,0 241,53,"This framework includes the incorporation of controls and processes prudent to ensuring we meet the values established by our Board, our stakeholders and the community",0,0,0,0,0,0,0,0,0,0,0 241,54,To support its commitment within its Sustainability Policy the Companys risk assessment process serves to identify potential risk factors by focussing on: Understanding the scope of what we are trying to achieve; Identification of whether the activities can be completed by SRG or require the services of an external supplier; Undertaking and analysis of the risks associated with achieving the outcome; Evaluating the likelihood and exposure,0,0,0,0,0,0,0,0,0,0,0 241,55,"SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 7 Implementing treatment strategies to mitigate the exposure to unforeseen events or circumstances; and monitoring, reviewing and communicating",0,0,0,0,0,0,0,0,0,0,0 241,56,Buy Local We recognise that Australia holds strong and regulated importation and manufacturing regulations to support local industry,0,0,0,0,0,0,0,0,0,0,0 241,57,"SRG will continue to procure where practical, the services of Australian suppliers to support its operations however recognises that this is not viable in all circumstances",0,0,0,0,0,0,0,1,0,0,0 241,58,"Education and Treatment Supplier Onboarding and Management To support the identification and assessment of slavery exposures in addition to wider human rights exposures, SRG has commenced the establishment of a Supplier Onboarding and Management procedure capturing the life cycle of external suppliers",0,0,0,0,0,0,0,1,0,0,0 2824,199,global slavery index data,0,0,0,0,0,0,0,1,0,0,0 2824,200,qualitative assessment in conjunction with industry bodies,0,0,0,0,0,0,0,1,0,0,0 2824,201,"industry commentary on modern slavery, and",0,0,0,0,0,0,0,1,0,0,0 2824,202,"a de minimis spend threshold of $5,000",0,0,0,0,0,0,0,1,0,0,0 2824,203,"Out of the thousands of suppliers to our operations, the assessment process yielded a result of 38 higher risk suppliers with which we have focussed our efforts and conducted enhanced due diligence in respect of modern slavery risks",0,0,0,0,0,0,1,0,0,0,0 2824,204,"Our actions described in pages 5-8 detail how we began engaging with these suppliers and, of course, any further development during the 2020-21 financial year will be reported in our next modern slavery statement",0,0,0,0,0,0,0,0,0,0,0 2824,205,"Further, there is a dedicated procurement function to manage the contracting, delivery and relationship process end to end alongside the relevant business unit within UniSuper",0,0,0,0,0,0,0,1,0,0,0 2824,206,"As part of this function, the appropriate contracting approach is determined in accordance with the reporting entitys procurement strategy",0,0,0,0,0,0,0,1,0,0,0 5169,95,"These audits can be internal (performed by corporate) or contracted to independent third party organisations, and remedial actions identified are implemented within the calendar year under the oversight of the mine site General Manager",0,0,0,0,0,0,0,0,0,1,0 5169,96,Resolute will follow this approach to ensure ongoing compliance with human rights and modern slavery best practice and standards,0,0,0,0,0,0,0,0,0,1,0 5169,97,"In 2021, Resolute will perform a human rights review across all its",0,0,0,0,0,0,0,0,0,1,0 5169,98,"Document Owner: Lead Document Controller (RSG) Page 7 of 7 Document Number: ADM-ADM-TMP-0022 Revision 1.02 Issue Date: 7/06/2021 Next Review:12 months Modern Slavery Voluntary Statement assets, under the guidance of recognised industry tools such as the Human Rights Impact Assessment (HRIA) developed by the Danish Institute on Human Rights, and the Slavery & Trafficking Risk Template (STRT) developed by the Social Responsibility Alliance",0,0,0,0,0,0,0,0,0,1,0 5169,99,Appropriate measures to address any improvements needed will be put in place thereafter,0,0,0,0,0,0,0,0,0,1,0 5169,100,"In addition, Resolute will also ensure that human rights indicators are monitored across the group, through our existing sustainability reporting framework, to enable annual performance tracking and target setting",0,0,0,0,0,0,0,0,0,1,0 5169,101,Resolute is committed to increasing disclosure on its management of sustainability issues across operations and published its first Group Sustainability Report in 2021,0,0,0,0,0,0,0,0,0,1,0 5169,102,Our Aim for 2021 Resolute has identified several progress areas to address and manage human rights and modern slavery related risk and opportunity within its operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 10291,47,"Since the enactment of Modern Slavery legislation in 2018, Atturra has been ensuring that appropriate modern slavery provisions are included in relevant agreements and will ensure ongoing agreements will include such provisions",0,0,0,0,0,0,0,1,0,0,0 10291,48,The majority of procurement spend is on individual contractors supplied onto client projects,0,0,0,0,0,1,0,0,0,0,0 10291,49,"The key categories of Atturras suppliers are contractors/sub-contractors that deliver services to clients on behalf of Atturra, the re-sale of software licensing, and recruitment",0,0,0,0,0,1,0,0,0,0,0 10291,50,"Other categories of suppliers include profes- sional services, IT hardware and services, marketing, PR services, merchandise, insurance, legal services, office consumables and facilities costs such as rent, utilities, cleaning and office fit outs",0,0,0,0,0,1,0,0,0,0,0 10291,51,Atturra rents each office premises held by Atturra in different geographic locations,0,0,0,0,0,1,0,0,0,0,0 10291,52,"Services related to these premises such as plumbing, electrical and maintenance services are procured and managed by the relevant premises building management",0,0,0,0,0,1,0,0,0,0,0 10291,53,"Risks of modern slavery practices in our operations and supply chain At Atturra, we acknowledge that modern slavery risks can arise in our operations due to country and industry specific modern slavery risk factors",0,0,0,0,0,0,1,0,0,0,0 10291,54,"We also recognise that modern slavery risks are constantly changing over time, particularly due to exter- nal factors such as the COVID-19 pandemic",0,0,0,0,0,0,1,0,0,0,0 241,59,This process is focussed on: Pre-Qualification; Onboarding; Management; and Assessment and Close Out,0,0,0,0,0,0,0,0,0,0,0 241,60,Oversight of the Supplier Onboarding and Management procedure will be administered through central locations via SRGs IMS and communicated to business units through the organisations SharePoint platform,0,0,0,0,0,0,0,0,0,0,0 241,61,Supplier Management Prequalification,0,0,0,0,0,0,0,0,0,0,0 241,62,Identification of the services required by an external vendor or supplier,0,0,0,0,0,0,0,1,0,0,0 241,63,"Risk Assessment on the works and services to be provided and terms of engagement Onboarding Undertake SRG Global Inductions, development ofmanagement plans",0,0,0,0,0,0,0,1,0,0,0 241,64,Close Out Review of Supplier or Vendor performance based on established key performance indicators (KPIs) Monitoring Interim reviews of Supplier or Vendor,0,0,0,0,0,0,0,0,0,1,0 241,65,"SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 8 Supplier Management Procedure At the onboarding phase, SRG will undertake assessment of its suppliers in accordance with its Code of Conduct",0,0,0,0,0,0,0,1,0,0,0 241,66,The risk assessment process will include: Reviews of the potential suppliers services and operations; Product sourcing or manufacturing (as applicable) including traceability audits; Terms of employment (such as the use of EBAs or other industrial agreements); and Conducting checks through third party bodies or resources such as government databases to identify breaches or violations of human rights including previous prosecutions; Approved suppliers will then be engaged ideally through an SRG contract including terms obligating the supplier to work in accordance with the ethical obligations included within the SRG Code of Conduct,0,0,0,0,0,0,0,1,0,0,0 2824,207,"The structure of such arrangements is determined on a case by case basis with reference to the business requirements, input from subject matter experts, nature of the service and output of an in-house evaluation tool, known as the vendor criticality assessment (VCA)",0,0,0,0,0,0,0,1,0,0,0 2824,208,"The VCA establishes a criticality rating that then determines other processes to follow or actions to take, such as the sourcing approach, whether to assess the risks of modern slavery in the supply chain, whether additional risk mitigation and due diligence activities are warranted",0,0,0,0,0,0,0,1,0,0,0 2824,209,"We made arrangements in the 2019-20 financial year to ensure procurement activities undertaken from 1 July 2020 (that is, prior to commencing a procurement activity, extending or varying a contract) via our procurement function would conduct a VCA",0,0,0,0,0,0,0,1,0,0,0 2824,210,"If the VCA result indicated a higher risk of modern slavery, then we took this into consideration when selecting vendors or assessing overall vendor performance",0,0,0,0,0,0,0,1,0,0,0 2824,211,The VCA result could also prompt further due diligence,0,0,0,0,0,0,0,1,0,0,0 2824,212,630 692 UNISUPER.COM.AU,0,0,0,0,0,0,0,0,0,0,0 2824,213,AREA MODERN SLAVERY RISKS IDENTIFIED Supply chains External investments Our externally managed investments comprise under one third of our investments,0,0,0,0,0,1,0,0,0,0,0 2824,214,"For modern slavery risk purposes, risks are potentially present in our external managers as suppliers and in relation to the assets being managed",0,0,0,0,0,0,1,0,0,0,0 5169,103,Our action plan for 2021 is below,0,0,0,0,0,0,0,0,0,0,0 5169,104,Action Area Initiative Timeframe Governance Update Corporate policies to align with leading human rights frameworks,0,0,0,0,0,0,0,1,0,0,0 5169,105,Q2 2021 Suppliers Develop a Supplier Sustainability Standard and due diligence questionnaire to assess exposure to human rights and modern slavery risks,0,0,0,0,0,0,0,1,0,0,0 5169,106,Q2 2021 Education & Awareness Human Rights trainings to be developed and made mandatory for all employees,0,0,0,0,0,0,0,1,0,0,0 5169,107,Q3 2021 Risk & Opportunity Undertake asset-level reviews to assess human rights risks and identify mitigation measures to be implemented,0,0,0,0,0,0,0,1,0,0,0 5169,108,Q4 2021 Suppliers Review / update Human Rights provisions in Company Services Agreements,0,0,0,0,0,0,0,1,0,1,0 5169,109,Q4 2021 ________________________________ Signed by Stuart Gale Managing Director & CEO,0,1,0,0,0,0,0,0,0,0,0 5284,0,MODERN SLAVERY STATEMENT 2021 ALLY FASHION,0,0,0,0,0,0,0,0,0,0,0 10291,55,"To identify and address these risks, Atturra has conducted a modern slavery risk assessment of our operations and supply chain",0,0,0,0,0,0,0,0,0,0,0 10291,56,Risks in our operations The Australian IT services industry within which Atturra operates is not considered to be a high-risk industry for modern slavery,0,0,0,0,0,0,1,0,0,0,0 10291,57,"Consequently, as a technology services business with a pre- dominantly professional workforce, we have assessed the risk of modern slavery in our own operations to be low",0,0,0,0,0,0,1,0,0,0,0 10291,58,"Our internal operations and employees are based in Australia, which is considered to be a low risk country for modern slavery as noted in the Global Slavery Index 2018",0,0,0,0,0,0,1,0,0,0,0 10291,59,"However, we understand that the industry in which we operate can have modern slavery risks due to a lack of visibility over supply chains, exploitation and underpayment of workers and working conditions",0,0,0,0,0,0,1,0,0,0,0 10291,60,"While Atturra does not identify these practices within its own supply chain and operations, we are cognisant that these modern slavery risks can occur and consequently, we have implement- ed actions to address and mitigate these risks as described in this Statement",0,0,0,0,0,0,1,0,0,0,0 10291,61,"Outside of Australia, Atturra also engages a small number of permanent employees in New Zealand and Singapore as part of its operations",0,0,0,0,1,0,0,0,0,0,0 10291,62,These workers are employed directly with Atturra under conditions complying with applicable New Zealand and Singapore law,0,0,0,0,0,0,0,0,0,0,0 241,67,"During the life cycle of the suppliers engagement, periodical reviews will be completed to ensure the suppliers continual compliance",0,0,0,0,0,0,0,0,0,1,0 241,68,We recognise that communication is key to the success of eradicating slavery practices,0,0,0,0,0,0,0,0,0,0,0 241,69,We remain committed to proactively working with our suppliers to better educate and promote awareness of both the prevalence and forms of modern slavery and human rights abuses,0,0,0,0,0,0,0,0,0,1,0 241,70,SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 9 Our FY21 Objectives SRG has established the following objectives for the FY21,0,0,0,0,0,0,0,0,0,0,0 241,71,These objectives are set to serve as the minimum achievements we expect to implement over the coming 12 months: Implementation of Supplier Management Procedure Complete the rollout of the Supplier Onboarding and Management Procedure commencing with early engagement and intervention with current suppliers,0,0,0,0,0,0,0,1,0,0,0 241,72,This will include the release of communications and awareness campaigns through the organisations IMS on the changes to the companys existing procedures and the importance of self-awareness within their own operations,0,0,0,0,0,0,0,1,0,0,0 241,73,Undertake Modern Slavery Training Delivery of modern slavery awareness training to all employees involved in the procurement of suppliers and vendors,0,0,0,0,0,0,0,1,0,0,0 241,74,"The training will focus on: What Modern Slavery is in 2020; Trends in Modern Slavery activity; Where Modern Slavery may exist within SRGs supply chain; Our process of identifying, assessing and treating exposures to Modern Slavery; and The role of our people and suppliers in managing Modern Slavery",0,0,0,0,0,0,0,0,0,0,0 2824,215,"For this Statement, we sought to gain a better understanding of our external managers processes for identifying, assessing and managing modern slavery risks (on a geographical risk and sector risk basis) when managing our investments",0,0,0,0,0,0,0,1,0,0,0 2824,216,This was done as part of our regular due diligence on managers ESG performance and processes as well as specific requests focussing on their modern slavery risk management,0,0,0,0,0,0,0,0,0,0,0 2824,217,We will report on our progress annually,0,0,0,0,0,0,0,1,0,0,0 2824,218,"We did not consider the potential modern slavery risks with external investment managers as tier one suppliers to be high, however, we will look to assess and address any possible risks in a future reporting year",0,0,0,0,0,0,1,0,0,0,0 2824,219,Employment agreements for USM employees and minimum term contractors We did not consider the potential modern slavery risks within this area to be high,0,0,0,0,0,0,1,0,0,0,0 2824,220,We will look to assess and address any possible risks in a future reporting year,0,0,0,0,0,0,0,0,0,0,0 2824,221,"Professional advisers (eg accounting firms, audit firms, law firms) We did not consider the potential modern slavery risks within this area to be high",0,0,0,0,0,0,1,0,0,0,0 2824,222,The services provided to us are predominately located in Australia,0,0,0,0,0,0,1,0,0,0,0 5284,1,"2021 ALLY FASHION Unit 10/1 Hordern Place, Camperdown NSW Australia 2050",0,0,0,0,0,0,0,0,0,0,0 5284,2,POL MODERN SLAVERY STATEMENT Process Owner: Human Resources Authorised: Head of HR Ref,0,0,0,0,0,0,0,0,0,0,0 5284,3,Number: 2.1 Page: 1 Date: 20 June 2021,0,0,0,0,0,0,0,0,0,0,0 5284,4,"Scope This statement applies to all Ally Fashion team members, suppliers, and contractors",0,0,0,0,0,0,0,0,0,0,0 5284,5,This statement is made in accordance with the Australia Commonwealth Modern Slavery Act,0,0,1,0,0,0,0,0,0,0,0 5284,6,"It describes how Ally Fashion works to prevent and mitigate the risk of forced labour, child labour, modern slavery and human trafficking in its business and supply chains",0,0,1,0,0,0,0,0,0,0,0 5284,7,Notice to Team Members This Policy is published on Ally Fashions website,0,0,0,0,0,0,0,0,0,0,0 5284,8,"Team members, suppliers, and contractors will be notified via email of changes",0,0,0,0,0,0,0,0,0,0,0 10291,63,"Singapore has an estimated prevalence of modern slavery of 3.4 victims per 1,000 people in the population, which is a higher prevalence of modern slavery than Australia and New Zealand (according to the Global Slavery Index 2018)",0,0,0,0,0,0,1,0,0,0,0 10291,64,"Further, the Global Slavery Index 2018 identifies geographic risks in Singapore due to the limited action from the Singaporean Government in response to modern slavery despite the magnitude of the problem and the resources at their disposal",0,0,0,0,0,0,1,0,0,0,0 10291,65,"Despite inherent geographic risks, Atturra does not consider this to be a high risk of modern slavery due to the limited number of employees based in Singapore and the measures Atturra has implement- ed to address any risks",0,0,0,0,0,0,1,0,0,0,0 10291,66,"Atturra has not identified increased geographic risks in New Zealand, particularly as the estimated prevalence of modern slavery practices in this jurisdiction is the same level as that in Australia (Global Slavery Index 2018)",0,0,0,0,0,0,1,0,0,0,0 10291,67,"Atturra Modern Slavery Statement FY22 Risks in our supply chain Atturra assesses the overall risk of its supply chain by consid- ering each suppliers individual risk profile based on its geo- graphic location, the nature of the goods or services provided, and the total value of payments made to the supplier",0,0,0,0,0,0,0,1,0,0,0 10291,68,"Atturra acknowledges that through its supply chain, it can be indi- rectly exposed to the risk of modern slavery including human trafficking and forced labour regardless of location or industry",0,0,0,0,0,0,1,0,0,0,0 10291,69,Atturra expects its suppliers to monitor their own supply chain for modern slavery risks and maintain open communication and cooperate with Atturra regarding any potential breach of its modern slavery obligations,0,0,0,0,0,0,0,1,0,0,0 10291,70,This expectation has been made known to its suppliers throughout the reporting year,0,0,0,0,0,0,0,1,0,0,0 241,75,"Measuring Success In line with our FY21 objectives, the following key performance indicators will be utilised as a benchmark: Complete rollout of the Supplier Onboarding and Management Procedure; Assessment of a minimum 30% of existing key SRG suppliers as at the date of this statements publication; 100% attendance of nominated employees of the modern slavery awareness training",0,0,0,0,0,0,0,0,0,1,0 241,76,Periodical audits on our progress and compliance will be undertaken by SRGs Quality and Compliance Manager,0,0,0,0,0,0,0,0,0,1,0 241,77,"SRG Global: Beyond 2020 As we navigate 2020, in the wake of the COVID-19 pandemic, through what has arguably been one of the greatest challenges faced by a more interconnected world, we understand that change is necessary to ensure we continue to meet the social responsibilities the community expects",0,0,0,0,0,0,0,0,0,0,0 241,78,Businesses will continue to look to find ways of managing and growing revenue and profits in this uncertain environment,0,0,0,0,0,0,0,0,0,0,0 241,79,"As a result, there is an inherent exposure that this may come at the cost of sourcing products that may place individuals involved in their manufacture and transport at risk in environments commensurate to modern slavery conditions",0,0,0,0,0,0,0,0,0,0,0 241,80,This statement will assist SRG and our supply chain partners to manage through such complexities in a fair and equitable manner,0,0,0,0,0,0,0,0,0,0,0 241,81,"As our first SRG Modern Slavery Statement, we recognise that the abolishment of modern slavery and human rights abuses is a journey that requires the engagement of our Suppliers, government and the greater community and we remain committed to ensuring we undertake our part in the process",0,0,0,0,0,0,0,0,0,0,0 241,82,SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 10 Appendix A SRG Global Limited Controlled Entities Extract taken from SRG Global Limited 2020 Annual Report,0,0,0,0,0,0,0,0,0,0,0 2824,223,We will look to assess and address any possible risks in a future reporting year,0,0,0,0,0,0,0,0,0,0,0 2824,224,Incidental ad hoc supplier agreements entered into at a business level on a repetitive basis We did not consider the potential modern slavery risks within this area to be high,0,0,0,0,0,0,1,0,0,0,0 2824,225,The extent of any such engagement would have been below a materiality threshold (otherwise the supply would have gone through the procurement process described in the key suppliers row of this table),0,0,0,0,0,0,1,0,0,0,0 2824,226,We will look to assess and address any possible risks in a future reporting year,0,0,0,0,0,0,0,0,0,0,0 2824,227,Our modern slavery statement APPENDIX 15,0,0,0,0,0,0,0,0,0,0,0 2824,228,CONTACT US 1800 331 685 +61 3 8831 7901 WEBSITE unisuper.com.au EMAIL,0,0,0,0,0,0,0,0,0,0,0 2824,229,"enquiry@unisuper.com.au ADDRESS UniSuper Level 1, 385 Bourke Street Melbourne Vic 3000 Australia US20-0106 0121 UniSuper Limited February 2021",0,0,0,1,0,0,0,0,0,0,0 3584,0,"Munich Res Statement on the Australian Modern Slavery Act This statement is made pursuant to Part II, section 14 of the Australian Modern Slavery Act 2018 and constitutes Munich Res joint Modern Slavery statement for the financial year ending 31 December 2020 for the following entities",0,0,1,0,0,0,0,0,0,0,0 5284,9,Principles Ally Fashion rejects modern slavery in all its forms,0,0,0,0,0,0,0,0,0,0,0 5284,10,"At Ally Fashion, we want to make fashion and design sustainable and sustainably fashionable",0,0,0,0,0,0,0,0,0,0,0 5284,11,"Modern slavery is unlawful within Australia, and, at Ally Fashion, we are committed to protecting the health, safety, and wellbeing of our people, and to implementing and enforcing effective systems and controls to reduce the risk of modern slavery in our business and in our supply chains",0,0,0,0,0,0,0,0,0,0,0 5284,12,"Globally, modern slavery affects approximately 40 million people and we at Ally Fashion understand that that eliminating modern slavery is our responsibility to eliminate at every level of our supply chain, and it is not only the responsibility of those countries where the abuse of such human rights is prevalent",0,0,0,0,0,0,0,0,0,0,0 5284,13,"Modern slavery, which includes slavery, servitude, forced labour, child labour and exploitation, debt bondage, forced marriage, deceptive recruiting for labour and human trafficking, is often a hidden problem and we recognise we have a responsibility to ensure that we do our part to address these systemic issues",0,0,0,0,0,0,0,0,0,0,0 5284,14,"Ally Fashion is committed to working with suppliers that actively reduce the risk of human rights abuses in their businesses, and in turn, our business",0,0,0,0,0,0,0,0,0,0,0 5284,15,We actively ensure that all parts of our business and supply chains fully understand and strictly adhere to our expectations of conduct,0,0,0,0,0,0,0,1,0,0,0 5284,16,"As a leading fashion retailer, we are often privileged to be the employer that kickstarts the employment of many young individuals, whilst being fully aware that millions of youngsters around the world enter the workforce through tragic, abusive, and inhumane means",0,0,0,0,1,0,0,0,0,0,0 10291,71,"To better understand the potential risk areas in Atturras supply chain, we developed a risk assessment process by undertaking supply chain mapping",0,0,0,0,0,0,0,1,0,0,0 10291,72,"This enabled us to better understand risks through contractual and industry perspectives, as well as inherent country risk factors relating to each supplier",0,0,0,0,0,0,0,0,0,0,0 10291,73,"In under- taking the supply chain mapping process, Atturra reviewed its supply chain and undertook a risk assessment of its suppliers using a number of criteria in order to identify any concerns relating to modern slavery",0,0,0,0,0,0,0,1,0,0,0 10291,74,"From this risk assessment, Atturra considers that its supply chain has low exposure to modern slavery risk areas",0,0,0,0,0,0,1,0,0,0,0 10291,75,The supply chain mapping only identified a small amount of higher-risk suppliers,0,0,0,0,0,0,1,0,0,0,0 10291,76,Atturra recognises product and service risks may exist when goods are purchased from suppliers who utilise modern slav- ery in their supply chain or when products procured contain materials that were sourced using modern slavery,0,0,0,0,0,0,1,0,0,0,0 10291,77,"Particularly, the supply chain mapping process identified key higher risk areas that Atturra identified and targeted for increased due diligence, included the following: Contingent Labour (including contractors, recruitment agencies, and payroll agencies), IT and marketing",0,0,0,0,0,0,1,0,0,0,0 10291,78,"These areas were chosen as having (1) the highest spend and (2) a greater risk of modern slavery in relation to five key indices: decent wages, forced labour, migrant workers, modern slavery, trafficking in persons",0,0,0,0,0,0,1,0,0,0,0 241,83,SRG GLOBAL: 2020 MODERN SLAVERY STATEMENT Page 11,0,0,0,0,0,0,0,0,0,0,0 241,84,"CORPORATE HEAD OFFICE Level 1, 338 Barker Rd Subiaco WA 6008 +61 8 9267 5400 info@srgglobal.com.au",0,0,0,0,0,0,0,0,0,0,0 373,0,Modern Slavery Statement FY20 v01,0,0,0,0,0,0,0,0,0,0,0 373,1,"Page 1 of 5 Modern Slavery & Human Trafficking Statement FY20 Introduction Modern slavery describes the most serious forms of exploitation including trafficking in persons, slavery, servitude, forced labour, forced marriage, debt bondage and the worst forms of child labour.1 These abuses can occur in all industries and sectors and distorts global markets and responsible business practices.2 Toll Holdings Limited, and our subsidiaries respect ethical labour practices and value diversity",0,0,0,0,0,0,0,0,0,0,0 373,2,"Toll takes a zero-tolerance approach to any form of human rights abuses, including modern slavery in our operations and supply chains and we expect that all our employees, suppliers, subcontractors and agents uphold these values",0,0,0,0,0,0,0,0,0,0,0 373,3,This statement is published by Toll Holdings Ltd (Australian registered Company Number 006 592 089) and our subsidiaries in compliance with section 54 of the United Kingdoms Modern Slavery Act 2015 and Australias Modern Slavery Act 2018 (Cth),0,0,1,0,0,0,0,0,0,0,0 373,4,It describes the steps taken by Toll Holdings Ltd and our subsidiaries in the financial year ending 31 March 2020 to assess and address modern slavery,0,0,0,0,0,0,0,0,0,0,0 373,5,"Structure, Operations & Supply Chain Our Structure & Operations With over 125 years experience, Toll operates an extensive global logistics network with direct operations in 26 countries as well as strong partnerships with agents in countries where we are not present",0,0,0,0,1,0,0,0,0,0,0 3584,1,Mnchener Rckversicherungs-Gesellschaft Aktiengesellschaft in Mnchen (MR AG) (ABN: 90 009 763 526) And its wholly owned subsidiaries,0,0,0,1,0,0,0,0,0,0,0 3584,2,Munich Holdings of Australasia Pty Limited (MHA) (ABN: 80 000 159 651),0,0,0,0,0,0,0,0,0,0,0 3584,3,Munich Reinsurance Company of Australasia Limited (MRA) (ABN: 51 004 804 013),0,0,0,0,0,0,0,0,0,0,0 3584,4,"Great Lakes Insurance SE (GLISE) (ABN: 18 964 580 576) The organisations structure, its business and its supply chains MR AG is the ultimate parent of the Munich Re Group which operates from more than 50 locations around the world",0,0,0,1,1,0,0,0,0,0,0 3584,5,Munich Re (Group) is one of the worlds leading risk carriers and provides both insurance and reinsurance under one roof,0,0,0,0,1,0,0,0,0,0,0 3584,6,This ena- bles the Group to cover large stretches of the value chain in the risk market,0,0,0,0,0,0,0,0,0,0,0 3584,7,Almost all reinsurance units operate under the uniform brand of Munich Re,0,0,0,1,0,0,0,0,0,0,0 3584,8,"Munich Res investments world-wide are mainly managed by Munich ERGO Asset Management GmbH (MEAG), which also offers its expertise to private and institutional investors outside the Group",0,0,0,0,0,1,0,0,0,0,0 5284,17,"Ally Fashion takes a continuous improvement approach to reducing the risks of modern slavery within its supply chain, aiming to reduce these complex risks over time",0,0,0,0,0,0,0,0,0,0,0 5284,18,"Personal and Professional Behaviour Ally Fashions Code of Conduct provides our team members, suppliers, and contractors with a framework to guide them through Ally Fashions core values",0,0,0,0,0,0,0,1,0,0,0 5284,19,"The Code covers topics such as duty of care, workplace culture, human rights, fraud detection, and loss prevention",0,0,0,0,0,0,0,1,0,0,0 5284,20,We work to,0,0,0,0,0,0,0,1,0,0,0 5284,21,POL MODERN SLAVERY STATEMENT Process Owner: Human Resources Authorised: Head of HR Ref,0,0,0,0,0,0,0,0,0,0,0 5284,22,Number: 2.1 Page: 2 Date: 20 June 2021,0,0,0,0,0,0,0,0,0,0,0 5284,23,"ensure a culture of honest and ethical conduct and Ally Fashion requires all individuals within the business to adhere to the Code and all underlying applicable policies, standards, and procedures",0,0,0,0,0,0,0,1,0,0,0 5284,24,We also expect those who we conduct business with to share and observe these same values,0,0,0,0,0,0,0,1,0,0,0 10291,79,"Due to the heightened risk in these areas for modern slavery practices, Atturra targeted these higher risk areas for increased due diligence through the distribution of the modern slavery risk questionnaire",0,0,0,0,0,0,0,1,0,0,0 10291,80,"Additionally, Atturra sources electronic equipment and mate- rials which may entail modern slavery risks as it has little to no visibility or influence over the supply chain and therefore modern slavery risks",0,0,0,0,0,0,1,0,0,0,0 10291,81,We recognise that this procurement may involve a higher risk of modern slavery,0,0,0,0,0,0,1,0,0,0,0 10291,82,"In order to better understand the modern slavery risks in our supply chain, Atturra also distributed a modern slavery risk questionnaire to suppliers who were identified as medium risk following the supply chain mapping process as described above",0,0,0,0,0,0,0,1,0,0,0 10291,83,The questionnaire sought to undertake a risk assess- ment of our major suppliers to enable Atturra to mitigate our exposure to modern slavery risks and ensure compliance to modern slavery laws,0,0,0,0,0,0,0,0,0,0,0 10291,84,The questionnaire identified no instances of modern slavery in our suppliers operations or supply chains and no concerns about labour practices,0,0,0,0,0,0,1,0,0,0,0 10291,85,"Further, the questionnaire demonstrated that several higher risk suppliers have plans or policies in place to manage and mitigate modern slavery risks",0,0,0,0,0,0,1,0,0,0,0 10291,86,Atturra understands the importance of raising awareness to aid the ending of modern slavery practices,0,0,0,0,0,0,0,0,0,0,0 373,6,"Tolls 27,436 employees provide a diverse range of transport and logistics solutions covering road, air, sea and rail to help customers meet their global supply chain needs",0,0,0,1,1,0,0,0,0,0,0 373,7,"Proudly part of Japan Post, and headquartered in Australia, Toll provides a diverse range of services to customers across the world, including: Freight (Global Forwarding): a full suite of international freight forwarding, specialising in Asia inbound and outbound trade lanes",0,0,0,1,1,0,0,0,0,0,0 373,8,Our transport methods include,0,0,0,0,1,0,0,0,0,0,0 373,9,Air Freight,0,0,0,0,0,0,0,0,0,0,0 373,10,Sea Freight,0,0,0,0,0,0,0,0,0,0,0 373,11,Road Freight,0,0,0,0,0,0,0,0,0,0,0 373,12,Rail Freight,0,0,0,0,0,0,0,0,0,0,0 373,13,Intermodal and Multimodal Freight; and,0,0,0,0,1,0,0,0,0,0,0 3584,9,"In reinsurance, we operate in life, health and property-casualty business",0,0,0,0,1,0,0,0,0,0,0 3584,10,"Under rein- surance, we also include specialised primary insurance activities that are handled by the reinsurance organisation and business from managing general agencies (MGAs)",0,0,0,0,1,0,0,0,0,0,0 3584,11,"Munich Re does business with over 4,000 corporate clients from more than 160 countries",0,0,0,0,1,0,0,0,0,0,0 3584,12,"We write our business in direct collaboration with primary insurers, but also via brokers and within the framework of strategic partnerships",0,0,0,0,1,0,0,0,0,0,0 3584,13,"In addition to traditional reinsurance business, we participate in insurance pools, public-private partnerships, business in specialist niche segments, and as a primary insurer",0,0,0,0,1,0,0,0,0,0,0 3584,14,MR AG writes non-life reinsurance business in Australia primarily through its Australian Branch (MRAU),0,0,0,0,1,0,0,0,0,0,0 3584,15,Life reinsurance business is conducted via MRA,0,0,0,0,1,0,0,0,0,0,0 3584,16,"GLISE maintains an Australian branch, Great Lakes Australia (GLA), offering primary insurance",0,0,0,0,1,0,0,0,0,0,0 5284,25,Team members are encouraged to report any concerns of Code breaches to their direct manager and/or a member of the Human Resources team,0,0,0,0,0,0,0,1,0,0,0 5284,26,"Ally Fashion Structure, Operations, and Supply Chain The Board of Ally Fashion is responsible for the overall governance, management and strategic direction of Ally Fashion in accordance with all duties and obligations imposed by law",0,0,0,0,0,0,0,0,0,0,0 5284,27,"Founded in 2001, we opened our first Ally Fashion (ABN 196 240 351 32) retail store in Sydney",0,0,0,0,1,0,0,0,0,0,0 5284,28,"Ally Fashion manufactures and provides clothing apparel, footwear, accessories, and a wide range of products to customers through our retail store network and eCommerce platform",0,0,0,0,1,0,0,0,0,0,0 5284,29,"Ally Fashions business comprises the sale of womens apparel and related accessories under its brands, Ally Fashion and You+All",0,0,0,0,1,0,0,0,0,0,0 5284,30,"Our mission was to provide quality, affordable womens clothing that reflected the biggest global fashion trends",0,0,0,0,0,0,0,0,0,0,0 5284,31,"Since then, Ally Fashion has expanded to over 180 stores across Australia, a global online fashion destination delivering to over 70 countries worldwide, and a successful employer providing fulfilling careers to over 1,000 staff",0,0,0,1,1,0,0,0,0,0,0 5284,32,"Our operations consist of design, fabrication, manufacturing, retail, corporate, customer service and warehouse functions",0,0,0,0,1,0,0,0,0,0,0 10291,87,"To that effect, Atturra has implemented the following policies, processes and tools to assist in the detection and prevention of modern slavery risks",0,0,0,0,0,0,0,0,0,0,0 10291,88,"Policies, processes and procedures Our actions",0,0,0,0,0,0,0,0,0,0,0 10291,89,"Code of Conduct: Atturra is committed to making pos- itive economic, social and environmental contributions to each of the communities in which it operates, while complying with all applicable laws and regulations and acting in a manner that is with honesty, integrity, fairness and respect",0,0,0,0,0,0,0,0,0,0,0 10291,90,Atturras Code of Conduct provides a frame- work for decisions and actions to ensure its duty of care to all employees and stakeholders,0,0,0,0,0,0,0,1,0,0,0 10291,91,b) Anti-Slavery Policy: Atturra has adopted an Anti-Slavery Policy which affirms Atturras commitment to upholding its responsibility to comply with all modern slavery laws and regulations,0,0,0,0,0,0,0,1,0,0,0 10291,92,"The policy sets out Atturras commitment to identify, reduce and mitigate the risk of modern slavery practices within its supply chain and business opera- tions",0,0,0,0,0,0,0,0,0,0,0 10291,93,This policy also supports Atturras mission to act with integrity to achieve the best outcomes for its clients,0,0,0,0,0,0,0,0,0,0,0 10291,94,To read the full policy visit https://atturra.com/au-en/ anti-slavery-policy,0,0,0,0,0,0,0,0,0,0,0 373,14,Specialised Freight Services,0,0,0,0,0,0,0,0,0,0,0 373,15,"Logistics: specialist contract logistics providing a range of customised transport, warehousing, and value- added services around the Asia Pacific region, including warehouse logistics, mining services, energy logistics, dangerous goods storage, dedicated transport services, liquid distribution, relocation management, remote and resource logistics, aviation services and helicopter services",0,0,0,0,1,0,0,0,0,0,0 373,16,Express Services: express freight of documents and parcels within Australia and New Zealand,0,0,0,0,1,0,0,0,0,0,0 373,17,"Business Support Services: a suite of business support services that includes recruitment and training, design print and promotion, mailroom services and relocation management",0,0,0,0,1,0,0,0,0,0,0 373,18,"For further details of the services we offer, please refer to our website",0,0,0,0,0,0,0,0,0,0,0 373,19,Commonwealth Modern Slavery Act 2018 Guidance for Reporting Entities 2 Commonwealth Modern Slavery Act 2018 Guidance for Reporting Entities,0,0,0,0,0,0,0,0,0,0,0 373,20,Modern Slavery Statement FY20 v01,0,0,0,0,0,0,0,0,0,0,0 373,21,"Page 2 of 5 Our Supply Chain To assist in the delivery of these services, Toll works with an extensive network of suppliers, subcontractors and agents",0,0,0,0,0,1,0,0,0,0,0 3584,17,"MRAU, and GLA are authorised by the Australian Prudential Regulation Authority (APRA) to operate as general insurers in Australia",0,0,0,0,1,0,0,0,0,0,0 3584,18,MRA is authorised by APRA to operate as a life insurer in Australia,0,0,0,0,1,0,0,0,0,0,0 3584,19,MHA acts as a holding company for MRA and employs all staff in Australia,0,0,0,1,0,0,0,0,0,0,0 3584,20,"As a globally operating organisation, Munich Re procures many different goods and services throughout the world",0,0,0,0,0,1,0,0,0,0,0 3584,21,"By purchasing at best total value in terms of quality, time and cost, while ensuring compliance at all times, the procurement functions throughout the Group seek to deliver a substantial and lasting contribution to the success of Munich Re",0,0,0,0,0,0,0,0,0,0,0 3584,22,"Munich Re has established a due diligence process for identi- fying, analysing, assessing, and managing potential risks of modern slavery within our supply chains, which we describe in more detail for all identified dimensions below",0,0,0,0,0,0,0,0,0,0,0 3584,23,All Munich Re processes and rules described below apply to all reporting entities,0,0,0,0,0,0,0,0,0,0,0 3584,24,Measures that apply only to GLISE are described as such,0,0,0,0,0,0,0,0,0,0,0 5284,33,Ally Fashions in-house design team designs product ranges which are manufactured in-house at our factories in China,0,0,0,0,1,0,0,0,0,0,0 5284,34,"Our head office comprises support functions including finance, marketing, IT, buying, design, quality assurance, store development and management, visual merchandising, operations, supply chain and logistics, legal, human resources, and planning",0,0,0,0,1,0,0,0,0,0,0 5284,35,Merchandise is distributed to our store networks and online orders received via our websites are fulfilled via Ally Fashions warehouses located in Australia,0,0,0,0,1,0,0,0,0,0,0 5284,36,Ally Fashions stores are stocked with products that are sourced internationally by both our brand partners as well as our own in-house designed brands with supply chains located in China,0,0,0,0,0,1,0,0,0,0,0 5284,37,"In this reporting period, we have chosen to focus on the present risks with our current suppliers and contractors, since we possess the strongest relationships with these businesses, and have the greatest influence within these groups",0,0,0,0,0,0,0,0,0,0,0 5284,38,"In the future, this will be addressed by assessing and understanding risks that exist within our suppliers supply chains",0,0,0,0,0,0,0,0,0,0,0 5284,39,Our Supply Chain,0,0,0,0,0,0,0,0,0,0,0 5284,40,"Our product design team is based in our Sydney head office, with all our products manufactured by our manufacturing team in China",0,0,0,0,1,0,0,0,0,0,0 10291,95,"c) Nomination and Remuneration Committee: At Atturra, we have processes in place to ensure employees are paid correctly and the hours worked by employees are monitored",0,0,0,0,0,0,0,1,0,0,0 10291,96,"The Nomination and Remuneration Committee oversees the process of appointment and remuneration of directors, senior executives and employees of Atturra",0,0,0,0,0,0,0,1,0,0,0 10291,97,d) Audit and Risk Committee: The objective of the Committee is to ensure the Company appropriately manages its business and operating risks,0,0,0,0,0,0,0,1,0,0,0 10291,98,"Part of these risks include economic, environmental and social sus- tainability risks which can extend to modern slavery risks in Atturras operations",0,0,0,0,0,0,0,1,0,0,0 10291,99,"e) Recruitment processes: Atturra understands modern slavery risks can occur where workers are charged illegal or excessive recruitment fees, are uninformed about the terms of employment or are fraudulently charged fees for work documentation",0,0,0,0,0,0,0,0,0,0,0 10291,100,"Consequently, for direct workers we aim to recruit directly without the use of recruitment services",0,0,0,0,0,0,0,1,0,0,0 10291,101,"Atturra avoids deceptive recruiting issues through finding workers via advertising and referrals, an interview process where the role expectations are clearly commu- nicated and directly engaging with the potential worker to discuss employment terms and pay details",0,0,0,0,0,0,0,1,0,0,0 10291,102,"Where Atturra uses external recruiters for direct workers, Atturra",0,0,0,0,0,0,0,1,0,0,0 373,22,"These include the suppliers of products and services used in our transport and warehousing activities, such as trucks, planes, ships, helicopters, materials handling equipment, IT equipment and personal equipment and clothing",0,0,0,0,0,1,0,0,0,0,0 373,23,"Our supply chain also includes the services provided by subcontractors and agents, mainly for the transport of goods",0,0,0,0,0,1,0,0,0,0,0 373,24,"This is particularly relevant for Freight/Global Forwarding, for which Toll engages a number of third parties to assist with completing these orders3",0,0,0,0,0,1,0,0,0,0,0 373,25,"In many cases we have long- standing relationships with these businesses, and in other cases short-term arrangements are made based on the requirements of our clients",0,0,0,0,0,1,0,0,0,0,0 373,26,An overview of the countries in which we operate as well as those in which we work with network partners can be seen below,0,0,0,0,0,0,0,0,0,0,0 373,27,"Risks of Modern Slavery in Operations & Supply Chains Operating in the global logistics sector, we are aware of the potential for Toll to cause, contribute to or be linked to modern slavery through our operations and supply chains.4 Operations Taking into account the activities of Tolls global operations, there is a risk of causing or contributing to modern slavery through the use of labour in vulnerable populations, high risk geographies or through the engagement of recruitment agencies",0,0,0,0,1,0,1,0,0,0,0 373,28,"Whilst Toll operates worldwide, nearly half of employees and a significant proportion of suppliers are based in Australia and New Zealand which somewhat decreases the geographical risk",0,0,0,0,0,0,1,0,0,0,0 373,29,"However, as our company continues to grow both locally and globally, we are aware of the risks and the need to address these in an appropriate manner",0,0,0,0,0,0,0,0,0,0,0 3584,25,Munich Res Statement on the Australian Modern Slavery Act Page 2/6 Munich Res policies in relation to slavery and human trafficking Munich Re is convinced that its business model can only be successfully realised in the future through long-term and responsible action,0,0,0,0,0,0,0,0,0,0,0 3584,26,"Therefore, we are committed to upholding human rights as defined in the UN Guiding Principles on Business and Human Rights, in the International Bill of Human Rights1, and in the Declaration on Fundamental Principles and Rights at Work issued by the International Labour Organization (ILO)",0,0,0,0,0,0,0,1,0,0,0 3584,27,"In addition, we emphasised and embraced our responsibility to uphold human rights by committing to the ten principles of the United Nations Global Compact in 2007",0,0,0,0,0,0,0,1,0,0,0 3584,28,These same principles are incorporated in our Group Code of Conduct,0,0,0,0,0,0,0,1,0,0,0 3584,29,"As a signatory to the UN Global Compact, Munich Re is committed to",0,0,0,0,0,0,0,0,0,0,0 3584,30,Promoting and observing the protection of internationally recognised human rights,0,0,0,0,0,0,0,0,0,0,0 3584,31,Making sure that the Group is not complicit in human rights abuses,0,0,0,0,0,0,0,0,0,0,0 3584,32,Upholding the freedom of association and the effective recognition of the right to collective bargaining,0,0,0,0,0,0,0,0,0,0,0 5284,41,"Our main sourcing country is China, which accounts for over 90% of our products",0,0,0,0,0,1,0,0,0,0,0 5284,42,"We have held solid relationships with some of our suppliers, the majority of whom we have dealt with over the last 15 years",0,0,0,0,0,1,0,0,0,0,0 5284,43,POL MODERN SLAVERY STATEMENT Process Owner: Human Resources Authorised: Head of HR Ref,0,0,0,0,0,0,0,0,0,0,0 5284,44,Number: 2.1 Page: 3 Date: 20 June 2021,0,0,0,0,0,0,0,0,0,0,0 5284,45,"Identifying the risks of Modern Slavery At Ally Fashion, we fully understand that the apparel industry carries several inherent and complex risks of modern slavery throughout all tiers of the supply chain at a global scale",0,0,0,0,0,0,1,0,0,0,0 5284,46,"Operational functions of the apparel and retail industry carry their own varied and distinct risks, and require additional consideration and assessment of risks to ensure that there modern slavery is minimised to a reasonably practical extent at each level of the supply chain",0,0,0,0,0,0,1,0,0,0,0 5284,47,"Our current checklist for ensuring we do not work with suppliers or contractors that engage in any form of Modern Slavery provides us with full visibility across all steps and levels of our supply chain, from the businesses we source our fabrics from, to the suppliers we use for shipping our products to customers worldwide",0,0,0,0,0,0,0,0,0,0,0 5284,48,"In Australia, we have determined the risks of modern slavery associated with our operations to be low",0,0,0,0,0,0,1,0,0,0,0 10291,103,Atturra Modern Slavery Statement FY22,0,0,0,0,0,0,0,0,0,0,0 10291,104,Modern Slavery Committee: Atturra established a Modern Slavery Committee which is comprised of 3 key executives that meet regularly to determine and review the actions being taken to detect and prevent modern slavery in Atturras supply chain,0,0,0,0,0,0,0,0,0,1,0 10291,105,"As at the date of this Statement, the Modern Slavery Committee has discussed and prepared policies relating to modern slavery and undertaken risk assessment pro- cesses including supply chain mapping and the follow up questionnaire",0,0,0,0,0,0,0,1,0,0,0 10291,106,"Additionally, the Modern Slavery Committee has prepared and delivered training to key personnel, prepared this Statement and discussed processes and procedures for managing modern slavery risks in this and the next reporting period",0,0,0,0,0,0,0,1,0,0,0 10291,107,"b) Supply chain mapping: Atturra undertakes due dili- gence in respect of its key suppliers to ensure that these parties are aligned with Atturra policies, codes and values",0,0,0,0,0,0,0,1,0,0,0 10291,108,"Supply chain mapping involves categorising suppliers by risks associated with their geographic location, size and industry",0,0,0,0,0,0,0,1,0,0,0 10291,109,This has been a key part of identifying and assessing actual and potential human rights impacts in accordance with UN Guiding Principle 17,0,0,0,0,0,0,0,1,0,0,0 10291,110,c) Follow up questionnaire: Atturra requires suppliers iden- tified as medium risk during the supply chain mapping exercise to complete a modern slavery risk questionnaire to ensure compliance with modern slavery laws and to identify any issues,0,0,0,0,0,0,0,1,0,0,0 373,30,"Supply Chain Toll works with an extensive network of suppliers, subcontractors and agents to provide the vast array of services around the globe",0,0,0,0,0,1,1,0,0,0,0 373,31,As such Toll is at risk of contributing to or being directly linked to modern slavery abuses relating to the activities of these business relations,0,0,0,0,0,0,1,0,0,0,0 373,32,"The extent of these is dependent on a number of factors including the level of human rights protection and/or enforcement in the countries where they operate or source from, use of labour hire and outsourcing practices",0,0,0,0,0,0,0,0,0,0,0 373,33,This is also applicable to suppliers from which we source the products and services we require to operate,0,0,0,0,0,0,0,0,0,0,0 373,34,Implications of COVID-19 on Tolls Operations and Supply Chain The lockdowns and border closures that were implemented by governments around the world to slow the spread of COVID-19 restricted the movement of goods globally,0,0,0,0,0,0,0,0,0,0,0 373,35,This had significant implications on Tolls global direct operations and supply chain,0,0,0,0,0,0,0,0,0,0,0 373,36,"In some instances, this was further compounded by bottlenecks created by additional protocols introduced to ensure the safety of workers",0,0,0,0,0,0,0,0,0,0,0 373,37,The pressure to make up this lost time poses an additional risk to our employees and contractors to work long hours and ignore general health and safety practices,0,0,0,0,0,0,0,0,0,0,0 3584,33,Advocating the elimination of all types of forced labour,0,0,0,0,0,0,0,0,0,0,0 3584,34,Championing the abolition of child labour,0,0,0,0,0,0,0,0,0,0,0 3584,35,"Helping put an end to discrimination in hiring and employment The Munich Re Board of Management has formulated its own position on human rights, which you can find on the Munich Re website",0,0,0,0,0,0,0,0,0,0,0 3584,36,"Munich Res due diligence processes in relation to slavery and human trafficking in its business and supply chains In order to bring our commitment to respecting human rights to life, Munich Re has developed a due diligence process that covers the key components of human-rights due diligence",0,0,0,0,0,0,0,0,0,0,0 3584,37,Policy commitment of the Board of Management to respect human rights,0,0,0,0,0,0,0,0,0,0,0 3584,38,Identifying and assessing human rights risks and impacts,0,0,0,0,0,0,0,0,0,0,0 3584,39,Implementing measures and monitoring,0,0,0,0,0,0,0,0,0,0,0 3584,40,Reporting and communicating,0,0,0,0,0,0,0,0,0,0,0 5284,49,A preliminary assessment of our operations in China has identified that our network of lower-level and infrequently used suppliers as necessitating further scrutiny and due diligence to understand any potential risks of vulnerable worker groups including temporary and migrant workers,0,0,0,0,0,1,1,0,0,0,0 5284,50,These activities have already commenced but are not yet at the level where results can be reported on,0,0,0,0,0,0,1,0,0,0,0 5284,51,The use of recruitment agencies in our China operations is low,0,0,0,0,0,1,0,0,0,0,0 5284,52,We also recognise the following risk factors in the apparel sector as indicators of the potential of modern slavery to occur,0,0,0,0,0,0,1,0,0,0,0 5284,53,unauthorised subcontracting,0,0,0,0,0,0,1,0,0,0,0 5284,54,sham contracting,0,0,0,0,0,0,1,0,0,0,0 5284,55,underpayment of wages,0,0,0,0,0,0,1,0,0,0,0 5284,56,consistent and excessive overtime,0,0,0,0,0,0,1,0,0,0,0 10291,111,"The follow up questionnaire covered questions including but not limited to the suppliers policies and procedures for modern slavery, compliance with legislation and the potential for modern slavery risks in their operations or supply chain",0,0,0,0,0,0,0,1,0,0,0 10291,112,Significant issues are escalated to senior management,0,0,0,0,0,0,0,1,0,0,0 10291,113,"From the collated responses, Atturra was able to better identify and assess the actual and potential adverse human rights impacts including modern slavery in its supply chains",0,0,0,0,0,0,0,0,0,0,0 10291,114,"Any significant issues arising out of the questionnaires were to be escalated to senior man- agement, however, none were reported",0,0,0,0,0,0,0,1,0,1,0 10291,115,"Ultimately, the questionnaire provided comfort that Atturras suppliers were acting in compliance with Australian laws and regulations and assurance that there is a limited risk of modern slavery in Atturras supply chain",0,0,0,0,0,0,0,0,0,0,0 10291,116,"Further, it improved Atturras oversight and visibility over its supply chain and demonstrated the actions its suppliers were Due diligence and remediation During the Reporting Period, Atturra engaged in due diligence and remediation processes in line with the UN Guiding Principles to identify, prevent, mitigate and account for how we address our modern slavery risks",0,0,0,0,0,0,0,0,0,0,0 10291,117,pays all associated fees and exercises due diligence in ensuring the candidate does not pay unfair or unreason- able recruitment fees,0,0,0,0,0,0,0,1,0,0,0 10291,118,f) Our values: Our core values underpin everything we do,0,0,0,0,0,0,0,0,0,0,0 373,38,It has also exposed our workforce to the risk of contracting the virus,0,0,0,0,0,0,0,0,0,0,0 373,39,"Actions Taken to Assess and Address the Risk of Modern Slavery We are taking a long-term systematic approach to integrating an ethical supply chain framework and increasing engagement with suppliers to identify risk, assess and address modern slavery",0,0,0,0,0,0,0,1,0,0,0 373,40,"Policies & Governance In FY20, Tolls values were refreshed and work shopped with senior leaders",0,0,0,0,0,0,0,0,0,0,0 373,41,The values have been rolled out in FY21 to represent the Toll we want to be,0,0,0,0,0,0,0,0,0,0,0 373,42,The refreshed values form a compass that will guide our behaviour and define our culture,0,0,0,0,0,0,0,0,0,0,0 373,43,https://www.tollgroup.com/freight 4 Commonwealth Modern Slavery Act 2018 Guidance for reporting entities p40,0,0,0,0,0,0,0,0,0,0,0 373,44,Modern Slavery Statement FY20 v01,0,0,0,0,0,0,0,0,0,0,0 373,45,"Page 3 of 5 In line with these values are Tolls policies and standards, which influence our behaviour towards Modern Slavery",0,0,0,0,0,0,0,1,0,0,0 3584,41,"Remedy and grievance mechanism Assessment of human rights risks In a systematic evaluation of potential risks, Munich Re defined the following four dimensions as critical to upholding human rights: employees, procurement, our insurance business (primary insurance and reinsurance), and investment manage- ment",0,0,0,0,0,0,0,0,0,0,0 3584,42,"For each of these dimensions, we identify, assess and, if necessary, mitigate potential risks with regard to the infringement of human rights",0,0,0,0,0,0,0,0,0,0,0 3584,43,We place particular emphasis on our core business and investments,0,0,0,0,0,0,0,0,0,0,0 3584,44,"We are con- scious of the fact that there is a range of industries and projects that may have a major impact on the environment, local communities and other stakeholder groups",0,0,0,0,0,0,0,0,0,0,0 3584,45,"The systematic anchoring of environmental, social and governance (ESG) aspects in core business enables us to identify these risks and, in cooperation with our clients, to minimise them as far as possible",0,0,0,0,0,0,0,0,0,0,0 3584,46,"With this in mind, we have specific analysis tools in place",0,0,0,0,0,0,0,0,0,0,0 3584,47,We established twelve generally applicable ESG aspects which explic- itly include human rights and labour rights,0,0,0,0,0,0,0,1,0,0,0 3584,48,"These aspects help to identify industrial sectors with high ESG risk exposure, thus allowing sensitive business topics to be recognised",0,0,0,0,0,0,0,1,0,0,0 5284,57,"the use of migrant, low-skilled workers",0,0,0,0,0,0,1,0,0,0,0 5284,58,temporary labour contracts; and/or,0,0,0,0,0,0,1,0,0,0,0 5284,59,lack of access to effective grievance mechanisms,0,0,0,0,0,0,1,0,0,0,0 5284,60,We acknowledge that the subject of a lot of these vulnerabilities are,0,0,0,0,0,0,1,0,0,0,0 5284,61,female workers,0,0,0,0,0,0,1,0,0,0,0 5284,62,migrant labour,0,0,0,0,0,0,1,0,0,0,0 5284,63,subcontracted labour,0,0,0,0,0,0,1,0,0,0,0 5284,64,agency and temporary/contract labour; and,0,0,0,0,0,0,1,0,0,0,0 10291,119,"Atturras core values are integrity, excellence, respect and innovation",0,0,0,0,0,0,0,0,0,0,0 10291,120,Our staff members are expected to act in accordance with our values,0,0,0,0,0,0,0,0,0,0,0 10291,121,Assessing effectiveness Atturra recognises the importance of continuous improvement by regularly assessing the effectiveness of our actions taken to address modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 10291,122,"In doing this, Atturra aims to build more transparent and open relationships with our suppliers in order to mitigate the risk of modern slavery in our operations and supply chain",0,0,0,0,0,0,0,0,0,0,0 10291,123,"The actions taken by Atturra during the reporting period have been effective in enabling Atturra to proactively identify, assess and mitigate any potential risk of modern slavery and human trafficking in its operations and supply chain",0,0,0,0,0,0,0,0,0,0,0 10291,124,Atturra has increased due diligence efforts on those industry areas that we consider to be higher risk for us and will continue to increase due diligence processes into the next reporting period,0,0,0,0,0,0,0,0,0,0,0 10291,125,taking to assess and address modern slavery risks in their own operations and supply chain,0,0,0,0,0,0,0,0,0,0,0 10291,126,"d) Training: At Atturra, we foster a culture of compliance, continuous improvement, integrity and honesty which is reflected in the way we conduct our business",0,0,0,0,0,0,0,0,0,0,0 373,46,Toll Group Code of Practice,0,0,0,0,0,0,0,0,0,0,0 373,47,Toll Group Anti-Human Trafficking and Modern Slavery Policy,0,0,0,0,0,0,0,0,0,0,0 373,48,Toll Group Ethical Employment Policy,0,0,0,0,0,0,0,0,0,0,0 373,49,Toll Group Employment Screening Policy,0,0,0,0,0,0,0,0,0,0,0 373,50,Toll Group Supplier Code of Practice,0,0,0,0,0,0,0,0,0,0,0 373,51,Toll Group Whistleblower Policy,0,0,0,0,0,0,0,0,0,0,0 373,52,"Toll Group Serious Misconduct Policy The day to day responsibility for developing these policies and overseeing compliance is assigned to relevant departments including Compliance & Security, HR, Procurement and Legal",0,0,0,0,0,0,0,1,0,0,0 373,53,These policies and standards are upheld in everything we do,0,0,0,0,0,0,0,0,0,0,0 3584,49,"Questionnaires specially tailored to these topics were integrated into an ESG tool, which helps our underwriters systematically take ESG aspects into account when performing risk assessments",0,0,0,0,0,0,0,1,0,0,0 3584,50,"In addition, we have created a risk mapping tool specifically for human rights",0,0,0,0,0,0,0,1,0,0,0 3584,51,This tool is designed to aid our employees in categorising and evaluating countries and economic sectors as per various indices and human rights topics,0,0,0,0,0,0,0,1,0,0,0 3584,52,"We consider the following topics when mapping risks by country: child labour and forced labour; 1 Including the Universal Declaration of Human Rights; the International Covenant on Civil and Political Rights; and the International Covenant on Economic, Social and Cultural Rights",0,0,0,0,0,0,0,1,0,0,0 3584,53,"Munich Res Statement on the Australian Modern Slavery Act Page 3/6 discrimination on the basis of gender, sexuality or religion; corruption; threats to communities; restrictions on peoples liberty or freedom; international and domestic conflicts",0,0,0,0,0,0,0,1,0,0,0 3584,54,"When we analyse sector risks, we focus on working conditions, child labour and forced labour, occupational health risks, and the sources of commodities",0,0,0,0,0,0,0,1,0,0,0 3584,55,Measures to manage human rights risks in Munich Res supply chains,0,0,0,0,0,0,0,0,0,0,0 3584,56,"Measures for each risk dimension For each of the four risk dimensions that we have defined employees, procurement, our (re)insurance business and investment management we have implemented measures, norms (incl",0,0,0,0,0,0,0,0,0,0,0 5284,65,underage children,0,0,0,0,0,0,1,0,0,0,0 5284,66,POL MODERN SLAVERY STATEMENT Process Owner: Human Resources Authorised: Head of HR Ref,0,0,0,0,0,0,0,0,0,0,0 5284,67,Number: 2.1 Page: 4 Date: 20 June 2021,0,0,0,0,0,0,0,0,0,0,0 5284,68,"Actions Taken to Address Modern Slavery Risks and Next Steps Our approach is embedded into our policy frameworks and processes, resourcing practices, supplier and contractor engagement, and industry partnerships",0,0,0,0,0,0,0,0,0,0,0 5284,69,"Our Leadership team shares responsibility for overseeing Ally Fashions risk management and compliance framework, and ensuring its implementation and delivery",0,0,0,0,0,0,0,1,0,0,0 5284,70,"A cross-functional and regional modern slavery working group will be established in 2021, and these members will collectively be tasked with developing a standardised operational and supply chain due diligence approach across Ally Fashion",0,0,0,0,0,0,0,1,0,0,0 5284,71,"Our current policy framework establishes the standards by which we operate as well as outlining responsibilities and expectations regarding workplace behaviour, compliance with relevant laws and regulations, bribery and corruption, harassment, and conflicts of interest",0,0,0,0,0,0,0,1,0,0,0 5284,72,"Across the regions in which we operate, our suite of policies and employee handbooks contain the following policies",0,0,0,0,0,0,0,1,0,0,0 10291,127,"Atturras modern slavery obligations and policies, procurement process, and awareness of modern slavery risks are communicated to Atturras employees through live and recorded training sessions",0,0,0,0,0,0,0,1,0,0,0 10291,128,"This training is delivered to senior management and personnel involved in procure- ment such as staff in the Marketing, HR, Talent Acquisition, Finance and IT departments",0,0,0,0,0,0,0,1,0,0,0 10291,129,"We encourage our directors, senior managers, suppliers, contractors and personnel to report any concerns or suspected breaches to our Anti-Slavery Policy",0,0,0,0,0,0,0,1,0,0,0 10291,130,"The Atturra Whistleblower Policy protects and safeguards the con- fidentiality, wellbeing and career of any individual who asserts any issues that affect the integrity of Atturras business operations",0,0,0,0,0,0,0,1,0,0,0 10291,131,"e) Whistleblower Protection: Atturras Whistleblower Policy protects employees, service providers and suppliers who voice their concerns about certain events or conduct in the business that may be unlawful or unethical",0,0,0,0,0,0,0,1,0,0,0 10291,132,"The policy validates Atturras efforts in safeguarding the confidenti- ality, wellbeing and career of any individual who asserts any issues that affect the integrity of Atturras business operations",0,0,0,0,0,0,0,0,0,0,0 10291,133,f) Continuous monitoring and Public Communication: Atturra will continue to monitor and assess modern slavery risks and we will publicly communicate our actions taken to address these risks by publishing a Modern Slavery Statement annually (as required),0,0,0,0,0,0,0,0,0,0,0 10291,134,Atturra Modern Slavery Statement FY22 Atturra is focused on continuously strengthening its proce- dures and processes to combat modern slavery practices and ensuring the protection of human rights,0,0,0,0,0,0,0,0,0,0,0 373,54,"We consider that, on the whole, the implementation of our company values and policies establishes an ethical culture and environment in which knowingly allowing human slavery or abuse to enter Tolls operations or supply chain will not be tolerated",0,0,0,0,0,0,0,0,0,0,0 373,55,A copy of these policies is publicly available on our website,0,0,0,0,0,0,0,0,0,0,0 373,56,"Supplier Governance Framework The Toll Group Supplier Code of Practice (Supplier Code"") sets out the behaviours Toll expects from suppliers",0,0,0,0,0,0,0,1,0,0,0 373,57,"This includes Tolls expectation that our suppliers will act with respect and comply with applicable employment and workplace laws and regulations, including labour and child labour laws",0,0,0,0,0,0,0,1,0,0,0 373,58,The Supplier Code reserves Tolls right to audit suppliers and their operations,0,0,0,0,0,0,0,1,0,0,0 373,59,"If a supplier fails to act consistently with the Supplier Code or specific contractual obligations, this may result in remedial action or termination of a contract",0,0,0,0,0,0,0,0,1,0,0 373,60,The Supplier Code is available on our website,0,0,0,0,0,0,0,0,0,0,0 373,61,Review of Operations and Supply Chains In 2019 Toll commenced a review of our potential modern slavery risks across our operations and supply chain,0,0,0,0,0,0,0,1,0,0,0 3584,57,"underwriting guidelines), and governance instruments",0,0,0,0,0,0,0,0,0,0,0 3584,58,This enables us to reduce or mitigate risks with regard to violations of human rights; these approaches also guide our decision-making in line with conscientious management practices,0,0,0,0,0,0,0,0,0,0,0 3584,59,"As an employer, Munich Re observes international human rights standards and provides optimum working conditions for its staff with special focus on occupational health and safety, promoting diversity, and equal opportunities",0,0,0,0,0,0,0,1,0,0,0 3584,60,Our Group-wide Diversity Policy sets down the most important principles in this action field and forms the basis for overarching and comprehensive diversity management,0,0,0,0,0,0,0,1,0,0,0 3584,61,"The focus areas of gender, different generations and internationality are key for our activities",0,0,0,0,0,0,0,1,0,0,0 3584,62,Equal treatment is an inherent part of our corporate culture,0,0,0,0,0,0,0,1,0,0,0 3584,63,"Our Code of Conduct and additional self-commitments for responsible behaviour specify that we expect our employees to observe the personal dignity, privacy and personality rights of every individual",0,0,0,0,0,0,0,1,0,0,0 3584,64,"We do not tolerate any discrimination (on grounds of age, sex, ethnic origin, nationality, political opinion, race, religion or the like), sexual harass- ment, other personal harassment, or insulting behaviour",0,0,0,0,0,0,0,1,0,0,0 5284,73,Code of Conduct,0,0,0,0,0,0,0,1,0,0,0 5284,74,Background Checking,0,0,0,0,0,0,0,1,0,0,0 5284,75,Communication Guidelines,0,0,0,0,0,0,0,0,0,0,0 5284,76,COVID-19 Policy,0,0,0,0,0,0,0,0,0,0,0 5284,77,Customer Service Standards Policy,0,0,0,0,0,0,0,0,0,0,0 5284,78,Environmental Statement,0,0,0,0,0,0,0,0,0,0,0 5284,79,Equality and Diversity Policy,0,0,0,0,0,0,0,0,0,0,0 5284,80,Ethical Sourcing Policy,0,0,0,0,0,0,0,1,0,0,0 10291,135,"In doing this, we aim to build more transparent and open relationships with our suppliers in order to mitigate the risk of modern slavery in our operations and supply chain",0,0,0,0,0,0,0,0,0,0,0 10291,136,"In preparation of this Statement, Atturra consulted with external legal advisers on its modern slavery processes to comply with requirements under the Act and to advise on best practice",0,0,0,0,0,0,0,0,0,1,0 10291,137,"Atturra will continue to monitor, evaluate and assess the effec- tiveness of its established procedures by",0,0,0,0,0,0,0,0,0,1,0 10291,138,"monitoring Atturras existing suppliers and undertaking risk assessments in relation to new suppliers to as certain whether they pose a modern slavery risk and, if they do, to reduce that risk to the maximum extent possible",0,0,0,0,0,0,0,0,0,1,0 10291,139,"continually assessing the effectiveness of our actions in identifying and managing modern slavery risks, particularly by undertaking regular internal governance processes in accordance with our governance policies",0,0,0,0,0,0,0,0,0,1,0 10291,140,"reviewing and updating training material to ensure that it is up to date, relevant and effective",0,0,0,0,0,0,0,0,0,1,0 10291,141,reviewing Atturras policies and implementing a Supplier Code of Conduct for the next financial year to ensure they remain relevant and in compliance with all applicable laws; and,0,0,0,0,0,0,0,0,0,1,0 10291,142,engaging with Atturras suppliers and key customers to verify they are following through with any modern slavery actions they have committed to undertaking,0,0,0,0,0,0,0,0,0,1,0 373,62,This review began with identifying the relative risk of the countries in which we operate using the Global Slavery Index (GSI),0,0,0,0,0,0,0,1,0,0,0 373,63,We also engaged with key internal and external stakeholders to gain a better understanding of the potential risks,0,0,0,0,0,0,0,1,0,0,0 373,64,"Toll will build on this work in FY21 by undertaking a formal human rights risk assessment to identify and prioritise human rights risks, including those relating to modern slavery",0,0,0,0,0,0,0,1,0,0,0 373,65,Given the global and diverse nature of our operations and supply chain we will take a step-by-step approach to addressing the identified risks to ensure they are addressed in a robust and effective manner,0,0,0,0,0,0,0,1,0,0,0 373,66,"Further to this, modern slavery questions have been added to the global Compliance Due Diligence questionnaire which was updated in late 2019 which is used as a tool to identify and engage with our network agents5",0,0,0,0,0,0,0,1,0,1,0 373,67,This was rolled out in late 2019 with a review undertaken in early 2020 to improve the process,0,0,0,0,0,0,0,1,0,1,0 373,68,"In FY20, Group HR initiated a global review of procedures for engagement of labour and recruitment practices globally with the aim to develop a unified approach throughout our growing global operations",0,0,0,0,0,0,0,0,0,1,0 373,69,As part of this review additional controls are being considered to mitigate modern slavery risks and we are working towards reducing the total number of recruitment agencies,0,0,0,0,0,0,0,1,0,0,0 3584,65,"With regard to all our procurement decisions and activities, we always observe the principles of compliance, and we embrace corporate responsibility throughout the value chain",0,0,0,0,0,0,0,1,0,0,0 3584,66,"Environmental, social and governance (ESG) criteria play a pivotal role in our procurement of goods and services",0,0,0,0,0,0,0,1,0,0,0 3584,67,We ensure compliance with ESG criteria and acceptance of the ten principles of the UN Global Compact in our day-to-day interaction with suppliers,0,0,0,0,0,0,0,1,0,0,0 3584,68,"To ensure compliance with the UN Global Compact within the supplier relationship, Munich Re implements a Corporate Responsibility (CR) clause into its standard contracts",0,0,0,0,0,0,0,1,0,0,0 3584,69,"If we believe the principles of the UN Global Com- pact have been breached, Munich Re reserves the right to cancel the contractual relationship by way of extraordinary termination for good cause",0,0,0,0,0,0,0,0,1,0,0 3584,70,"If a new supplier wishes to do business with Munich Re, it must first complete a supplier registration process",0,0,0,0,0,0,0,0,1,0,0 3584,71,"Using a self-disclosure questionnaire, it is requested to provide key informa- tion on the subject of sustainability",0,0,0,0,0,0,0,0,1,0,0 3584,72,This information also addresses aspects relevant for exclusion criteria (refusal to sign the CR clause can be an exclusion criterion),0,0,0,0,0,0,0,0,1,0,0 5284,81,Fair and Equitable Workplace,0,0,0,0,0,0,0,1,0,0,0 5284,82,Gifts and Gratuities Policy,0,0,0,0,0,0,0,0,0,0,0 5284,83,Grievance Handling Policy,0,0,0,0,0,0,0,1,0,0,0 5284,84,HR Privacy Policy,0,0,0,0,0,0,0,0,0,0,0 5284,85,ICT System Usage Policy,0,0,0,0,0,0,0,0,0,0,0 5284,86,Leave Policy,0,0,0,0,0,0,0,0,0,0,0 5284,87,Drug and Alcohol Policy,0,0,0,0,0,0,0,0,0,0,0 5284,88,Manual Handling Policy,0,0,0,0,0,0,0,0,0,0,0 10291,143,"Consultation COVID-19 pandemic Throughout the COVID-19 pandemic, Atturra has consistently complied with Australian government regulations and health advice to ensure the health and safety of our personnel",0,0,0,0,0,0,0,0,0,0,0 10291,144,"To date, the COVID-19 pandemic has had a minimal impact on Atturras operations as our consultants are generally able to work remotely",0,0,0,0,0,0,0,0,0,0,0 10291,145,"However, Atturra recognises this may not be the case for its suppliers and/or stakeholders",0,0,0,0,0,0,0,0,0,0,0 10291,146,"While there has not been an increased risk of modern slavery due to COVID-19 for Atturras operations or supply chain, Atturra has continued to prioritise stakeholder and supplier engagement to ensure modern slavery risks are identified, assessed and mitigated in the context of the COVID-19 pandemic during the reporting period",0,0,0,0,0,0,1,0,0,0,0 10291,147,Future commitments Atturra is committed to further developing our processes as we progress our understanding about the modern slavery risks in our operations and supply chains and ways to mitigate them,0,0,0,0,0,0,0,0,0,0,0 10291,148,Atturra takes a continuous improvement approach to compli- ance to ensure that we are demonstrating our progress over time as the business community increases its understanding of modern slavery,0,0,0,0,0,0,0,0,0,0,0 10291,149,"Over the next year, we intend to continue assessing the risks in our operations and supply chain through our Modern Slavery Committee, supply chain mapping, ques- tionnaires, training and other actions taken",0,0,0,0,0,0,0,1,0,0,0 10291,150,The board of directors in their capacity as principal governing body of Atturra Limited have approved this Statement on 7 October 2022,1,0,0,0,0,0,0,0,0,0,0 373,70,We are also implementing a global recruitment system which will be integrated into our existing HR system,0,0,0,0,0,0,0,0,0,1,0 373,71,This will help to ensure that our policies and procedures are executed consistently throughout our operations,0,0,0,0,0,0,0,0,0,1,0 373,72,"At Toll, a Network Agent is an entity with which Toll Global Forwarding establishes a documented non-exclusive business relationship whereby Toll Global Forwarding and the Network Agent on behalf of each other perform and handle freight transportation and other related services (including international and domestic cargo transportation and logistics), limited to specific defined territories",0,0,0,0,0,0,0,0,0,0,0 373,73,Modern Slavery Statement FY20 v01,0,0,0,0,0,0,0,0,0,0,0 373,74,"Page 4 of 5 Whistleblower Hotline In December 2019, Tolls new Group Whistleblower Policy came into effect",0,0,0,0,0,0,0,1,0,0,0 373,75,This was accompanied by an extensive communication campaign aimed at increasing internal awareness of the policy and the Toll Disclosure Hotline,0,0,0,0,0,0,0,1,0,0,0 373,76,"This included widespread communications via the intranet, staff newsletters and throughout our physical operations",0,0,0,0,0,0,0,1,0,0,0 373,77,Training was also provided to relevant employees with additional information and support to those with direct obligations and responsibilities,0,0,0,0,0,0,0,1,0,0,0 3584,73,"Within the supplier registration process, it is mandatory for the supplier to confirm compliance with the UN Global Compact",0,0,0,0,0,0,0,0,1,0,0 3584,74,Munich Re has signed up to the Principles for Sustainable Insurance (PSI) and as such is committed to implementing ESG aspects that are relevant for our (re-)insurance business,0,0,0,0,0,0,0,0,1,0,0 3584,75,"The Munich Re human-rights risk mapping tool makes it possible to categorise all countries and sectors according to various human rights aspects, especially in the areas of child labour and modern slavery",0,0,0,0,0,0,0,0,1,0,0 3584,76,This tool enables all our employees to carry out an initial risk analysis quickly and easily,0,0,0,0,0,0,0,0,1,0,0 3584,77,A set of underwriting guidelines defines how all underwriters and client managers are to handle ESG risks in insurance transactions,0,0,0,0,0,0,0,0,1,0,0 3584,78,"These binding guidelines as well as best-practice recommendations were drawn up for sensitive topics and industry sectors; they are applicable for reinsurance, primary insurance and investment",0,0,0,0,0,0,0,0,1,0,0 3584,79,"These documents place particular emphasis on child labour and forced labour in mining, farming, and along their respective value chains, as well as the forced resettle- ment of indigenous communities",0,0,0,0,0,0,0,0,1,0,0 3584,80,"Human rights risks that threaten our reputation are presented as part of due diligence to the Reputational Risk Committee, which then takes a decision, possibly rejecting the risky course of action",0,0,0,0,0,0,0,0,1,0,0 5284,89,Mental Health Policy,0,0,0,0,0,0,0,0,0,0,0 5284,90,Our Way of Working,0,0,0,0,0,0,0,0,0,0,0 5284,91,Police Records Checking Policy,0,0,0,0,0,0,0,0,0,0,0 5284,92,Recruitment and Selection Policy,0,0,0,0,0,0,0,1,0,0,0 5284,93,Recruitment Referral Policy,0,0,0,0,0,0,0,1,0,0,0 5284,94,Remuneration Policy,0,0,0,0,0,0,0,1,0,0,0 5284,95,Smoke Free Workplace Policy,0,0,0,0,0,0,0,0,0,0,0 5284,96,Social Media Policy,0,0,0,0,0,0,0,0,0,0,0 10291,151,This Statement is signed by Stephen Kowal in his role as Chief Executive Officer and Director of Atturra Limited and the information in this Statement is accurate as of 30 June 2022,0,1,0,0,0,0,0,0,0,0,0 10291,152,"Atturras corporate governance policies, practices and pro- cedures, including our Anti-Slavery Policy, apply to all entities of Atturra Limited",0,0,0,0,0,0,0,0,0,0,1 10291,153,"During the Reporting Period this Statement covers, and in preparing this Statement, Atturra has consulted with key personnel within the entities it owns or controls, as required under section 16.1(f) of the Act, to ensure a compre- hensive approach to detecting and preventing modern slavery risks",0,0,0,0,0,0,0,0,0,0,1 10291,154,We discussed details of the Acts reporting requirements and criterion regarding the actions we intend to take to address these requirements,0,0,0,0,0,0,0,0,0,0,1 10291,155,"By doing this, we ensure our key personnel are aware of our commitment to identifying, assessing and addressing modern slavery risks in our supply chain and are conscious of the actions they need to take in accordance with this Statement",0,0,0,0,0,0,0,0,0,0,1 10291,156,Atturras supply chain mapping process is conducted through an analysis of each individual business unit prior to categoris- ing suppliers by risk,0,0,0,0,0,0,0,0,0,0,0 10291,157,"Additionally, modern slavery awareness training has been delivered to Atturras Executive General Managers and all other personnel involved in supplier pro- curement within Atturra",0,0,0,0,0,0,0,1,0,0,0 10291,158,/10/22,0,1,0,0,0,0,0,0,0,0,0 373,78,"The Toll Disclosure Hotline enables employees and suppliers in certain Toll locations to anonymously report suspected misconduct, including matters relating to labour practices and human rights",0,0,0,0,0,0,0,1,0,0,0 373,79,It is managed by a third party which helps to maintain anonymity of whistleblowers as well as protecting data privacy,0,0,0,0,0,0,0,1,0,0,0 373,80,The system also enables communication between Toll and the whistleblower to ensure they are kept informed of the outcomes of subsequent investigations,0,0,0,0,0,0,0,1,0,0,0 373,81,Information on how to access the hotline is readily accessible in 20 languages to ensure all parties have equal access,0,0,0,0,0,0,0,1,0,0,0 373,82,All allegations received are reviewed and appropriately investigated,0,0,0,0,0,0,0,0,1,0,0 373,83,Toll takes a timely and proportionate approach to implementing corrective or disciplinary actions and learnings,0,0,0,0,0,0,0,0,1,0,0 373,84,This includes working with managers and other relevant employees to implement necessary changes to prevent any further breaches occurring in the future,0,0,0,0,0,0,0,0,1,0,0 373,85,Training Our ability to identify and respond to human rights issues is heavily reliant on our employees identifying and reporting potential breaches,0,0,0,0,0,0,0,0,0,0,0 3584,81,Munich Res Statement on the Australian Modern Slavery Act Page 4/6 GLISE operates an agency model for accessing insurance business but recognises delegated authority can present greater risk due to the operational separation of such arrangements,0,0,0,0,1,0,1,0,0,0,0 3584,82,GLISE includes contractual obligations on agents to not commit any criminal activity,0,0,0,0,0,0,0,1,0,0,0 3584,83,It also expressly instructs agents to exercise care and skill in sub-delegating or performing their duties,0,0,0,0,0,0,0,1,0,0,0 3584,84,"The need for personnel to have profes- sional qualification and experience is part of this duty, which is accepted to reduce the likeliness of working conditions that could constitute an offence",0,0,0,0,0,0,0,1,0,0,0 3584,85,Our Agency function conducts due diligence when onboarding (re)insurance business and any concerns around modern slavery or human trafficking are escalated,0,0,0,0,0,0,0,1,0,0,0 3584,86,Our dedicated Agency Audit function also includes the topic of Modern Slavery to the scope of audits,0,0,0,0,0,0,0,0,0,1,0 3584,87,"Because Munich Res business model as an insurer has a long-term focus, sustaina- bility criteria play a key, strategic role in investment",0,0,0,0,0,0,0,0,0,0,0 3584,88,We are obligated to invest our clients money sensibly and profitably in a manner that adheres to strict security and return requirements,0,0,0,0,0,0,0,1,0,0,0 5284,97,Team Member Purchases Policy,0,0,0,0,0,0,0,0,0,0,0 5284,98,Workplace Health and Safety Policy,0,0,0,0,0,0,0,0,0,0,0 5284,99,POL MODERN SLAVERY STATEMENT Process Owner: Human Resources Authorised: Head of HR Ref,0,0,0,0,0,0,0,0,0,0,0 5284,100,Number: 2.1 Page: 5 Date: 20 June 2021,0,0,0,0,0,0,0,0,0,0,0 5284,101,Existing governance in our international regions includes independent grievance mechanisms and risk monitoring in our China operations,0,0,0,0,0,0,0,1,0,0,0 5284,102,Our work going forward is to gain further understanding of their effectiveness and explore how they are responding to the nature of risks specific to their region,0,0,0,0,0,0,0,0,0,0,0 5284,103,Our internal policies and checklists are continuously reviewed for improvement to tighten our due diligence around preventing the above forms of modern slavery,0,0,0,0,0,0,0,0,0,1,0 5284,104,Suppliers found to not be compliant with our internal checklist and policies are prevented from engaging with Ally Fashion until these issues are confirmed as remedied,0,0,0,0,0,0,0,0,1,0,0 10492,0,"P 1300 119 919 E info intellihub.com.au www.intellihub.com.au Unit D1, 15 21 Doody Street, Alexandria, NSW 2015, Australia 1",0,0,0,1,0,0,0,0,0,0,0 10492,1,INTELLIHUB GROUP MODERN SLAVERY STATEMENT DocuSign Envelope ID: 6B496E5F-D8EC-41BA-A7E5-7DDC90A692EF,0,0,0,0,0,0,0,0,0,0,0 10492,2,"P 1300 119 919 E info intellihub.com.au www.intellihub.com.au Unit D1, 15 21 Doody Street, Alexandria, NSW 2015, Australia 2",0,0,0,0,0,0,0,0,0,0,0 10492,3,"au www.intellihub.com.au Unit D1, 15 21 Doody Street, Alexandria, NSW 2015, Australia P 1300 119 919 E info intellihub.com",0,0,0,0,0,0,0,0,0,0,0 10492,4,THIS STATEMENT ADDRESSES THE PERIOD FROM 1 JULY 2021 TO 30 JUNE 2022,0,0,0,0,0,0,0,0,0,0,0 10492,5,INTRODUCTION 2 THE INTELLIHUB BUSINESS 3 ASSESSING OUR RISK 4 OUR ACTIONS 6 APPROVAL AND SIGNATURE,0,0,0,0,0,0,0,0,0,0,0 10492,6,DocuSign Envelope ID: 6B496E5F-D8EC-41BA-A7E5-7DDC90A692EF,0,0,0,0,0,0,0,0,0,0,0 10492,7,"P 1300 119 919 E info intellihub.com.au www.intellihub.com.au Unit D1, 15 21 Doody Street, Alexandria, NSW 2015, Australia",0,0,0,0,0,0,0,0,0,0,0 373,86,"As such, it is vital that employees have a good understanding of what human rights and modern slavery issues are; how to report them and how to address them",0,0,0,0,0,0,0,0,0,0,0 373,87,Toll continues to raise awareness of modern slavery with training and e-Learning on the Code of Conduct together with ongoing consultation on modern slavery in higher-risk areas within the business (Procurement department),0,0,0,0,0,0,0,1,0,0,0 373,88,"In FY20, customised training was provided to the Group Procurement team to give an overview of Modern Slavery, identify the relevant risks to Toll and outline their role in addressing these risks",0,0,0,0,0,0,0,1,0,0,0 373,89,"Our induction e-Learning modules for all employees have also been updated to contain sections on Modern Slavery and Human Rights, with reference to our Anti-Modern Slavery Policy",0,0,0,0,0,0,0,1,0,0,0 373,90,In FY21 we will continue to build on this with the roll out of a dedicated e-Learning module on Modern Slavery,0,0,0,0,0,0,0,1,0,0,0 373,91,"COVID-19 Response Strict safety protocols were implemented throughout Tolls operations including the provision of appropriate protective gear, social distancing, regular disinfection of workspaces and contactless deliveries to protect the health of our employees",0,0,0,0,0,0,0,0,0,0,0 373,92,"We have also worked closely with our suppliers, contractors and clients to ensure their employees are also implementing similar processes",0,0,0,0,0,0,0,0,0,0,0 373,93,To prevent the risk of employees and contractors being forced to work long hours we have reinforced our strict policies regarding working hours which have been closely monitored to ensure working conditions are safe,0,0,0,0,0,0,0,0,0,0,0 3584,89,Therefore we have committed to observing the Principles for Responsible Investment (PRI) and consider it essential to integrate ESG aspects in our investment processes,0,0,0,0,0,0,0,1,0,0,0 3584,90,"For the majority of Munich Res investments, our target is to be sustainable in accordance with our Group-wide Responsible Investment Guideline (RIG), and we track our progress in this regard in an internal sustainability index",0,0,0,0,0,0,0,0,0,1,0 3584,91,Over 80% of our relevant investments were invested sustainably in 2020,0,0,0,0,0,0,0,0,0,1,0 3584,92,We systematically incorporate individually defined ESG criteria into the selection pro- cess for the different asset classes,0,0,0,0,0,0,0,1,0,0,0 3584,93,"For investments in equities and bonds we use sustainability indices, ratings and specific ESG research by MSCI, which also includes human rights issues",0,0,0,0,0,0,0,1,0,0,0 3584,94,"In the asset classes of infrastructure, renewable ener- gies, forestry and farmland, ESG aspects including human rights issues are reviewed in the due diligence process for investments",0,0,0,0,0,0,0,1,0,0,0 3584,95,We regularly review our sustainability criteria for all assets,0,0,0,0,0,0,0,0,0,1,0 3584,96,b) General measures Monitoring systems help us examine the effectiveness of our measures,0,0,0,0,0,0,0,0,0,0,0 5284,105,"Industries which make use of short-term contract, migrant labour and labour hire agencies such as cleaning, third party warehousing, freight and logistics pose greater risks and as such will be a focus of our efforts",0,0,0,0,0,0,1,0,0,0,0 5284,106,"Over the course of the next reporting period, Ally Fashion will engage in internal and third-party audits to verify the continuous compliance of suppliers and contractors with our internal policies and Code of Conduct",0,0,0,0,0,0,0,0,0,1,0 5284,107,"Whilst audits in some regions will be hampered by the current pandemic, audit assessments will attempt to be conducted virtually, such that business operations can continue with minimal risks",0,0,0,0,0,0,0,0,0,1,0 5284,108,"Our Code of Conduct for Team Members, Suppliers, and Contractors addresses forced labour risks including child labour and debt bondage",0,0,0,0,0,0,0,1,0,0,0 5284,109,"The Code of Conduct, coupled with our Ethical Sourcing Policy, governs the minimum requirements of our trading relationships",0,0,0,0,0,0,0,1,0,0,0 5284,110,"To assist with compliance and understanding, our Supplier Code of Conduct will also be translated into Mandarin for our China-based factories",0,0,0,0,0,0,0,1,0,0,0 5284,111,We recognise that modern slavery risks exist beyond level-one into further levels of the supply chain,0,0,0,0,0,0,0,0,0,0,0 5284,112,"We have visibility of a portion of our level-one fabric mills and, whilst mapping of this level continues, further due diligence of our most strategic suppliers will allow us to identify whether these facilities have undergone social assessments and audits",0,0,0,0,0,0,0,0,0,1,0 10492,8,INTRODUCTION Modern slavery is one of the most complex and important human rights challenges of our time,0,0,0,0,0,0,0,0,0,0,0 10492,9,"According to the International Labour Organisation, the term modern slavery covers a set of legal concepts, including forced labour, debt bondage, slavery of children and human trafficking",0,0,0,0,0,0,0,0,0,0,0 10492,10,"Modern slavery is an umbrella term to refer to situations of exploitation that an individual cannot refuse or leave because of threats, violence, coercion, deception, or abuse of power",0,0,0,0,0,0,0,0,0,0,0 10492,11,"At Intellihub, we do not tolerate modern slavery and are fully committed to preventing slavery and human trafficking in our operations and supply chain",0,0,0,0,0,0,0,0,0,0,0 10492,12,This statement sets out the actions that the Intellihub Group has taken to understand and address potential modern slavery risks related to our business,0,0,0,0,0,0,0,0,0,0,0 10492,13,DocuSign Envelope ID: 6B496E5F-D8EC-41BA-A7E5-7DDC90A692EF,0,0,0,0,0,0,0,0,0,0,0 10492,14,"P 1300 119 919 E info intellihub.com.au www.intellihub.com.au Unit D1, 15 21 Doody Street, Alexandria, NSW 2015, Australia",0,0,0,0,0,0,0,0,0,0,0 10492,15,"STRUCTURE Intellihub Group is made up of privately held Australian and New Zealand companies, employing over 300 people across offices in Sydney, Melbourne, Auckland, Hobart, and Brisbane",0,0,0,1,1,0,0,0,0,0,0 373,94,Assessment & Effectiveness of our Actions Toll recognises the importance of monitoring how effective our anti-modern slavery processes are and we have actively taken steps to review our approach to assessing and addressing modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 373,95,In our own operations we utilise our global network of dedicated employees to oversee the effectiveness of the relevant actions taken to address modern slavery,0,0,0,0,0,0,0,0,0,1,0 373,96,"This includes representatives from Security and Compliance, HSE, HR and Procurement who have been trained to identify and act upon risks in our day to day operations",0,0,0,0,0,0,0,0,0,1,0 373,97,We intend to build upon this in FY21 with the establishment of a modern slavery working group who will meet regularly to discuss actions taken and their effectiveness,0,0,0,0,0,0,0,0,0,1,0 373,98,"For our supply chain partners, we are currently working to better assess the effectiveness of our actions to address modern slavery",0,0,0,0,0,0,0,0,0,1,0 373,99,We are establishing levers for audits through clauses in contracts and engaging with high risk agents identified via our compliance due diligence process,0,0,0,0,0,0,0,0,0,1,0 373,100,Modern Slavery Statement FY20 v01,0,0,0,0,0,0,0,0,0,0,0 373,101,"Page 5 of 5 Our Future Tolls Anti-Modern Slavery Program, and this statement, are a result of consultation and collaboration between many areas within Toll",0,0,0,0,0,0,0,0,0,0,0 3584,97,We strive to continually improve our processes of due diligence and expand our screening of risks,0,0,0,0,0,0,0,0,0,0,0 3584,98,"For the monitoring in (re-)insurance business and investment, we use renowned external ESG databases to subject sensitive projects to a comprehensive review (also particularly with regard to human rights criteria)",0,0,0,0,0,0,0,0,0,1,0 3584,99,"The active tender pro- cess of GLISE is periodically reviewed at contract renewal, where a suppliers ethics and risk of modern slavery and human trafficking offences are part of GLISEs overall consideration to conduct business",0,0,0,0,0,0,0,0,0,1,0 3584,100,The review of the Corporate Responsibility clause in Munich Res procurement contracts and the contractually guaranteed possibility of termination in the event of violations is carried out by our Compliance Depart- ment,0,0,0,0,0,0,0,0,1,1,0 3584,101,"If a violation of human rights is reported, or we learn of it by any other means, the Munich Re compliance units responsible will look into the violation",0,0,0,0,0,0,0,0,1,0,0 3584,102,"An investigation is launched, which follows a procedure defined in an internal set of guidelines",0,0,0,0,0,0,0,0,1,0,0 3584,103,Every potential instance of misconduct will be investigated and responded to,0,0,0,0,0,0,0,0,1,0,0 3584,104,"If we learn of human rights violations in an existing contractual relationship, we will engage in dia- logue with the responsible stakeholders and seek to put risk-mitigating measures into practice",0,0,0,0,0,0,0,0,1,0,0 5284,113,Our sourcing strategy will continue to explore further due diligence measures to mitigate risks in this area of our supply chain,0,0,0,0,0,0,0,0,0,1,0 5284,114,"As this is our first Modern Slavery Statement, we have not yet had the opportunity to assess the effectiveness of the above executed actions",0,0,0,0,0,0,0,0,0,1,0 5284,115,We have established a process to review the completion and outcomes of assigned actions throughout the year and to review the overall effectiveness each year,0,0,0,0,0,0,0,0,0,1,0 5284,116,"Future Priorities Looking ahead, our focus will be on our governance structures to strengthen existing systems and processes, whilst investing further effort towards capacity-building both internally and with our suppliers",0,0,0,0,0,0,0,0,0,0,0 5284,117,We at Ally Fashion strongly support fundamental human rights and the prevention of modern slavery and human trafficking,0,0,0,0,0,0,0,0,0,0,0 5284,118,One of the key learnings from us during this assessment and preparation of this Statement is the relatively low level of actual transparency,0,0,0,0,0,0,0,0,0,0,0 5284,119,POL MODERN SLAVERY STATEMENT Process Owner: Human Resources Authorised: Head of HR Ref,0,0,0,0,0,0,0,0,0,0,0 5284,120,Number: 2.1 Page: 6 Date: 20 June 2021,0,0,0,0,0,0,0,0,0,0,0 10492,16,OPERATIONS The Intellihub Group is a utility services company that delivers innovative metering and data solutions to maximise digital and new energy services,0,0,0,0,1,0,0,0,0,0,0 10492,17,"We are an experienced and leading provider of multi- utility services for residential, commercial & industrial, embedded network and solar metering customers",0,0,0,0,1,0,0,0,0,0,0 10492,18,"CONSULTATATION As part of preparing this statement, we consulted with Executive Leaders and directors for the reporting entities within the Intellihub Group who have reviewed and approved the content",0,0,0,0,0,0,0,0,0,0,1 10492,19,Our consultation included review by the Executive Leaders of our subsidiary companies both within Australia and in New Zealand,0,0,0,0,0,0,0,0,0,0,1 10492,20,"All our subsidiaries are required to follow the same policies and processes despite not being reporting entities or, in the case of our New Zealand subsidiary, not directly being subject to the Australian Modern Slavery legislation",0,0,0,0,0,0,0,0,0,0,1 10492,21,"In addition, this statement has been approved on 20/10/2022 by the Board of Directors of Spark Investment Holdco Pty Ltd as the parent entity for the Intellihub Group and its reporting entities",1,0,0,0,0,0,0,0,0,0,0 10492,22,"GOVERNANCE We are committed to embedding human rights considerations into decision-making, our policies and governance framework",0,0,0,0,0,0,0,0,0,0,0 10492,23,"Members of executive leadership and our Board formally review and approve Intellihub policies, including those listed above",0,0,0,0,0,0,0,0,0,0,0 373,102,"These include Procurement, Legal, Human Resources, Health and Safety and Compliance and Security",0,0,0,0,0,0,0,0,0,0,0 373,103,"This is testament to our shared values, policies and governance frameworks together with a belief in the importance of actions to address Modern Slavery risks",0,0,0,0,0,0,0,0,0,0,0 373,104,"Toll recognises the need to continuously build on our understanding, oversight and management of modern slavery risks in our operations and supply chains",0,0,0,0,0,0,0,0,0,0,0 373,105,"We continue to build on our work from this financial year, progress the enhancements of our mitigation actions and engagement within our operations and supply chain",0,0,0,0,0,0,0,0,0,0,0 373,106,"This statement was approved by the principal governing body for Toll, Toll Holdings Ltd Board on 28 October 2020",1,0,0,0,0,0,0,0,0,0,0 373,107,Thomas Knudsen Managing Director Toll Group,0,1,0,0,0,0,0,0,0,0,0 462,0,MODERN SLAVERY STATEMENT 2020,0,0,0,0,0,0,0,0,0,0,0 462,1,"This statement outlines the actions taken by Computershare Limited (Computershare) and its related entities to identify and mitigate the risks of modern slavery in our businesses and supply chains, during the year ending 30 June 2020",0,0,0,0,0,0,0,0,0,0,0 3584,105,"Employees have the opportunity to report incidents directly to their line managers, the Compliance Officer or to Internal Audit",0,0,0,0,0,0,0,1,0,0,0 3584,106,"To additionally strengthen the compli- ance system, an independent external ombudsman has been appointed",0,0,0,0,0,0,0,1,0,0,0 3584,107,"Further- more, Munich Re and GLISE offers its staff members, clients, suppliers, and other business partners a whistleblowing portal publicly accessible on the Munich Re website to report potential or actual compliance breaches",0,0,0,0,0,0,0,1,0,0,0 3584,108,"Here, relevant information can be exchanged safely and confidentially globally and around the clock",0,0,0,0,0,0,0,1,0,0,0 3584,109,The compliance unit receives this information and is responsible for processing it further,0,0,0,0,0,0,0,1,0,0,0 3584,110,Everyone can provide information anonymously or under their own name,0,0,0,0,0,0,0,1,0,0,0 3584,111,Munich Res Statement on the Australian Modern Slavery Act Page 5/6 Training and capacity building on slavery and human trafficking All Munich Re staff worldwide are required to attend training on the Code of Conduct every two years so that they are familiar with the standards of ethical conduct in our daily work and are aware of the need to observe these rules day to day,0,0,0,0,0,0,0,1,0,1,0 3584,112,"This training includes, for example, reporting of infringements, data protection and corruption",0,0,0,0,0,0,0,0,0,0,0 5284,121,"that we have into the practices engaged in by our level-one suppliers, let alone our entire supply chain network",0,0,0,0,0,0,0,0,0,0,0 5284,122,"This has greatly enhanced our perspective, understanding, and necessity of increasing visibility into such an important aspect of our supply chain, and stimulated a desire to continue this journey and worthy goal to do our part to try to eradicate modern slavery in our supply chain, in the retail and apparel industry, and hopefully, the world",0,0,0,0,0,0,0,0,0,0,0 5284,123,Ally Fashion acknowledges that the actions taken are just the first steps in a journey towards ensuring there is no modern slavery in our supply chain,0,0,0,0,0,0,0,0,0,0,0 5284,124,We are committed to making continuous ongoing improvement in our assessment and management of risk in this area,0,0,0,0,0,0,0,0,0,0,0 5284,125,"Our main future priorities include, but are not limited to",0,0,0,0,0,0,0,0,0,0,0 5284,126,Execute and assess the effectiveness of the actions noted in this Statement,0,0,0,0,0,0,0,0,0,0,0 5284,127,Broaden our level of interaction with all of our suppliers and contractors at every level to eradicate any degree of exposure or involvement in modern slavery beyond reasonable doubt,0,0,0,0,0,0,0,1,0,1,0 5284,128,This includes conducting internal and supplier/contractor audits on a scheduled and randomized basis,0,0,0,0,0,0,0,1,0,1,0 10492,24,Our Executive Leaders and Board were also intimately involved in creating and endorsing our ESG Framework,0,0,0,0,0,0,0,1,0,0,0 10492,25,The ESG Framework provides the basis for ongoing efforts to meet our commitments to partner and work with our suppliers to combat modern slavery and human trafficking and improve working conditions,0,0,0,0,0,0,0,1,0,0,0 10492,26,"We reinforce, monitor, and assess our ESG Frame commitments by reflecting them as significant components of our Executive Leaders KPIs, which are cascaded down to individual KPIs through our organisation",0,0,0,0,0,0,0,0,0,1,0 10492,27,REPORTING ENTITIES,0,0,0,0,0,0,0,0,0,0,0 10492,28,This Modern Slavery Statement is provided on behalf of the following reporting entities within the Intellihub Group,0,0,1,0,0,0,0,0,0,0,0 10492,29,Spark Investment Holdco Pty Ltd ACN 626 001 394,0,0,1,0,0,0,0,0,0,0,0 10492,30,Spark Investment Midco Pty Ltd ACN 626 002 248,0,0,1,0,0,0,0,0,0,0,0 10492,31,Intellihub Holdings Pty Ltd ACN 626 003 236,0,0,1,0,0,0,0,0,0,0,0 462,2,This statement has been prepared to comply with the requirements of the Australian Modern Slavery Act 2018 (Act),0,0,0,0,0,0,0,0,0,0,0 462,3,"It is a joint statement that applies to all Computershare reporting entities within the scope of the Act, as identified in the Appendix to this statement",0,0,0,0,0,0,0,0,0,0,0 462,4,"This is our first statement, which outlines our commitment to advancing human rights along with the steps we have taken to identify and reduce the risk of modern slavery in our business and supply chains",0,0,0,0,0,0,0,0,0,0,0 462,5,"Our business Computershare is a global market leader in transfer agency and share registration, employee equity plans, mortgage servicing, proxy solicitation and stakeholder communications",0,0,0,0,1,0,0,0,0,0,0 462,6,"We also specialise in corporate trust, bankruptcy, class action and a range of other diversified financial and governance services",0,0,0,0,1,0,0,0,0,0,0 462,7,"Founded in 1978, Computershare is renowned for its expertise in high integrity data management, high volume transaction processing and reconciliations, payments and stakeholder engagement",0,0,0,0,1,0,0,0,0,0,0 462,8,"Many of the worlds leading organisations use us to streamline and maximise the value of relationships with their investors, employees, creditors and customers",0,0,0,0,0,0,0,0,0,0,0 462,9,"Computershare is represented in all major financial markets and has over 12,000 employees worldwide in 21 countries",0,0,0,1,1,0,0,0,0,0,0 3584,113,"In the reinsurance sector, our corporate responsibility experts coordinate the imple- mentation of the Principles for Sustainable Insurance (PSI) and the integration of ESG aspects in our reinsurance business",0,0,0,0,0,0,0,1,0,0,0 3584,114,"With this in mind, these experts on corpo- rate responsibility provide relevant training for managers, underwriters and client managers in the different divisional units",0,0,0,0,0,0,0,1,0,0,0 3584,115,"In addition, a Corporate Responsibility in Business coordinators network was established in the reinsurance sector and the coordinators were made aware of the topic",0,0,0,0,0,0,0,1,0,0,0 3584,116,"More than 800 staff members have been sensitised to ESG aspects and, in their role as multipliers, are now transferring their knowledge within their own departments, in risk assessments, client discussions and in exchanges with other units",0,0,0,0,0,0,0,1,0,0,0 3584,117,Employees responsible for human rights issues within the Group regularly attend external seminars and webinars in order to deepen their knowledge,0,0,0,0,0,0,0,1,0,0,0 3584,118,Munich Re is also an active member of the Peer Learning Group of the German Global Compact Network,0,0,0,0,0,0,0,1,0,0,0 3584,119,Process of consultation MR AG maintains a series of measures to ensure consistency across the Munich Re Group,0,0,0,0,0,0,0,0,0,0,0 3584,120,All Munich Re Group investments are managed centrally by MEAG,0,0,0,0,0,0,0,0,0,0,0 5284,129,Establish and continuously improve our internal modern slavery working group,0,0,0,0,0,0,0,1,0,0,0 5284,130,Continue the development of our Supplier Selection Criteria Checklist in order to prioritise due diligence efforts and map against audit findings; and,0,0,0,0,0,0,0,1,0,1,0 5284,131,Provide Modern Slavery training and awareness to team members during the induction process,0,0,0,0,0,0,0,1,0,0,0 5284,132,Forms,0,0,0,0,0,0,0,0,0,0,0 5284,133,Not applicable,0,0,0,0,0,0,0,0,0,0,0 5284,134,Annexes,0,0,0,0,0,0,0,0,0,0,0 5284,135,Not applicable,0,0,0,0,0,0,0,0,0,0,0 5284,136,Requests for change,0,0,0,0,0,0,0,0,0,0,0 10492,32,Intellihub Australia Pty Ltd ACN 626 079 614 DocuSign Envelope ID: 6B496E5F-D8EC-41BA-A7E5-7DDC90A692EF,0,0,1,0,0,0,0,0,0,0,0 10492,33,"P 1300 119 919 E info intellihub.com.au www.intellihub.com.au Unit D1, 15 21 Doody Street, Alexandria, NSW 2015, Australia",0,0,0,0,0,0,0,0,0,0,0 10492,34,"OUR SUPPLY CHAIN Our supply chains include major global suppliers with manufacturing locations in Indonesia, China and Malaysia and we are committed to improving the working conditions of people who are connected to our business and recognise the need to monitor for conditions that put workers at risk of modern slavery",0,0,0,0,0,1,0,0,0,0,0 10492,35,"As part of providing our customers with utility services and data solutions, our supply chain includes suppliers spanning the following major spending categories",0,0,0,0,0,1,0,0,0,0,0 10492,36,"Smart metering and communications devices, and associated equipment which we primarily own and install, allowing us to provide managed services to our customers who are overwhelmingly electricity retail businesses",0,0,0,0,0,1,0,0,0,0,0 10492,37,"Smart metering device installation, and maintenance services, provided by qualified electrical field service technicians",0,0,0,0,0,1,0,0,0,0,0 10492,38,"Software, data, mobile connectivity, telecommunications, and other information technology services enabling our technology platform and allowing us to provide metering and other data services to our customers; and",0,0,0,0,0,1,0,0,0,0,0 10492,39,"General operations and corporate services, including freight/shipping, legal services, insurance, office information technology and support",0,0,0,0,0,1,0,0,0,0,0 462,10,"For internal reporting and risk management purpose, Computershares operating businesses are structured across the following areas",0,0,0,0,1,0,0,0,0,0,0 462,11,"Issuer Services: register maintenance, corporate actions, stakeholder relationship management, corporate governance and related services",0,0,0,0,1,0,0,0,0,0,0 462,12,"Mortgage Services and Property Rental Services: mortgage servicing and related activities, together with tenancy bond protection services in the UK",0,0,0,0,1,0,0,0,0,0,0 462,13,"Employee Share Plans and Voucher Services: provision of administration and related services for employee share and option plans, together with childcare voucher administration in the UK",0,0,0,0,1,0,0,0,0,0,0 462,14,"Business Services: services supporting for bankruptcy administration, class actions and corporate trust administration",0,0,0,0,1,0,0,0,0,0,0 462,15,"Communication Services and Utilities: document composition and printing, intelligent mailing, inbound process automation, scanning and electronic delivery, and utilities administration",0,0,0,0,1,0,0,0,0,0,0 462,16,Technology Services: provision of software specialising in share registry and financial services,0,0,0,0,1,0,0,0,0,0,0 462,17,"These operating businesses are supported by corporate and shared service functions, including finance, risk and compliance, human resources, internal audit and legal",0,0,0,0,1,0,0,0,0,0,0 3584,121,Our Corporate Underwriting department conducts regular audits to ensure that all applicable rules and guidelines in (re-)insurance business are adhered to in all entities worldwide,0,0,0,0,0,0,0,0,0,1,0 3584,122,The group-wide Human Resources and Procurement Policies of Munich Re constitute a binding set of rules for all entities worldwide,0,0,0,0,0,0,0,0,0,0,1 3584,123,"With the help of Group-wide reporting lines and control principles, compliance with these binding rules is ensured by all local units",0,0,0,0,0,0,0,0,0,0,1 3584,124,"MR AG has engaged with senior leaders from the subsidiary reporting entities, MHA, MRA and GLISE outlining the Munich Re Group approach for identifying and assessing modern slavery risks and these senior leaders have reviewed this statement prior to its publication",0,0,0,0,0,0,0,0,0,0,1 3584,125,Activities in the financial year 2020 We will continue to work on the implementation of human and labour rights aspects and to consider our obligations under the Australian Modern Slavery Act 2018,0,0,0,0,0,0,0,0,0,0,0 3584,126,"In 2020, we offered training courses on compliance topics and ESG integration in business, raising awareness of human rights issues and possible human rights violations",0,0,0,0,0,0,0,1,0,0,0 3584,127,"Due to the special situation resulting from the coronavirus pandemic, only a few training courses were completed in 2020, with most postponed to 2021",0,0,0,0,0,0,0,0,0,1,0 3584,128,"Additionally, we built the global core-model for digital supplier management and went live with this solution at our Munich headquarters in 2020",0,0,0,0,0,0,0,1,0,0,0 5284,137,Requests for changes or improvements to this procedure shall be forwarded to the Process Owner identified in the footer of this document,0,0,0,0,0,0,0,0,0,0,0 5284,138,"Changes to this procedure must be approved by the Head of People, Culture, and Development (Head of HR)",0,0,0,0,0,0,0,0,0,0,0 5284,139,Approval This document is approved by the Ally Fashion Board,1,0,0,0,0,0,0,0,0,0,0 5284,140,"Nitya Raghavan Head of People, Culture, and Development",0,1,0,0,0,0,0,0,0,0,0 6063,0,allenovery.com,0,0,0,0,0,0,0,0,0,0,0 6063,1,"Modern Slavery and Human Trafficking Statement 2020/21 19 October 2021 Purpose of this statement This statement is made on behalf of Allen & Overy LLP, its wholly owned subsidiary Allen & Overy Service Company Ltd, Allen & Overy an Australian partnership, and the entities that they own or control (including The Trustee for Allen & Overy (Australia) Discretionary Trust and its trustee Allen & Overy (Australia) Pty Ltd) (together, the Firm) pursuant to section 54(1) of the Modern Slavery Act 2015 (the UK Act) and section 14 of the Modern Slavery Act 2018 (Cth) (the Australian Act) (the Statement)",0,0,1,1,0,0,0,0,0,0,0 6063,2,The Statement describes the steps the Firm has taken in the financial year ending 30 April 2021,0,0,0,0,0,0,0,0,0,0,0 6063,3,"Introduction The Firm takes its obligations in relation to the identification, reporting and prevention of modern slavery and human trafficking very seriously",0,0,0,0,0,0,0,0,0,0,0 10492,40,"MODERN SLAVERY RISKS As a company that purchases a large volume of smart metering and communication devices, we consider that the main modern slavery risk in our supply chain comes from exposure to product manufacturing supply chains",0,0,0,0,0,0,1,0,0,0,0 10492,41,We source our smart meters and associated communications technology from reputable global suppliers,0,0,0,0,0,0,0,1,0,0,0 10492,42,"Some of these suppliers partly operate in geographies with an elevated modern slavery risk for manufacturing, including China, Indonesia, and Malaysia",0,0,0,0,0,0,1,0,0,0,0 10492,43,"While modern slavery can be found in all countries, suppliers with manufacturing operations in countries associated with a higher risk for modern slavery, for example, countries with large populations of migrant workers, weak labour law enforcement, countries where charging workers recruitment fees is common practice, or countries where modern slavery prevalence has been well documented",0,0,0,0,0,0,0,0,0,0,0 10492,44,"Even though the suppliers we purchase from are well- established reputable organisations, we are careful to manage our relationships and contracting practices in a manner which helps ensure workers are safe",0,0,0,0,0,0,0,0,0,0,0 10492,45,DocuSign Envelope ID: 6B496E5F-D8EC-41BA-A7E5-7DDC90A692EF,0,0,0,0,0,0,0,0,0,0,0 10492,46,"P 1300 119 919 E info intellihub.com.au www.intellihub.com.au Unit D1, 15 21 Doody Street, Alexandria, NSW 2015, Australia",0,0,0,0,0,0,0,0,0,0,0 10492,47,"OUR ACTIONS OUR MODERN SLAVERY POLICIES Our policies communicate the Intellihub Groups values and expectations, setting standards for ourselves and our partners while making clear that we do not tolerate modern slavery",0,0,0,0,0,0,0,0,0,0,0 462,18,"Our business is mainly office based, with some print and mail and warehouse facilities supporting our communication services business",0,0,0,0,1,0,0,0,0,0,0 462,19,Our commitment Computershare is committed to ensuring that modern slavery plays no part in the services we provide or in the supply chains we rely on to render those services,0,0,0,0,0,0,0,0,0,0,0 462,20,Our Global Human Rights Policy reflects our commitment to act ethically and with integrity in all our business dealings and relationships,0,0,0,0,0,0,0,1,0,0,0 462,21,We are committed to implementing and enforcing effective systems and controls across our business and supply chains in support of these commitments,0,0,0,0,0,0,0,0,0,0,0 462,22,We are also committed to ensuring there is transparency in our business and in our approach to tackling modern slavery throughout our supply chains,0,0,0,0,0,0,0,0,0,0,0 462,23,We expect the same high standards from all our suppliers and we expect that they hold their own suppliers to the same high standards,0,0,0,0,0,0,0,0,0,0,0 462,24,"Governance framework Our company values of Certainty, Ingenuity and Advantage, supported by our Being Purple ways of working, guide our staff in how they should act and conduct themselves",0,0,0,0,0,0,0,0,0,0,0 462,25,We have redeveloped our global learning modules to embed our Being Purple ways of working and promote the right behaviours from our staff,0,0,0,0,0,0,0,0,0,0,0 3584,129,"The core-model will be rolled out globally over the next few years, and will enable us to improve accessibility, acceptance and documentation of the UN Global Compact Princi- ples among our global supply base",0,0,0,0,0,0,0,1,0,0,0 3584,130,The human right to health was obviously a particular concern for Munich Re in 2020,0,0,0,0,0,0,0,0,0,0,0 3584,131,"In the wake of the COVID-19 pandemic, Munich Re developed a compre- hensive hygiene concept at an early stage to protect staff against infection with SARS-CoV-2 through a variety of work-safety measures",0,0,0,0,0,0,0,0,0,0,0 3584,132,"The plan included strict rules for behaviour in office buildings (including meeting rooms, restrooms, cafe- terias and canteens), mandatory wearing of mouth and nose protection, guidance for unavoidable business travel including quarantine rules, and many more meas- ures",0,0,0,0,0,0,0,0,0,0,0 3584,133,This hygiene concept was continuously adapted to the current pandemic,0,0,0,0,0,0,0,0,0,0,0 3584,134,Munich Res Statement on the Australian Modern Slavery Act Page 6/6 situation across all locations worldwide,0,0,0,0,0,0,0,0,0,0,0 3584,135,Several mouth-and-nose masks were distributed to each employee who entered an office building,0,0,0,0,0,0,0,0,0,0,0 3584,136,"From the beginning of the government-imposed lockdown measures, Munich Re made it possible for a large part of the workforce to work from home",0,0,0,0,0,0,0,0,0,0,0 6063,4,The Firm is committed to taking appropriate steps to ensure that modern slavery and human trafficking does not occur within any part of its own business or any of its supply chains,0,0,0,0,0,0,0,0,0,0,0 6063,5,The Firms Business and Human Rights practice is also working with clients to help them avoid involvement in modern slavery and human trafficking and also has a programme of charitable and pro bono work that supports many human rights charities and non-government organisations,0,0,0,0,0,0,0,0,0,0,0 6063,6,Overview of business activities The Firm is one of the worlds leading international legal practices providing legal expertise and legal services across a number of sectors within a culture built on a philosophy of continual improvement to meet its clients changing needs,0,0,0,0,1,0,0,0,0,0,0 6063,7,"The Firms expanding network of more than 40 offices in 29 countries spans Europe, Asia Pacific, the Middle East, North America, Central and South America and Africa",0,0,0,0,1,0,0,0,0,0,0 6063,8,"The Firms full-service capabilities are delivered by approximately 5,500 people, including some 550 partners worldwide who work in a highly integrated manner across the Firms office network",0,0,0,1,0,0,0,0,0,0,0 6063,9,"The Firms supply chain As a law firm, the Firm has a relatively simple supply chain model that is built around supporting its core legal practice and maintaining its global office and technology infrastructure",0,0,0,0,0,1,0,0,0,0,0 6063,10,The types of goods and services necessary to do so fall into five broad categories,0,0,0,0,0,0,0,0,0,0,0 6063,11,"business services the diverse range of products and services the Firm buys to ensure it can maintain normal day-to-day operations in its offices and support its core legal practice, such as catering, security, library services, and print and document services; ii) professional services the professional services the Firm buys such as external training, audit",0,0,0,0,0,1,0,0,0,0,0 10492,48,These policies demonstrate our strong stance against modern slavery and include our,0,0,0,0,0,0,0,1,0,0,0 10492,49,Environmental Social Governance (ESG) Framework,0,0,0,0,0,0,0,1,0,0,0 10492,50,Modern Slavery Policy,0,0,0,0,0,0,0,1,0,0,0 10492,51,Code of Conduct; and,0,0,0,0,0,0,0,1,0,0,0 10492,52,Whistle-Blower Policy,0,0,0,0,0,0,0,1,0,0,0 10492,53,"Within the last reporting period, we launched our new ESG Framework",0,0,0,0,0,0,0,1,0,0,0 10492,54,"This framework sets out our goals and commitments in relation to combatting modern slavery and gives us a pathway forward to follow which supports and requires responsible sourcing, a safer workplace, helps drive zero emissions and enables each of us and everyone involved in our operations and supply chain to thrive",0,0,0,0,0,0,0,0,0,0,0 10492,55,"In particular, our ESG Framework directly addresses modern slavery under the Responsible Sourcing Pillar",0,0,0,0,0,0,0,0,0,0,0 462,26,"We have in place several policies to help guide our employees, including: Code of Conduct Global Human Rights Policy Diversity and Inclusion Policy Whistleblower Policy Anti-Bribery and Corruption Policy Anti-Money Laundering and Terrorist Financing Policy",0,0,0,0,0,0,0,1,0,0,0 462,27,"In addition, our global compliance training program covers obligations under our group policies on issues such as health, safety, wellbeing and environment, discrimination and bullying, accessibility, diversity and inclusion, human rights, anti-bribery and anti-corruption measures, and privacy",0,0,0,0,0,0,0,1,0,0,0 462,28,"We monitor, report and manage mandatory training completion rates, as part of our training governance framework",0,0,0,0,0,0,0,0,0,1,0 462,29,Employees who fail to complete mandatory compliance training without a valid reason may face disciplinary action,0,0,0,0,0,0,0,0,0,1,0 462,30,Computershare has adopted a risk-based approach to assessing and managing modern slavery risk,0,0,0,0,0,0,0,0,0,0,0 462,31,"We established a working group to review our business and supply chain activities, and to coordinate the implementation of changes needed to comply with Modern Slavery legislation in Australia and in other jurisdictions in which Computershare operates",0,0,0,0,0,0,0,1,0,0,0 462,32,"This working group includes representatives from Procurement, Risk and Compliance, Legal, and business line management",0,0,0,0,0,0,0,1,0,0,0 462,33,"The group is responsible for implementing appropriate practices to manage and mitigate potential modern slavery risks across our businesses, operations and wider supply chains",0,0,0,0,0,0,0,1,0,0,0 3584,137,Only around 10% of employees worked in the office during the lockdown periods,0,0,0,0,0,0,0,0,0,0,0 3584,138,"Increased flexibility in working hours has enabled parents to balance childcare, home schooling and work while following all social distancing rules",0,0,0,0,0,0,0,0,0,0,0 3584,139,This Statement has been approved by the Board of Management of MR AG on 20 May 2021,1,0,0,0,0,0,0,0,0,0,0 3584,140,"Dr Joachim Wenning Chairman of the Board of Management Munich Re 2021 Mnchener Rckversicherungs-Gesellschaft Kniginstrasse 107, 80802 Mnchen, Germany Mnchener Rckversicherungs-Gesellschaft (Munich Reinsurance Company) is a reinsurance company organised under the laws of Germany",0,1,0,0,0,0,0,0,0,0,0 3584,141,"In some countries, including in the United States, Munich Reinsurance Company holds the status of an unauthorised reinsurer",0,0,0,0,0,0,0,0,0,0,0 3584,142,Policies are underwritten by Munich Reinsurance Company or its affiliated insurance and reinsurance subsidiaries,0,0,0,0,0,0,0,0,0,0,0 3584,143,Certain coverages are not available in all juris dictions,0,0,0,0,0,0,0,0,0,0,0 3584,144,Any description in this document is for general information purposes only and does not consti- tute an offer to sell or a solicitation of an offer to buy any product,0,0,0,0,0,0,0,0,0,0,0 6063,12,allenovery.com,0,0,0,0,0,0,0,0,0,0,0 6063,13,"services and advisory services in areas such as tax, regulation and insurance; iii) real estate the office space the Firm buys or leases to accommodate its people and operate its business; iv) technology the systems, software and equipment that are necessary to maintain its global technology infrastructure that supports the Firms legal practice; and",0,0,0,0,0,1,0,0,0,0,0 6063,14,"travel as an international law firm, global mobility is essential and the Firm works with a large number of travel providers such as hotels and airlines",0,0,0,0,0,1,0,0,0,0,0 6063,15,The Firm considers that the provision of these services and facilities general present a low risk of modern slavery and human trafficking,0,0,0,0,0,0,1,0,0,0,0 6063,16,"However, the Firm has a central procurement function that manages the procurement of high value and/or goods and services that are considered to present a medium or high risk in accordance with the Firms procurement policy and formal tendering procedures",0,0,0,0,0,0,1,0,0,0,0 6063,17,"More information about how the Firm procures goods and services, and screens new suppliers is contained in the section below titled Risk assessment of the Firms supply chain and due diligence procedures and actions taken to address those risks",0,0,0,0,0,0,0,0,0,0,0 6063,18,Relevant policies The Firm has a number of existing policies and procedures which are relevant for mitigating the risk of slavery or human trafficking occurring in the Firms business or any of its supply chains,0,0,0,0,0,0,0,0,0,0,0 6063,19,"In particular, the following Firm policies are directly relevant to the issues discussed in this Statement: Procurement policy this policy includes specific procedures relating to how slavery and human trafficking risks are identified and assessed through the Firms procurement processes",0,0,0,0,0,0,0,1,0,0,0 10492,56,"Our ambition is to ensure we are partnering for social impact across our value chain, with specific targets and actions, including",0,0,0,0,0,0,0,0,0,0,0 10492,57,To work with our suppliers to educate and raise awareness of our commitment to combat modern slavery and human trafficking; and,0,0,0,0,0,0,0,1,0,0,0 10492,58,All tier 1 suppliers confirm their commitment to improving working conditions in combating modern slavery as a pre-condition by 2025,0,0,0,0,0,0,0,1,0,0,0 10492,59,"During the reporting period, we also finalised our refreshed Code of Conduct, which, amongst other things specifically addresses Modern Slavery",0,0,0,0,0,0,0,1,0,0,0 10492,60,This Code of Conduct is publicly available on our website and to our employees via our intranet,0,0,0,0,0,0,0,1,0,0,0 10492,61,We also began the process of reviewing and updating our Procurement Policy,0,0,0,0,0,0,0,1,0,1,0 10492,62,"Although this policy was not finalised within the reporting period, this work will continue and we expect our updated policy to be finalised during FY23",0,0,0,0,0,0,0,1,0,0,0 10492,63,OUR CONTRACTING PRACTICES,0,0,0,0,0,0,0,0,0,0,0 462,34,"Our position As a provider of services in financial markets, Computershare has assessed the risk of modern slavery within our direct business operations as low",0,0,0,0,1,0,1,0,0,0,0 462,35,"However, we recognise that we can be indirectly exposed to these risks, for example through our supply chain",0,0,0,0,0,0,1,0,0,0,0 462,36,Further detail on Computershares approach to addressing modern slavery risk in its supply chain is provided below,0,0,0,0,0,0,0,0,0,0,0 462,37,"In our assessment of Computershares risks in relation to Modern slavery, we have identified the following procurement categories that may have a higher risk of Modern slavery: Facilities service providers (eg cleaning and premises maintenance) Information technology infrastructure and hardware Paper suppliers (eg to our global print and mail business) Outsourcing suppliers (with focus on outsourced resource suppliers operating from a lower-cost location, eg India)",0,0,0,0,0,0,1,0,0,0,0 462,38,"In addition, we have also analysed country risk associated with our main business locations (and those of key suppliers), and we currently consider, based on information sourced via the Global Slavery Index, that the higher-risk locations to be: South Africa China India The Philippines Having regard to these risk-based assessments, we have identified the suppliers who are within the higher risk procurement categories and have also identified key suppliers within the higher risk locations",0,0,0,0,0,0,1,1,0,0,0 462,39,"We have also implemented a program where we actively seek confirmation from these suppliers that they conform to a Human Rights Policy (as required by laws and regulations in their jurisdiction), or alternatively, Computershares Human Rights Policy",0,0,0,0,0,0,0,1,0,0,0 462,40,"So far, we have reviewed around 300 suppliers globally, of which approximately 100 operate in higher-risk locations and/or in a higher risk procurement category, as listed above",0,0,0,0,0,0,1,0,0,1,0 462,41,Over two-thirds of our supply chain have now been reviewed; all of these suppliers either have an appropriate public stated position on Human Rights and Modern Slavery or have confirmed they have a Human Rights and Modern Slavery Policy in place,0,0,0,0,0,0,0,0,0,1,0 3708,0,______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 1,0,0,0,0,0,0,0,0,0,0,0 3708,1,ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT,0,0,0,0,0,0,0,0,0,0,0 3708,2,/17/2021,0,0,0,0,0,0,0,0,0,0,0 3708,3,______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 2,0,0,0,0,0,0,0,0,0,0,0 3708,4,Table of Contents Introduction and who we are,0,0,0,0,0,0,0,0,0,0,0 3708,5,Approval and Signing,0,0,0,0,0,0,0,0,0,0,0 3708,6,"Our Structure, Operations and Supply Chains",0,0,0,0,0,0,0,0,0,0,0 3708,7,Where we operate,0,0,0,0,0,0,0,0,0,0,0 6063,20,"Supplier code of conduct the code of conduct sets out the standards the Firm expects its suppliers to observe, including provisions that specifically prevent the use of compulsory and involuntary labour",0,0,0,0,0,0,0,1,0,0,0 6063,21,The code of conduct also provides the Firms suppliers and their workers with a mechanism to report suspected breaches of the code or other abuses to the Firm for investigation,0,0,0,0,0,0,0,1,0,0,0 6063,22,Third party suppliers background checks policy this policy sets out the screening and background checks that suppliers to the Firm must adhere to in relation to their employees (including identity verification and right to work verification),0,0,0,0,0,0,0,1,0,0,0 6063,23,Authority limits and contract signing policy this policy sets out the Firms internal control and governance procedures with regard to approving financial transactions and signing contracts with suppliers,0,0,0,0,0,0,0,1,0,0,0 6063,24,The policy ensures that contracts cannot be entered into without an appropriate level of review and authorisation by a suitably senior and qualified member of staff,0,0,0,0,0,0,0,1,0,0,0 6063,25,Health and safety policy this policy sets out the Firms commitment and approach to ensuring it provides a healthy working environment for its own staff and contractors that work onsite,0,0,0,0,0,0,0,0,0,0,0 6063,26,"Dignity at work policy this policy sets out the Firms approach to preventing the occurrence of discrimination, harassment, bullying or victimisation in the work place",0,0,0,0,0,0,0,0,0,0,0 6063,27,The Firm also provides its employees with access to an employee assistance programme (provided by an independent third party company) that can be used by its employees for free and confidential advice in relation to workplace concerns or issues,0,0,0,0,0,0,0,1,0,0,0 10492,64,"As part of our ongoing efforts to address the risks of modern slavery in our supply chain, we are committed to ensuring that appropriate contractual protections and obligations are included in new supply and procurement agreements",0,0,0,0,0,0,0,0,0,0,0 10492,65,This includes ensuring our supply and procurement agreements incorporate drafting requiring our suppliers comply with all relevant modern slavery laws and provide assurances around their practices and our expectations,0,0,0,0,0,0,0,1,0,0,0 10492,66,DocuSign Envelope ID: 6B496E5F-D8EC-41BA-A7E5-7DDC90A692EF,0,0,0,0,0,0,0,0,0,0,0 10492,67,"P 1300 119 919 E info intellihub.com.au www.intellihub.com.au Unit D1, 15 21 Doody Street, Alexandria, NSW 2015, Australia",0,0,0,0,0,0,0,0,0,0,0 10492,68,OUR ACTIONS OUR CONTRACTING PRACTICES (CONTINUED),0,0,0,0,0,0,0,0,0,0,0 10492,69,"During the reporting period, we entered into a new strategic partnership agreement with one of our largest suppliers",0,0,0,0,0,0,0,1,0,0,0 10492,70,"As part of negotiations, we prioritised robust provisions and protections ensuring accountability and compliance around modern slavery, including",0,0,0,0,0,0,0,1,0,0,0 10492,71,"taking reasonable steps to identify, assess and address risks of modern slavery practices in the operations and supply chains used (including any third party); and",0,0,0,0,0,0,0,1,0,0,0 462,42,We also conduct regular searches of global news sources to ensure we are aware of any reports of human rights violations committed by our suppliers,0,0,0,0,0,0,0,0,0,1,0 462,43,"In the past year, we have also broadened and deepened our efforts to understand and manage modern slavery risk in our organisation",0,0,0,0,0,0,0,0,0,0,0 462,44,We have updated our regulatory learning modules include definitions of Human Rights risks and our legal and regulatory obligations to protect the rights and wellbeing of all Computershare staff worldwide,0,0,0,0,0,0,0,1,0,0,0 462,45,"In addition, we have embedded our Being Purple ways of working into all regulatory learning modules",0,0,0,0,0,0,0,0,0,0,0 462,46,These ways of working make it clear to all employees how we expect them to carry out their role and give clear guidance on acceptable behaviour and working practices,0,0,0,0,0,0,0,0,0,0,0 462,47,We have also piloted discussions on modern slavery risk in management meetings to broaden awareness within the business,0,0,0,0,0,0,0,1,0,0,0 462,48,"Future commitments Over the next year, our focus will be on continuing to develop the maturity of our supplier due diligence program within our risk management framework",0,0,0,0,0,0,0,1,0,0,0 462,49,This will include the development of an additional due diligence process for new suppliers to undertake an assessment of their human rights and modern slavery compliance at the time of on-boarding,0,0,0,0,0,0,0,1,0,0,0 3708,8,Where we source,0,0,0,0,0,0,0,0,0,0,0 3708,9,Modern Slavery Risks in our Operations and Supply Chains,0,0,0,0,0,0,0,0,0,0,0 3708,10,How we identified modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 3708,11,Modern slavery risks identified,0,0,0,0,0,0,0,0,0,0,0 3708,12,Assessing and Addressing Potential and Actual Modern Slavery Risks,0,0,0,0,0,0,0,0,0,0,0 3708,13,Supplier Due Diligence Screening process,0,0,0,0,0,0,0,0,0,0,0 3708,14,Supplier Contracting,0,0,0,0,0,0,0,0,0,0,0 3708,15,"Governance Programs, Policies and Codes",0,0,0,0,0,0,0,0,0,0,0 6063,28,Policies that are directly relevant to our supply chain (such as our supplier code of conduct and third party background checks policy) are shared with our suppliers through a policy portal website that can be accessed at any time by our suppliers,0,0,0,0,0,0,0,1,0,0,0 6063,29,"Risk assessment of the Firms supply chain and due diligence procedures and actions taken to address those risks As a regulated international legal practice, the risk of modern slavery and human trafficking existing within the Firms own business is considered to be low",0,0,0,0,0,0,1,0,0,0,0 6063,30,allenovery.com 3,0,0,0,0,0,0,0,0,0,0,0 6063,31,The Firm recognises that the greatest risk of modern slavery and human trafficking is in its supply chains,0,0,0,0,0,0,1,0,0,0,0 6063,32,"As a result, the Firms procurement policy requires that all new suppliers are subject to an appropriate level of risk assessment and screening",0,0,0,0,0,0,0,1,0,0,0 6063,33,"The scope of the risk assessment and screening the Firm performs depends on the nature of the goods or services being procured, but can include: financial checks; data security assessments; reference checks; obtaining copies of relevant documents; corporate responsibility checks; site inspections/audits; and/or modern slavery risk assessments",0,0,0,0,0,0,0,1,0,0,0 6063,34,"To determine whether a modern slavery risk assessment is required, the Firm employs an analytical method that takes into account various risk factors (including country, sector and impact risk) to give an overall indication of potential risk with a given supplier",0,0,0,0,0,0,0,1,0,0,0 6063,35,Prospective suppliers are then allocated a risk score which determines the extent of further due diligence required,0,0,0,0,0,0,0,1,0,0,0 10492,72,"assurances that no form of forced, compulsory or slave labour is used",0,0,0,0,0,0,0,1,0,0,0 10492,73,"In addition to the above controls, where we identify non-compliance with modern slavery obligations by our suppliers, we have internal documents and guidelines setting out further investigation assessment questions for vendors and remediation guidance",0,0,0,0,0,0,0,0,1,0,0 10492,74,DocuSign Envelope ID: 6B496E5F-D8EC-41BA-A7E5-7DDC90A692EF,0,0,0,0,0,0,0,0,0,0,0 10492,75,"P 1300 119 919 E info intellihub.com.au www.intellihub.com.au Unit D1, 15 21 Doody Street, Alexandria, NSW 2015, Australia",0,0,0,0,0,0,0,0,0,0,0 10492,76,AND,0,0,0,0,0,0,0,0,0,0,0 10492,77,The Intellihub Groups Modern Slavery Statement has been approved by the Board of Directors of Spark Investment Holdco Pty Ltd as the parent entity and principal governing body for the Intellihub Group and its reporting entities,1,0,0,0,0,0,0,0,0,0,0 10492,78,Wes Ballantine Intellihub Group CEO,0,1,0,0,0,0,0,0,0,0,0 10492,79,October 2022 This is a joint modern slavery statement made pursuant to section 14 of the Modern Slavery Act 2018 (Cth),0,0,0,0,0,0,0,0,0,0,0 462,50,We will also be enhancing our employee training so that employees are better aware of the appropriate company policies in relation to slavery and human trafficking and understand that they have a responsibility to identify any potential breaches of those policies,0,0,0,0,0,0,0,1,0,0,0 462,51,This statement has been approved by the Board of Computershare Limited,1,0,0,0,0,0,0,0,0,0,0 462,52,Stuart Irving Chief Executive Officer 30 November 2020,0,1,0,0,0,0,0,0,0,0,0 462,53,Appendix This statement applies to the following Computershare Group reporting entities for the purposes of the Act and has been approved by the Boards of each of these entities: Computershare Investor Services Pty Limited Computershare Communication Services Pty Limited Registrars Holdings Pty Limited CDS International Pty Limited ACN 080 903 957 Pty Ltd ACN 081 035 752 Pty Ltd,1,0,1,0,0,0,0,0,0,0,0 890,0,MODERN SLAVERY STATEMENT Financial Year 2020,0,0,0,0,0,0,0,0,0,0,0 890,1,Weopposeslaveryandforcedlabour,0,0,0,0,0,0,0,0,0,0,0 890,2,"Asastrongvoiceforpeopleexperiencingdisadvantageandpoverty,andpassionateadvocatesforjustice,wedonotacceptanyformof slaveryorforcedlabour",0,0,0,0,0,0,0,0,0,0,0 890,3,"For90years,theBrotherhoodofSt",0,0,0,0,0,0,0,0,0,0,0 3708,16,Areas of opportunity,0,0,0,0,0,0,0,0,0,0,0 3708,17,How we measure the effectiveness of what we are doing,0,0,0,0,0,0,0,0,0,0,0 3708,18,Consultation,0,0,0,0,0,0,0,0,0,0,0 3708,19,Any other relevant information,0,0,0,0,0,0,0,0,0,0,0 3708,20,______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 3,0,0,0,0,0,0,0,0,0,0,0 3708,21,ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT,0,0,0,0,0,0,0,0,0,0,0 3708,22,Introduction and who we are,0,0,0,0,0,0,0,0,0,0,0 3708,23,This section addresses the mandatory criterion of identifying the reporting entity (section 16(1)(a) Modern Slavery Act),0,0,0,0,0,0,0,0,0,0,0 6063,36,Higher risk suppliers are required to complete a modern slavery questionnaire which is used by the Firm to evaluate the adequacy of a suppliers current anti-modern slavery policies and controls,0,0,0,0,0,0,0,1,0,0,0 6063,37,"Where appropriate, the assessment may also include a site audit and development of an action plan to address any identified gaps",0,0,0,0,0,0,0,1,0,0,0 6063,38,"Suppliers are also contractually required to adhere to the Firms supplier code of conduct (which explicitly forbids the use of forced labour and other forms of human rights abuses) and other policies, as applicable to the supplier, published in our supplier policy portal site",0,0,0,0,0,0,0,1,0,0,0 6063,39,"In addition to this, the Firm includes specific anti-slavery and human trafficking contractual clauses in contracts for goods and services that are categorised as of higher risk",0,0,0,0,0,0,0,1,0,0,0 6063,40,"Since June 2020, in light of the COVID-19 pandemic, the Firm has applied enhanced due diligence processes to pose additional questions to suppliers regarding workplace conditions and homeworking",0,0,0,0,0,0,0,1,0,0,0 6063,41,The Firm has also applied a media monitoring system to track media coverage of its key suppliers (approximately 50 suppliers),0,0,0,0,0,0,0,1,0,0,0 6063,42,"If any instances of modern slavery or human trafficking are suspected in the Firms business or supply chains, the Firm will investigate and, if substantiated, engage in remediation processes as appropriate, which may include terminating its relationship with the relevant supplier",0,0,0,0,0,0,0,0,1,0,0 6063,43,"Evaluating the effectiveness of the Firms actions The Firm monitors and reviews the following indicators of relevance to its effectiveness at combating slavery and human trafficking in the Firms business and supply chains: the number of modern slavery risk assessments carried out in relation to medium to high risk suppliers; supplier audit results; formal scorecard reporting on the performance of its key suppliers, including compliance and risk matters; and the number of staff provided with modern slavery training, including those completing our modern slavery e-learning module",0,0,0,0,0,0,0,0,0,1,0 10492,80,"It constitutes the joint modern slavery statement of Spark Investment Holdco Pty Ltd, Spark Investment Midco Pty Ltd, Intellihub Holdings Pty Ltd and Intellihub Australia Pty Ltd for the reporting period 1 July 2021 to 30 June 2022",0,0,0,0,0,0,0,0,0,0,0 10492,81,This modern slavery statement addresses each of the mandatory criteria for content set out in section 16 of the Modern Slavery Act 2018 (Cth),0,0,0,0,0,0,0,0,0,0,0 10492,82,DocuSign Envelope ID: 6B496E5F-D8EC-41BA-A7E5-7DDC90A692EF,0,0,0,0,0,0,0,0,0,0,0 11201,0,Senex Energy Pty Ltd Modern Slavery Statement Financial Year 2022,0,0,0,0,0,0,0,0,0,0,0 11201,1,Senex Energy Pty Ltd Modern Slavery Statement FY22,0,0,0,0,0,0,0,0,0,0,0 11201,2,Our commitment,0,0,0,0,0,0,0,0,0,0,0 11201,3,This Modern Slavery Statement by Senex Energy Pty Ltd (ABN 50 008 942 827) and its controlled entities (Senex) is prepared as required by the Modern Slavery Act 2018 (Cth) for the financial year ended 30 June 2022,0,0,1,0,0,0,0,0,0,0,0 11201,4,Senex consulted the relevant controlled entities in the development of this statement,0,0,0,0,0,0,0,0,0,0,1 890,4,Laurence(BSL)hasstoodalongsidethosemostdisadvantagedinourcommunityandadvocatedfortheir rights,0,0,0,0,0,0,0,0,0,0,0 890,5,Slaveryfundamentallystripsawayoneshumanrightsanddignity,0,0,0,0,0,0,0,0,0,0,0 890,6,"Unbelievably,inourveryowncountryandonthisverydaythereareapproximately15,000peoplelivinginconditionsofmodernslavery.*",0,0,0,0,0,0,0,0,0,0,0 890,7,"Itisourresponsibilitytoensurewestandagainstslavery,andensureouroperationsandoursupplychainsdonotinadvertentlyallowslavery tothrive",0,0,0,0,0,0,0,0,0,0,0 890,8,Thatswhyourorganisationalsystemsandprocessesmustbestrongastosuppressandreduceslavery,0,0,0,0,0,0,0,0,0,0,0 890,9,"Keytothisisourprocurement processesandpartneringprocesses,ensuringweonlyengagewithsuppliers,partnersandotherorganisationswhosepractices,processes andconvictiontoensuringnoslaverymirrorsours",0,0,0,0,0,0,0,0,0,0,0 890,10,"Wehaveinstigatedmanyactivitiesthatwillcontributetothemitigationofslavery,andourdevelopmentofathreeyearstrategytofurther minimisethelikelihoodofModernSlaveryinouroperationsandsupplychainwillreinforceandconsolidatetheseactivities",0,0,0,0,0,0,0,0,0,0,0 890,11,"Throughannual reporting,wewilldemonstrateourprogressagainststrategy,andholdourselvestoaccountonthisimportantissue",0,0,0,0,0,0,0,0,0,0,0 3708,24,"This is the modern slavery statement (Statement) for Adobe Systems Pty Ltd (Adobe Australia, we or us) and is made in accordance with the Commonwealth Modern Slavery Act 2018 (Modern Slavery Act)",0,0,1,0,0,0,0,0,0,0,0 3708,25,"This Statement constitutes Adobe Australias modern slavery and human trafficking statement for its financial year ending November 27, 2020",0,0,0,0,0,0,0,0,0,0,0 3708,26,"Adobe Australia is committed to acting ethically and responsibly and to use its position as one of the largest and most diversified software companies in the world, which enables customers including students, creative artists, small businesses, government agencies, and the largest global brandsto design and deliver exceptional digital experiences",0,0,0,0,1,0,0,0,0,0,0 3708,27,"We believe that creativity can change the worldand we are working with our employees, customers and partners to elevate diverse voices, give back to our communities and build a more sustainable future",0,0,0,0,0,0,0,0,0,0,0 3708,28,"Not only do we firmly support and comply with the anti-slavery and human trafficking laws in the countries in which we do business, but we work actively within our business circles to combat slavery and human trafficking",0,0,0,0,0,0,0,0,0,0,0 3708,29,"______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 4 Approval and Signing In accordance with section 13 of the Modern Slavery Act 2018 (Cth), this Modern Slavery Statement has been approved by the Board of Adobe Systems Pty Ltd on May 18, 2021",1,0,0,0,0,0,0,0,0,0,0 3708,30,Signature of Phillip Justin Judd Director of Board of Adobe Systems Pty Ltd Date,0,0,0,0,0,0,0,0,0,0,0 3708,31,Signature of Simon Keith Tate Director of Board of Adobe Systems Pty Ltd Date,0,0,0,0,0,0,0,0,0,0,0 6063,44,Training in relation to modern slavery and human trafficking The Firm has introduced a modern slavery e-learning module that seeks to: raise awareness about modern slavery and the various forms it can take; teach staff and partners to recognise the red flags that may indicate modern slavery; understand what to do if a case of modern slavery or human trafficking is suspected within the supply chain; and learn about the laws associated with modern slavery and the Firms policies in relation to preventing the occurrence of Modern Slavery within the supply chain,0,0,0,0,0,0,0,1,0,0,0 6063,45,allenovery.com,0,0,0,0,0,0,0,0,0,0,0 6063,46,The modern slavery e-learning module has been rolled out globally across the Firm and completing the course is mandatory for all of our staff and partners,0,0,0,0,0,0,0,1,0,0,0 6063,47,The Firm also delivers more targeted training for the teams and individuals within the business that have direct responsibility for procuring goods and services and managing suppliers,0,0,0,0,0,0,0,1,0,0,0 6063,48,The training is focused on raising awareness of the Firms specific procedures for identifying and appropriately screening higher risk suppliers,0,0,0,0,0,0,0,1,0,0,0 6063,49,"Consultation and approvals The Statement was prepared by the Firms central Risk team (with input from other teams) in consultation with, and reviewed and approved by, each of the individual entities comprising the Firm",0,0,0,0,0,0,0,0,0,0,1 6063,50,The Statement was approved by the Board of Allen & Overy LLP on behalf of the Firm on 19 October 2021,1,0,0,0,0,0,0,0,0,0,0 6063,51,"________________________________________ Wim Dejonghe Designated Member, on behalf of Allen & Overy LLP 19 October 2021 ________________________________________ Wim Dejonghe Director, on behalf of Allen & Overy Service Company Ltd 19 October 2021",0,1,0,0,0,0,0,0,0,0,0 11201,5,Senex is committed to transparency in relation to modern slavery and addressing any modern slavery risks in its operations and supply chain,0,0,0,0,0,0,0,0,0,0,0 11201,6,"Utilising the Senex Enterprise Risk Management Framework, our company undertakes risk assessments of modern slavery in our operations and supply chain",0,0,0,0,0,0,0,0,0,0,0 11201,7,This statement outlines progress to date and our future commitments,0,0,0,0,0,0,0,0,0,0,0 11201,8,"Our structure, operations, and supply chains",0,0,0,0,0,0,0,0,0,0,0 11201,9,"Senex is an established and growing Australian producer of low-carbon natural gas, committed to securing Australias energy future",0,0,0,0,1,0,0,0,0,0,0 11201,10,Senex has committed to invest more than A$1 billion in a major expansion of its Atlas and Roma North natural gas developments in Queenslands Surat Basin,0,0,0,0,1,0,0,0,0,0,0 11201,11,"The expansion is expected to increase Senexs production to 60 petajoules a year by the end of 2025, which is equivalent to more than 10 per cent of annual east coast domestic gas demand or around 40 per cent of Queenslands demand",0,0,0,0,1,0,0,0,0,0,0 11201,12,Senex employs more than 130 people and will increase its workforce to meet the demands of the expansion,0,0,0,1,0,0,0,0,0,0,0 890,12,ThisdocumentactstooutlineourstatementonModernSlaveryandprovidesinsighttosomeoftheactionswewilltaketosupportingan AustraliafreeofslaverysofundamentaltoourownvisionofanAustraliafreeofpoverty,0,0,0,0,0,0,0,0,0,0,0 890,13,ConnyLenneberg ExecutiveDirector,0,0,0,0,0,0,0,0,0,0,0 890,14,*GlobalSlaveryIndex2018referencing2016data,0,0,0,0,0,0,0,0,0,0,0 890,15,Contents,0,0,0,0,0,0,0,0,0,0,0 890,16,Thereportingentity,0,0,0,0,0,0,0,0,0,0,0 890,17,Organisationaloverview,0,0,0,0,0,0,0,0,0,0,0 890,18,Assessmentofmodernslaveryrisk,0,0,0,0,0,0,0,0,0,0,0 890,19,Actionstomitigatetherisks,0,0,0,0,0,0,0,0,0,0,0 3708,32,Signature of Jillian Elizabeth Forusz Director of Board of Adobe Systems Pty Ltd Date,0,0,0,0,0,0,0,0,0,0,0 3708,33,"Electronically signed by: Jillian Forusz Date: May 17, 2021 15:29 PDT 05/17/2021 Electronically signed by: Simon Tate Date: May 18, 2021 08:31 GMT+10 05/18/2021 Electronically signed by: Justin Judd Date: May 17, 2021 17:17 MDT 05/17/2021",0,1,0,0,0,0,0,0,0,0,0 3708,34,______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 5,0,0,0,0,0,0,0,0,0,0,0 3708,35,"Our Structure, Operations and Supply Chains",0,0,0,0,0,0,0,0,0,0,0 3708,36,"This section addresses the mandatory criterion of describing the structure, operations and supply chains of the reporting entity (section 16(1)(b) Modern Slavery Act)",0,0,0,0,0,0,0,0,0,0,0 3708,37,"Adobe Australia, a proprietary limited company incorporated and domiciled in Australia, is part of the Adobe group of companies sitting under our ultimate parent entity, Adobe Inc, which is an American publicly-traded company incorporated in Delaware, headquartered in San Jose, California, and listed on the Nasdaq Stock Exchange",0,0,0,1,0,0,0,0,0,0,0 3708,38,"Adobe Australia has a wholly owned subsidiary, Business Catalyst Systems Pty Ltd, however this subsidiary has no operations",0,0,0,1,0,0,0,0,0,0,0 3708,39,"In this Statement, we refer to the Adobe group of companies globally as the Adobe Group and a company within the Adobe Group as an Adobe Group Entity",0,0,0,0,0,0,0,0,0,0,0 6063,52,Allen & Overy means Allen & Overy LLP and/or its affiliated undertakings,0,0,0,0,0,0,0,0,0,0,0 6063,53,Allen & Overy LLP is a limited liability partnership registered in England and Wales with registered number OC306763,0,0,0,0,0,0,0,0,0,0,0 6063,54,Allen & Overy (Holdings) Limited is a limited company registered in England and Wales with registered number 07462870,0,0,0,0,0,0,0,0,0,0,0 6063,55,Allen & Overy LLP and Allen & Overy (Holdings) Limited are authorised and regulated by the Solicitors Regulation Authority of England and Wales,0,0,0,0,0,0,0,0,0,0,0 6063,56,"The term partner is used to refer to a member of Allen & Overy LLP or a director of Allen & Overy (Holdings) Limited or, in either case, an employee or consultant with equivalent standing and qualifications or an individual with equivalent status in one of Allen & Overy LLPs affiliated undertakings",0,0,0,0,0,0,0,0,0,0,0 6063,57,"A list of the members of Allen & Overy LLP and of the non-members who are designated as partners, and a list of the directors of Allen & Overy (Holdings) Limited, is open to inspection at our registered office at One Bishops Square, London E1 6AD",0,0,0,0,0,0,0,0,0,0,0 6063,58,Allen & Overy LLP 2021,0,0,0,0,0,0,0,0,0,0,0 6063,59,This document is for general information purposes only and is not intended to provide legal or other professional advice,0,0,0,0,0,0,0,0,0,0,0 11201,13,"Importantly, increased supply of Senexs sustainable and reliable natural gas means energy security for industry and manufacturers",0,0,0,0,0,0,0,0,0,0,0 11201,14,Senex has also committed to net zero operational emissions by 2040,0,0,0,0,0,0,0,0,0,0,0 11201,15,"Senex was previously a public company listed on the ASX until 4 April 2022 when it was delisted, after the 100% acquisition of Senex shares by Senex Holdings Pty Ltd on 1 April 2022",0,0,0,1,0,0,0,0,0,0,0 11201,16,"Senex is now a private proprietary company owned by Senex Holdings Pty Ltd, a company owned by POSCO International Corporation (50.1%) and Hancock Energy Corporation Pty Ltd (49.9%)",0,0,0,1,0,0,0,0,0,0,0 11201,17,"There was no change in the management of Senex, and operations continue as before",0,0,0,0,0,0,0,0,0,0,0 11201,18,"As at 30 June 2022, Senex held the following subsidiaries",0,0,0,1,0,0,0,0,0,0,0 11201,19,Azeeza Pty Ltd ACN 009 030 068,0,0,0,1,0,0,0,0,0,0,0 11201,20,Permian Oil Pty,0,0,0,1,0,0,0,0,0,0,0 890,20,Existingpoliciesandprocedures,0,0,0,0,0,0,0,0,0,0,0 890,21,ActivitiesundertakeninFY2020,0,0,0,0,0,0,0,0,0,0,0 890,22,Actionsmovingforward,0,0,0,0,0,0,0,0,0,0,0 890,23,Measuringsuccess,0,0,0,0,0,0,0,0,0,0,0 890,24,Initialmeasures,0,0,0,0,0,0,0,0,0,0,0 890,25,Potentialfuturemeasures,0,0,0,0,0,0,0,0,0,0,0 890,26,Consultation,0,0,0,0,0,0,0,0,0,0,0 890,27,Anyotherrelevantinformation,0,0,0,0,0,0,0,0,0,0,0 3708,40,"Since the inception of our Australian operations in 1991, Adobe Australia (with its 450+ employees and ecosystem of partners who are official resellers and distributors of our products) has become a leader in designing and developing exceptional digital experiences, transforming many industries, such as banking, healthcare, government and retail",0,0,0,1,0,0,0,0,0,0,0 3708,41,"Our software and services include content creation, marketing, advertising, analytics and commerce",0,0,0,0,1,0,0,0,0,0,0 3708,42,"Adobe Australia supplies very few physical products, although we do have limited physical production and distribution of certain Digital Media and Print and Publishing Business Unit products",0,0,0,0,1,0,0,0,0,0,0 3708,43,"For these products we have outsourced our supplier needs to Adobe Systems Software Ireland Limited (Adobe Ireland), which has one of their suppliers, located in Singapore, with inventory locations in Singapore, Germany and the U.S",0,0,0,0,0,1,0,0,0,0,0 3708,44,This supplier in Singapore produces packaging for our Digital Media and Print and Publishing Business Unit products,0,0,0,0,0,1,0,0,0,0,0 3708,45,Adobe Irelands supplier in Singapore in turn has one subcontractor in Japan that produces product DVDs for our Print and Publishing Business Unit products but does not hold any inventory,0,0,0,0,0,1,0,0,0,0,0 3708,46,Where we operate Adobe Australias primary focus is to serve its partners and customers in Australia and it has offices in Sydney and Melbourne,0,0,0,0,1,0,0,0,0,0,0 3708,47,Where we source The majority of goods and services Adobe Australia procures come from suppliers and contractors based in Australia,0,0,0,0,0,1,0,0,0,0,0 6063,60,| UKS1: 2006168676.1,0,0,0,0,0,0,0,0,0,0,0 6272,0,OSW Modern Slavery Statement 1,0,0,0,0,0,0,0,0,0,0,0 6272,1,One Stop Warehouse Pty Ltd Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 6272,2,OSW Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 6272,3,Introduction This is the first Modern Slavery Statement (Statement) produced by One Stop Warehouse Pty Ltd (ACN 161 849 323) (OSW) under the Modern Slavery Act 2018 (Cth) (Act),0,0,0,0,0,0,0,0,0,0,0 6272,4,This Statement sets out the actions taken by OSW to assess and address modern slavery risks in its operations and supply chains for the reporting period 1 July 2020 30 June 2021 (Reporting Period),0,0,0,0,0,0,0,0,0,0,0 6272,5,"This Statement is a joint statement and applies to OSW and all of its controlled entities, including One Stop Warehouse Finance Pty Ltd (ACN 609 758 143), Client Solutions Pty Ltd (ACN 604 283 472), Sailfish Storage Pty Ltd (ACN 651 732 455), Solar & Battery Central Pty Ltd (ACN 649 507 040), Solar & Battery Place Pty Ltd (ACN 649 506 007) and all majority-owned and/or controlled subsidiaries of OSW Warehouse that meet the definition of reporting entity under the Act",0,0,1,1,0,0,0,0,0,0,0 6272,6,"Business and Operations OSW is an Australian company that is a wholesale distributor of Solar PV panels, solar invertors, components and electrical products",0,0,0,0,1,0,0,0,0,0,0 11201,21,Ltd,0,0,0,1,0,0,0,0,0,0,0 11201,22,ACN 104 456 386,0,0,0,1,0,0,0,0,0,0,0 11201,23,Senex Assets Pty Ltd ACN 160 649 338,0,0,0,1,0,0,0,0,0,0,0 11201,24,Senex Assets 2 Pty Ltd ACN 650 731 918,0,0,0,1,0,0,0,0,0,0,0 11201,25,Senex Compression Facility Pty Ltd ACN 654 787 747,0,0,0,1,0,0,0,0,0,0,0 11201,26,Senex Qld Exploration Pty Ltd ACN 623 117 251,0,0,0,1,0,0,0,0,0,0,0 11201,27,Senex Weribone Pty Ltd ACN 007 897 627,0,0,0,1,0,0,0,0,0,0,0 11201,28,"Stuart Petroleum Pty Ltd ACN 059 146 226, which is the holder of 100% of the issued share capital in",0,0,0,1,0,0,0,0,0,0,0 890,28,Thereportingentity TheBrotherhoodofStLaurenceisanassociationdomiciledinAustraliaandisanotforprofitentity,0,0,1,1,0,0,0,0,0,0,0 890,29,"Theaddressofitsregisteredofficeis67 BrunswickStreet,Fitzroy,Victoria3065",0,0,0,1,0,0,0,0,0,0,0 890,30,TheBoardisappointedbytheBrotherhoodofStLaurenceCharterandLifeMemberstogovernthe organisationsactivities,0,0,0,1,0,0,0,0,0,0,0 890,31,Organisationaloverview Weareasocialjusticeorganisationworkingalongsidepeopleexperiencingdisadvantagetoaddressthefundamentalcausesofpovertyin Australia,0,0,0,0,1,0,0,0,0,0,0 890,32,Webelievenooneshouldliveinpoverty,0,0,0,0,0,0,0,0,0,0,0 890,33,"Ourmissionistopursuelastingchange,tocreateamorecompassionateandjustsocietywhereeveryonecanthrive",0,0,0,0,0,0,0,0,0,0,0 890,34,Weareproudtobeastrongvoiceforpeopleexperiencingdisadvantage,0,0,0,0,0,0,0,0,0,0,0 890,35,Ithasbeenourwaysincethe1930swhenFatherTuckersactivismfor socialreformamidtheGreatDepressionledtoourinception,0,0,0,0,0,0,0,0,0,0,0 3708,48,Adobe Australias main categories of procurement include,0,0,0,0,0,0,0,0,0,0,0 3708,49,Property/Facilities Facilities Services Marketing Services Information Technology,0,0,0,0,0,1,0,0,0,0,0 3708,50,______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 6,0,0,0,0,0,0,0,0,0,0,0 3708,51,Human Resources Services Professional Services (ie consulting; advisory),0,0,0,0,0,1,0,0,0,0,0 3708,52,Adobe Australia sells Adobe software licences and services within Australia,0,0,0,0,1,0,0,0,0,0,0 3708,53,"Whilst Adobe Australia does not manufacture in the traditional sense with the use of factories or labour houses, Adobe Australia evaluates its supply chain to identify any partners and suppliers that might pose risks for illegal or unethical behavior such as engaging in human trafficking, slavery or other human rights violations",0,0,0,0,1,0,0,0,0,0,0 3708,54,"Adobe Australia oversees a supply chain that includes approximately 75 offshore indirect vendors, the majority of which are in the US",0,0,0,0,0,1,0,0,0,0,0 3708,55,"These vendors provide marketing services, technology products and services, non-tech professional services, human resources and facilities services to Adobe Australia",0,0,0,0,0,1,0,0,0,0,0 6272,7,"OSW is committed to reducing the carbon footprint, driving sustainability, and responsible environmental management in line with the recommendations of AS/NZS ISO 14001",0,0,0,0,0,0,0,0,0,0,0 6272,8,Supply chain OSW operates its business from its offices in Australia,0,0,0,0,1,0,0,0,0,0,0 6272,9,"As part of its supply chain, OSW receives supplies relating to solar panels, batteries, inverters, mountings, optimizers and other electrical equipment, and has numerous key supply partners in its global supply chain",0,0,0,0,0,1,0,0,0,0,0 6272,10,"OSWs major suppliers include, but are not limited to",0,0,0,0,0,1,0,0,0,0,0 6272,11,"Sungrow Power Supply Co., Ltd, a supplier of power supply equipment for renewable energy",0,0,0,0,0,1,0,0,0,0,0 6272,12,GCL System Integration Technology Co,0,0,0,0,0,1,0,0,0,0,0 6272,13,"Ltd (002506 Shenzhen Stock), an international energy company specialising in clean and sustainable power production",0,0,0,0,0,1,0,0,0,0,0 6272,14,LONGi Green Energy Technology Co,0,0,0,0,0,1,0,0,0,0,0 11201,29,Senex Energy Pty Ltd Modern Slavery Statement FY22,0,0,0,0,0,0,0,0,0,0,0 11201,30,o Stuart Petroleum Cooper Basin Gas Pty Ltd ACN 130 588 055; and o Stuart Petroleum Cooper Basin Oil Pty Ltd ACN 130 588 019,0,0,0,1,0,0,0,0,0,0,0 11201,31,Victoria Oil Pty,0,0,0,1,0,0,0,0,0,0,0 11201,32,Ltd,0,0,0,0,0,0,0,0,0,0,0 11201,33,ACN 010 514 119; and,0,0,0,1,0,0,0,0,0,0,0 11201,34,Victoria Oil Exploration (1977) Pty,0,0,0,1,0,0,0,0,0,0,0 11201,35,Ltd,0,0,0,0,0,0,0,0,0,0,0 11201,36,ACN 008 898 431,0,0,0,1,0,0,0,0,0,0,0 890,36,"Usingourstrongfocusonresearchinpracticealongsideourprogramsandservices,wecreateevidencethatinformsdesignofinnovative solutionsforpeopleofallages",0,0,0,0,0,0,0,0,0,0,0 890,37,Wealsousethisevidencetoinformpolicymakersonmakingtherightpolicydecisionstoreducepovertyacross Australia,0,0,0,0,0,0,0,0,0,0,0 890,38,"Inadditiontoourresearchandevidence,ourfocusonpartnershipsiskeytooursuccess",0,0,0,0,0,0,0,0,0,0,0 890,39,"Weworktogetherwithpeoplewhoexperience disadvantage,andtheorganisationswhoassistthem,tounderstandtheirlivedexperiencesandamplifytheirvoicestodrivechange",0,0,0,0,1,0,0,0,0,0,0 890,40,"We developmodelsbyworkingwithotherorganisations,bothlocallyandnationally,tobroadenourimpact",0,0,0,0,1,0,0,0,0,0,0 890,41,Wethenscaleupthesemodelsand influencethestructuresthatareoftenatthecauseofpoverty,0,0,0,0,1,0,0,0,0,0,0 890,42,"Today,ourcommunityprogramsandservicessupportpeoplerightacrossthelifespan,fromearlyyearstoseniors,andwithsupportthatenables peopletodeveloptheircapabilityandcapacitytoovercomedisadvantage,includingeducation,training,employmentsupport,care,andsomuch more",0,0,0,0,1,0,0,0,0,0,0 890,43,"ThisincludesourLocalAreaCoordinationServiceimplementingtheNationalDisabilityInsuranceScheme,whereweareactivelysupport peoplewithdisabilitytomaketheirownchoicesanddecisions",0,0,0,0,1,0,0,0,0,0,0 3708,56,Adobe Australia outsources manufacturing and fulfillment to a single vendor based in Singapore,0,0,0,0,0,1,0,0,0,0,0 3708,57,Modern Slavery Risks in our Operations and Supply Chains,0,0,0,0,0,0,0,0,0,0,0 3708,58,"This section addresses the mandatory criterion of describing the risks of modern slavery practices in the operations and supply chains of the reporting entity, and any entities that the reporting entity owns or controls (section 16(1)(c) Modern Slavery Act)",0,0,0,0,0,0,0,0,0,0,0 3708,59,How we identified modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 3708,60,Adobe Australia is in the process of mapping out the modern slavery risks in its operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 3708,61,"Given that our wholly owned subsidiary, Business Catalyst Systems Pty Ltd, does not have its own operations or supply chains, we have not included this entity in our risk mapping exercise",0,0,0,1,1,1,0,0,0,0,0 3708,62,We have also had the benefit of the information in the Modern Slavery Act 2018 Guidance for Reporting Entities (Commonwealth Guidance) and the Global Slavery Index 2018 published by the Minderoo Foundation (Global Slavery Index) to inform our identification of modern slavery risks,0,0,0,0,0,0,0,1,0,0,0 3708,63,Modern slavery risks identified,0,0,0,0,0,0,0,0,0,0,0 6272,15,"Ltd, a supplier of products and services in the photovoltaic and semiconductor industry",0,0,0,0,0,1,0,0,0,0,0 6272,16,"Huawei, a global provider of information and communications technology (ICT) infrastructure and smart devices",0,0,0,0,0,1,0,0,0,0,0 6272,17,"Canadian Solar, a global manufacturer of solar PV modules and solar system solutions; and",0,0,0,0,0,1,0,0,0,0,0 6272,18,"Q-Cells, a manufacturer of photovoltaic solar cells",0,0,0,0,0,1,0,0,0,0,0 6272,19,Modern slavery risks OSW have conducted a risk assessment of its supply chain by taking into account the risk profile of individual countries and the services provided by its key suppliers,0,0,0,0,0,0,0,1,0,0,0 6272,20,"Due to the nature of OSWs business model, OSW recognises the potential risks of modern slavery and human trafficking occurring within its Australian and international supply chain",0,0,0,0,0,0,1,0,0,0,0 6272,21,"OSW sources a high proportion of its solar and electrical products from suppliers that operate in high risk countries, including China",0,0,0,0,0,0,1,0,0,0,0 6272,22,OSW undertakes due diligence on its suppliers and their supply chains and takes action as necessary to manage any suppliers who it has identified as high risk,0,0,0,0,0,0,0,0,0,0,0 11201,37,Operations Senex owns and operates several natural gas supply projects in the Surat Basin in southern Queensland,0,0,0,0,1,0,0,0,0,0,0 11201,38,"Our Atlas operation, near Wandoan, is dedicated to supplying the domestic market and provides gas to commercial and industrial customers",0,0,0,0,1,0,0,0,0,0,0 11201,39,"Since 2019, Senex has signed almost 90 petajoules of natural gas sales agreements with household names in power generation and manufacturing from CleanCo Queensland and Southern Oil Refining, to CSR Building Products, Orora and Visy Glass, just to name a few",0,0,0,0,1,0,0,0,0,0,0 11201,40,In January 2022 Senex acquired undeveloped gas fields PL209 and PL445 from APLNG,0,0,0,0,1,0,0,0,0,0,0 11201,41,These fields are adjacent to and will complement the Atlas operation,0,0,0,0,1,0,0,0,0,0,0 11201,42,"Senexs Roma North operation, near Roma, provides important natural gas supplies to the GLNG liquefied natural gas project as well as the domestic market",0,0,0,0,1,0,0,0,0,0,0 11201,43,Supply chain Senex contracts and partners with predominantly Australia-domiciled companies that provide specialised gas services in the following areas,0,0,0,0,0,1,0,0,0,0,0 11201,44,drilling and well completion services,0,0,0,0,0,1,0,0,0,0,0 890,44,"Complementingourdeliveryofresearch,advocacyandprogramsandservices,isoursocialenterprisebusinesses,includingour23opshops acrossMelbourneandGeelongandouronlinebookstore",0,0,0,0,1,0,0,0,0,0,0 890,45,Thesearesupportedbyourvolunteersandthecommunitytoraisefundsforour innovativeprogramsandpolicydevelopment,0,0,0,0,1,0,0,0,0,0,0 890,46,"Ourorganisationemploys1,480peopleatsome70sitelocationsandtapsintothecommunityeffortofafurther1,200volunteers",0,0,0,1,1,0,0,0,0,0,0 890,47,"Inasurvey conductedin201314,2.6percentofstaffidentifiedasAboriginalandTorresStraitIslander",0,0,0,0,1,0,0,0,0,0,0 890,48,TolearnmoreabouttheBrotherhoodofSt,0,0,0,0,0,0,0,0,0,0,0 890,49,"Laurence,pleasevisitbsl.org.au",0,0,0,0,0,0,0,0,0,0,0 890,50,"Assessmentofmodernslaveryrisk Likemanyotherlargeorganisations,werecognisethatmodernslaveryispervasiveacrossallsectors,andthereforemayexistsomewhereinour supplychainandoperations",0,0,0,0,0,0,0,0,0,0,0 890,51,"Wemanagemanydifferenttypesofprogramstoaddresspovertyinalargerangeofdemographics,withdedicatedfundingfromavarietyof sources,procurementhasbeendispersedandsiloed",0,0,0,0,0,0,1,0,0,0,0 3708,64,"Entity risk evaluation The Adobe Group conducts a prioritized, risk-based assessment on its sales partners in the same way that it conducts a risk-based assessment on its suppliers",0,0,0,0,0,0,0,1,0,0,0 3708,65,Adobe Irelands supplier in Singapore performed a risk assessment utilizing the self-assessment tool available through the RBA (Responsible Business Alliance),0,0,0,0,0,0,1,0,0,0,0 3708,66,This supplier has also been assessed as low risk under the Self-Assessment Questionnaire (SAQ) and therefore no audits,0,0,0,0,0,0,1,0,0,0,0 3708,67,______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 7,0,0,0,0,0,0,0,0,0,0,0 3708,68,were required,0,0,0,0,0,0,1,0,0,0,0 3708,69,This supplier uses the SAQ to self-assess risk management systems and identify gaps related to workers rights and environmental related issues,0,0,0,0,0,0,0,0,0,0,0 3708,70,"Pre-COVID, Adobe Systems Pte",0,0,0,0,0,0,0,0,0,0,0 3708,71,"Ltd (Adobe Singapore) personnel would be present during the assembly production process during product launches and observe the staff working in the warehouse, and we would anticipate this process will resume again when safe to do so",0,0,0,0,0,0,0,0,0,0,0 6272,23,There is risk of OSW being directly linked or contributing to modern slavery within its supply chain due to suppliers location in high risk locations or OSWs sourcing of products that are known to have high risk supply chains,0,0,0,0,0,0,1,0,0,0,0 6272,24,Poor procurement practices including pressure to drive down costs can further increase our risks,0,0,0,0,0,0,1,0,0,0,0 6272,25,OSW Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 6272,26,"In the Reporting Period, OSW has identified that",0,0,0,0,0,0,1,0,0,0,0 6272,27,"one key supplier has a supply chain which has established links to slave labour, and poses a modern slavery risk to the organisation; and",0,0,0,0,0,0,1,0,0,0,0 6272,28,another key supplier potentially has a supply chain that poses modern slavery risks to the organisation,0,0,0,0,0,0,1,0,0,0,0 6272,29,OSW is currently assessing these situations and reviewing its current supplier contracts with these suppliers to assess the risks of this affecting OSWs supply chain,0,0,0,0,0,0,0,0,1,0,0 6272,30,OSW will work with the relevant suppliers to ensure that these risks are appropriately managed and resolved to OSWs satisfaction,0,0,0,0,0,0,0,0,1,0,0 11201,45,construction of well pads and pipelines,0,0,0,0,0,1,0,0,0,0,0 11201,46,operations of above-ground gas processing facilities,0,0,0,0,0,1,0,0,0,0,0 11201,47,logistics,0,0,0,0,0,1,0,0,0,0,0 11201,48,specialist technical services,0,0,0,0,0,1,0,0,0,0,0 11201,49,corporate and professional services,0,0,0,0,0,1,0,0,0,0,0 11201,50,What we buy,0,0,0,0,0,0,0,0,0,0,0 11201,51,"engineering, construction, and fabrication services",0,0,0,0,0,1,0,0,0,0,0 11201,52,"drilling, compression, and wellhead equipment",0,0,0,0,0,1,0,0,0,0,0 890,52,"Thishasresultedinalargenumberofsuppliers,manywithlowspend,engagedinavariety ofways",0,0,0,0,0,0,1,0,0,0,0 890,53,"Whilstwearenotawareofanymodernslaverypracticesinthesupplychain,thesheernumberofsuppliersincreasestheuncertainty ofacleanchain",0,0,0,0,0,0,1,0,0,0,0 890,54,"Atthisstage,theuncertaintyaroundthesupplychainisthebiggestrisktotheBrotherhoodofSt",0,0,0,0,0,0,1,0,0,0,0 890,55,LaurenceofModernSlavery,0,0,0,0,0,0,1,0,0,0,0 890,56,"Thisisanevolvingprocessandaswebetterunderstandoursuppliersandsupplychain,andasmorestaffareawareoftheissueofmodern slavery,itisexpectedthattheriskswillbecomemoredetailed,targetedandunderstood",0,0,0,0,0,0,0,0,0,0,0 890,57,Actionstomitigatetherisks Modernslaverycanthrivewhenthereisalackofpolicyandgovernance,0,0,0,0,0,0,0,0,0,0,0 890,58,WehavecommittedtodevelopingaModernSlaveryStrategy(the Strategy)inFY2021,0,0,0,0,0,0,0,1,0,0,0 890,59,"Overthenextthreeyears,wewillcontinuetoimplementinitiativestoensurethelikelihoodofmodernslaverywithinour operationsandsupplychainisminimised",0,0,0,0,0,0,0,1,0,0,0 3708,72,"Geographic risks The Adobe Group has a list of higher-risk countries, which it refers to when considering risks in its supply chains",0,0,0,0,0,0,0,0,0,0,0 3708,73,We have a supplier for our Digital Media and Print and Publishing Business Unit products in Singapore and this supplier has one subcontractor in Japan,0,0,0,0,0,1,1,0,0,0,0 3708,74,Japan and Singapore are countries recognised by the Global Slavery Index as medium risk in terms of their governments responses to modern slavery,0,0,0,0,0,0,1,0,0,0,0 3708,75,"Sector risks Adobe Australia procures Facilities Services, which include cleaning services",0,0,0,0,0,1,0,0,0,0,0 3708,76,We are aware that cleaning services by their nature are recognised as a higher risk sector,0,0,0,0,0,0,1,0,0,0,0 3708,77,"However, the Adobe Group has conducted a risk assessment on our cleaning services provider",0,0,0,0,0,0,1,0,0,0,0 3708,78,"Based on the suppliers own internal modern slavery policies and practices, our cleaning services provider is not high risk",0,0,0,0,0,0,1,0,0,0,0 3708,79,Product and services risks Adobe Australia procures Information Technology (IT),0,0,0,0,0,1,0,0,0,0,0 6272,31,"Where not resolved, OSW will explore opportunities to replace such suppliers with compliant suppliers",0,0,0,0,0,0,0,0,1,0,0 6272,32,Actions taken to address risks of modern slavery OSW has taken the following steps to manage and safeguard against modern slavery and human trafficking risks within its business and supply chain,0,0,0,0,0,0,0,0,0,0,0 6272,33,Policies OSW is committed to high standards of corporate governance,0,0,0,0,0,0,0,0,0,0,0 6272,34,OSW has a number of policy and procedural documents in place to provide a framework for protection against slavery and human trafficking,0,0,0,0,0,0,0,1,0,0,0 6272,35,"In the Reporting Period, OSW has updated its policies and procedures to identify and manage risks associated with slavery and human trafficking, including OSWs code of conduct which outlines the corporate values and ethical principles, and sets out the acceptable behaviours expected of OSWs employees, contractors and suppliers",0,0,0,0,0,0,0,1,0,0,0 6272,36,"Supplier due diligence OSW is also committing to improving its procurement systems to have better oversight over its suppliers, particularly those suppliers based in high risk jurisdictions",0,0,0,0,0,0,0,0,0,0,0 6272,37,"When engaging new suppliers in its supply chain, OSW has committed to",0,0,0,0,0,0,0,1,0,0,0 6272,38,identify any high-risk jurisdictions in its supply chain,0,0,0,0,0,0,0,1,0,0,0 11201,53,"pipeline materials, including valves and fittings",0,0,0,0,0,1,0,0,0,0,0 11201,54,wellsite services,0,0,0,0,0,1,0,0,0,0,0 11201,55,maintenance spares and services,0,0,0,0,0,1,0,0,0,0,0 11201,56,electrical and electronic equipment,0,0,0,0,0,1,0,0,0,0,0 11201,57,operations support services including remote accommodation and catering services,0,0,0,0,0,1,0,0,0,0,0 11201,58,"specialist labour, professional and corporate services",0,0,0,0,0,0,0,0,0,0,0 11201,59,"In 2022, we had 521 active vendors and suppliers and spent $148 million with 33 Tier 1 suppliers (direct suppliers with $1 million spend per annum)",0,0,0,0,0,1,0,0,0,0,0 11201,60,We have established long-term,0,0,0,0,0,1,0,0,0,0,0 890,60,"TheStrategywillbebaseduponaprincipleofcontinuousimprovementaswelearnmoreaboutour potentialexposures,theStrategywillevolvetoaddressthese",0,0,0,0,0,0,0,1,0,0,0 890,61,"Thereareexistingcontrols;policies,processes,practicesandethicalapproachesthatlowertherisksofmodernslaveryinouroperations",0,0,0,0,0,0,0,1,0,0,0 890,62,"In addition,activitieswereundertakeninfinancialyear2020targetedtoimprovetheoverallmanagementandgovernanceoftheorganisationand willhaveanimpactontherisksofmodernslavery",0,0,0,0,0,0,0,1,0,0,0 890,63,OurAudit&RiskCommitteeisresponsibleforprovidingoversightonbehalfoftheBoard,0,0,0,0,0,0,0,1,0,0,0 890,64,It monitorscompliancewithourethicalrelatedpolicies,0,0,0,0,0,0,0,1,0,0,0 890,65,Existingpoliciesandprocedures Wehavecorporatepoliciesandproceduresthatcontributetoensuringthedirectrisksofmodernslaveryareeffectivelymanagedwithin our operations,0,0,0,0,0,0,0,1,0,0,0 890,66,Each of these has a continual review process into which findings and further treatments for modern slavery can be incorporatedtoensurebestpractice,0,0,0,0,0,0,0,1,0,1,0 890,67,"Theseare: whistleblowingpolicy codeofethics partnershipspolicy recruitmentpoliciesandprocesses complainthandlingpolicy staffhaveaccesstoanemployeeassistanceprogram unionrecognition bullying,stalking,cyberbullyingandworkplaceviolencepolicy volunteermanual 4.2",0,0,0,0,0,0,0,1,0,0,0 3708,80,Some IT products and services may be higher risk due to the way in which they are produced such as by using low skilled labour,0,0,0,0,0,0,1,0,0,0,0 3708,81,Assessing and Addressing Potential and Actual Modern Slavery Risks,0,0,0,0,0,0,0,0,0,0,0 3708,82,"This section addresses the mandatory criterion of describing the actions taken by the reporting entity and any entity that the reporting entity owns or controls, to assess and address those risks, including due diligence and remediation processes (section 16(1)(d) Modern Slavery Act)",0,0,0,0,0,0,0,0,0,0,0 3708,83,The Adobe Group Entities are committed to taking action to assess and address modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 3708,84,The measures described in this section are part of the global approach taken by the Adobe Group,0,0,0,0,0,0,0,0,0,0,0 3708,85,"Pursuant to the Modern Slavery Act, the Adobe Group has taken steps to identify the risk of slavery and human trafficking taking place in any of its supply chains and in any part of its business",0,0,0,0,0,0,0,0,0,0,0 3708,86,The Adobe Group commits publicly to the Responsible Business Alliance (RBA) Code of Conduct (Code) and actively pursues conformance to the Code and its standards as a total supply chain initiative,0,0,0,0,0,0,0,1,0,0,0 3708,87,"The Adobe Group also requires business partners and suppliers to agree to its Business Partner Code of Conduct which outlines necessary management systems to ensure workers' rights are protected and includes abiding by its Labour Standards Freely Chosen Employment, Child Labour Avoidance, Lawful Employment, Non-Discrimination or",0,0,0,0,0,0,0,1,0,0,0 6272,39,evaluate the modern slavery risks of each new supplier / distributor prior to entering into a contractual relationship; and,0,0,0,0,0,0,0,1,0,0,0 6272,40,obtain specific contractual commitment with respect to modern slavery risks from each of its suppliers through inclusion of appropriate contractual terms with its suppliers,0,0,0,0,0,0,0,1,0,0,0 6272,41,"In the event that slavery or human trafficking is found to be occurring within our direct supply chain in the future, OSW will engage directly with the supplier to remedy the issue, and may terminate the supplier relationship if the issue is severe and cannot be remedied to align with OSWs policies",0,0,0,0,0,0,0,0,1,0,0 6272,42,Awareness and training OSW recognises the vital role that internal training and development plays in promoting awareness of modern slavery risks and responses,0,0,0,0,0,0,0,0,0,0,0 6272,43,"To assist with the identification and mitigation of modern slavery risks going forward, OSW has committed to provide a modern slavery awareness training program to its employees (including those of its wholly-owned subsidiaries) covering",0,0,0,0,0,0,0,1,0,0,0 6272,44,information about what constitutes modern slavery,0,0,0,0,0,0,0,1,0,0,0 6272,45,how employees can identify signs of modern slavery and human trafficking; and,0,0,0,0,0,0,0,1,0,0,0 6272,46,how employees should respond if they suspect slavery or human trafficking,0,0,0,0,0,0,0,1,0,0,0 11201,61,Senex Energy Pty Ltd Modern Slavery Statement FY22,0,0,0,0,0,0,0,0,0,0,0 11201,62,"relationships with many of our suppliers, the majority of which are located in Australia",0,0,0,0,0,1,0,0,0,0,0 11201,63,Australian suppliers comprise at least 98 per cent of our total expenditure,0,0,0,0,0,1,0,0,0,0,0 11201,64,"In addition to our Australian suppliers, about $4.3 million of our annual procurement spending is directly with overseas suppliers operating in six countries, primarily Canada and the United States",0,0,0,0,0,1,0,0,0,0,0 11201,65,"Wherever possible, Senex actively pursues opportunities to sustain and grow local Surat Basin businesses",0,0,0,0,0,0,0,0,0,0,0 11201,66,"In 2022, the local supplier base represented 7 per cent of our total expenditure (local refers to Roma, Wandoan and neighbouring communities)",0,0,0,0,0,1,0,0,0,0,0 11201,67,Senex released its first standalone Sustainability Report in November 2021,0,0,0,0,0,0,0,0,0,0,0 11201,68,The Sustainability Report contains information on our sustainable practices across our supply chain and our partnerships with local suppliers,0,0,0,0,0,0,0,0,0,0,0 890,68,"ActivitiesundertakeninFY2020 RecruitmentofaninternalGeneralCounselroletoprovideaconduittoensureeffectiveandrobustcontractdevelopment,andmore effectivecorporategovernance",0,0,0,0,0,0,0,1,0,0,0 890,69,"Implementedanewfinancesystem,whichhasenabledimprovedanalysisandunderstandingofthesuppliersweutilise",0,0,0,0,0,0,0,1,0,0,0 890,70,Thishas highlightedalargeandcomplexsupplychain,0,0,0,0,0,0,0,1,0,0,0 890,71,"Asthisisfurtherembedded,thiswillassistinmonitoringthedevelopmentand implementationoftheStrategyandprovidedetailtohelpassesstherisks",0,0,0,0,0,0,0,1,0,0,0 890,72,"ActivitiesidentifiedwithintheReconciliationActionPlanandSocialProcurementpolicyensurethatourprocurementpreferences organisationsestablishedtosupport,orexclusivelyrunby,keyatriskdemographics",0,0,0,0,0,0,0,1,0,0,0 890,73,Implementedacentralisedprocurementframeworktoensureconsistencyinprocurementmethodologiesandarobustapproachto vettingofpotentialsuppliers,0,0,0,0,0,0,0,1,0,0,0 890,74,Thisincludes: ethicalprocurement standardprinciplesforrequestsfortender standardcontracts centralrepositoryforprocurementdocuments effectivegovernanceforprocurements consistentcontractmanagement implementationofapreferredproviderpanelprocess enhancedduediligenceprocess stafftraining ReviewoftheBrotherhoodofSt,0,0,0,0,0,0,0,1,0,0,0 890,75,Laurencepartnershipframeworktohighlightourappetiteforengagingwithorganisationsthat generatebusinesswithincertainsectorsthatdonotalignwithourvalues,0,0,0,0,0,0,0,1,0,0,0 3708,88,______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 8,0,0,0,0,0,0,0,0,0,0,0 3708,89,"Harassment, Freedom of Association, Safe Conditions, Working Hours, and Wage and Benefits",0,0,0,0,0,0,0,1,0,0,0 3708,90,The steps taken by the Adobe Group for direct suppliers that produce its products include,0,0,0,0,0,0,0,1,0,0,0 3708,91,"Verification: The Adobe Group Companies evaluate and address risks of human trafficking and slavery through conformance to the Code, Section A.I, which states, among other standards, that forced, bonded (including debt bondage) or indentured labour, involuntary prison labour, slavery or trafficking of persons shall not be used",0,0,0,0,0,0,0,1,0,0,0 3708,92,"They pursue conformance by using the RBA's Maplecroft Risk Assessment tool, the Supplier Self- Assessment Questionnaire, and Validated Audit Process (VAP)",0,0,0,0,0,0,0,1,0,0,0 3708,93,"The Maplecroft Risk Assessment tool is a third-party service that evaluates risks with respect to the Code (including Section A.I) by inherent risk, sector and location",0,0,0,0,0,0,0,0,0,0,0 3708,94,The Supplier Self-Assessment Questionnaire (SAQ) is a self- evaluation that inquires about demographics and existing policies at the facility level against all sections of the Code,0,0,0,0,0,0,0,0,0,0,0 3708,95,"The VAP audits carried out on RBA member facilities and their suppliers' facilities are completed by independent, third-party auditors specially trained in social and environmental auditing and the VAP audit protocol",0,0,0,0,0,0,0,1,0,0,0 6272,47,OSW Modern Slavery Statement 4,0,0,0,0,0,0,0,0,0,0,0 6272,48,"Assessing the effectiveness of our actions The effectiveness of OSWs actions to mitigate modern slavery risks will be assessed by monitoring and analysing supplier due diligence responses, survey and audit results and completion rates for awareness and training modules",0,0,0,0,0,0,0,0,0,1,0 6272,49,Impacts Of COVID-19 COVID-19 has had a limited impact on OSWs ability to manage risks relating to modern slavery,0,0,0,0,0,0,1,0,0,0,0 6272,50,Travel restrictions locally and abroad have resulted in a reduction of physical audits of OSWs suppliers,0,0,0,0,0,0,1,0,0,0,0 6272,51,COVID-19 has negatively impacted OSW through freight delays and disrupted delivery schedules as a result of intermittent lockdowns across Australia,0,0,0,0,0,0,0,0,0,0,0 6272,52,"Consultation with our entities In order to prepare this Statement, OSW engaged with each of the reporting entities covered by this Statement and consulted the entities OSW owns or controls",0,0,0,0,0,0,0,0,0,0,1 6272,53,"This included engagement with a modern slavery working group, consisting of Hongwei Zhang and Chang Yu which was formed as part of OSWs commitment to help manage human rights and modern slavery risks across its operations and supply chains",0,0,0,0,0,0,0,0,0,0,0 6272,54,"Approval This statement has been developed by OSW, in consultation with each of its controlled entities, and was approved by the board of OSW on 02 December 2021",1,0,0,0,0,0,0,0,0,0,1 11201,69,The Sustainability Report can be found here,0,0,0,0,0,0,0,0,0,0,0 11201,70,Areas of risks,0,0,0,0,0,0,0,0,0,0,0 11201,71,"Using the Enterprise Risk Management Framework, Senex conducted an initial risk assessment of modern slavery in our operations and supply chain and continues to monitor the effectiveness of actions being taken to assess and address modern slavery risks",0,0,0,0,0,0,0,0,0,0,0 11201,72,"As previously identified, potential areas where there may be some risks for modern slavery are",0,0,0,0,0,0,1,0,0,0,0 11201,73,suppliers who may use products purchased or manufactured in high-risk countries; and,0,0,0,0,0,0,1,0,0,0,0 11201,74,products purchased which are made in high-risk countries,0,0,0,0,0,0,1,0,0,0,0 11201,75,"In 2020, Senex investigated the risk of modern slavery in relation to our business critical and higher risk direct suppliers, with no remediation actions required regarding modern slavery",0,0,0,0,0,0,1,0,0,0,0 11201,76,Senex continues to assess its direct suppliers regularly,0,0,0,0,0,0,0,0,0,0,0 890,76,Undertookstrategicprocurementofcleaningservices,0,0,0,0,0,1,0,1,0,0,0 890,77,Thisisthefirstofmanystrategicprocurementstodevelopapreferredsupplier panel,0,0,0,0,0,0,0,1,0,0,0 890,78,"Bylimitingthenumberofprovidersforcleaningservices,thelikelihoodofmodernslaveryinthissectorofthesupplychainis minimised",0,0,0,0,0,0,0,1,0,0,0 890,79,"Actionsmovingforward ThesearetheinitialproposedactionstobeformalisedandexpandedwiththedevelopmentoftheStrategy; establishamodernslaveryworkinggroupfromacrosstheorganisationtodevelopandimplementtheStrategy targetedtrainingforstaffwhoprocurefromatriskcategories reducethenumberofsuppliersthroughstrategicprocurementandtheuseofpreferredsupplierpanels ensureappropriateriskassessmentofsuppliers,includingdevelopingasupplierriskassessmenttool ensuresuppliersareappropriatelyvettedanddevelopappropriatetoolsforvetting: product/services,size,complexity,depthoftheirsupplychain,geographicallocation engagingwithcurrentsuppliers: initiallytargetthosewithsignificantexpenditure targetthosewithinhighriskcategoriesformodernslaveryhospitality,construction,domesticwork,foodservice reviewmemorandaofunderstandingandcontracts",0,0,0,0,0,0,0,1,0,0,0 890,80,"Measuringsuccess ToensuretheeffectiveimplementationoftheStrategy,andthatwefullyunderstandtherisksofmodernslaveryinouroperationsandsupply chain,metricshavebeendevelopedandwillbemonitored",0,0,0,0,0,0,0,0,0,0,0 890,81,"AstheStrategyevolves,newmetricsandmeasureswillbedevelopedtoensure effectiveandtargetedmonitoring",0,0,0,0,0,0,0,0,0,0,0 890,82,Initialmeasures Overallnumberofsuppliersusedtargettoreduce(byJune2022) Numberofstrategicprocurementactivitiesconducted(10identifiedforFY2021) Percentageofprocurementsutilisingtheformalprocurementframeworkandprocesstargetallprocurementevents 5.2,0,0,0,0,0,0,0,0,0,1,0 890,83,Potentialfuturemeasures CountofexistingcontractsandMOUsreviewedandrenegotiatedtoincludemodernslaveryobligations Numberofcontractscancelled Countofnegativefindingfromsuppliers Numberofsuppliermodernslaverystatementsprovided Numberofsupplierauditsconducted CountPositive/Negativefindings Numberofsuppliersinhighriskcategories,0,0,0,0,0,0,0,0,0,1,0 3708,96,"This helps to set consistent, industry-wide expectations",0,0,0,0,0,0,0,0,0,0,0 3708,97,The Adobe Group conducts these activities annually,0,0,0,0,0,0,0,1,0,0,0 3708,98,"Supplier Audits: The Adobe Group either conducts VAP audits or obtains audit reports through RBA's audit sharing system, for suppliers scoring ""high risk"" on the SAQ",0,0,0,0,0,0,0,1,0,0,0 3708,99,These audit reports are valid for two years,0,0,0,0,0,0,0,0,0,0,0 3708,100,The tools referenced above help the Adobe Group to decide which suppliers to audit by helping to identify risk levels for slave labour or human trafficking practices,0,0,0,0,0,0,0,0,0,0,0 3708,101,"The VAP assesses suppliers against the entire RBA Code, including: Labour, Health & Safety, Environment, Ethics, and Management Systems",0,0,0,0,0,0,0,0,0,0,0 3708,102,"It includes many different components, such as On-Site Inspections, Document Reviews, and Worker and Management Interviews",0,0,0,0,0,0,0,0,0,0,0 3708,103,"Certification: Pursuant to Section E of the RBA Code, Adobe utilises a management system that contains ""a process to communicate the Code requirements and to monitor supplier compliance to the Code."" This does not mean that suppliers submit certifications",0,0,0,0,0,0,0,1,0,0,0 6272,55,Hongwei Zhang Director One Stop Warehouse Pty Ltd,0,1,0,0,0,0,0,0,0,0,0 6676,0,MODERN SLAVERY STATEMENT 2021 THE HARRIS HMC GROUP,0,0,0,0,0,0,0,0,0,0,0 6676,1,Introduction 3 Our Company 4 Business Structure 4 Reporting Period 4 Business Structure Overview Diagram 5 Identifying and Taking Action 6 HT1s Operations 6 Suppliers 6 Supply Chain Risks 7 Trades and Subcontracting 7 Operational Procurement 7 Tier 1 Suppliers 8 Tier 2 Suppliers 9 Mitigation and Remediating Risks 10 CONTENTS 2 Modern Slavery Statement 2021,0,0,0,0,0,0,0,0,0,0,0 6676,2,Modern Slavery Statement 2021 INTRODUCTION The Harris HMC Group recognises and understands the importance of respecting and protecting the human rights of all people,0,0,0,0,0,0,0,0,0,0,0 6676,3,"As a prominent organisation within the Construction and Services Industry we are in a position where we can promote and enact positive change across our business, industry, and the communities in which we live, work and play",0,0,0,0,1,0,0,0,0,0,0 6676,4,"In our first year of reporting, this statement outlines our early progress in establishing and using a risk management framework and our initial steps to combat the risk of modern slavery in our operations and supply chains",0,0,0,0,0,0,0,0,0,0,0 6676,5,"Looking ahead, The Harris HMC Group commits to continuous improvement",0,0,0,0,0,0,0,0,0,0,0 6676,6,"We will continue to develop our Modern Slavery Framework, processes and conversations and will engage with our clients, employees and suppliers ensuring the growth of our business is done in a socially responsible way",0,0,0,0,0,0,0,0,0,0,0 11201,77,"For these reasons, Senex considers it has a low risk of modern slavery in its immediate supply chain (ie material suppliers are domiciled in low risk geographies and in low risk industries)",0,0,0,0,0,0,1,0,0,0,0 11201,78,"Prior to the planned expansions commencing in early 2023, Senex will be reviewing its modern slavery risks",0,0,0,0,0,0,0,1,0,0,0 11201,79,"In future years as our supply chain matures and the business grows, Senex will extend these investigations to additional direct suppliers and critical indirect suppliers and customers",0,0,0,0,0,0,0,1,0,0,0 11201,80,"Our approach To ensure efforts are focused appropriately in preparing for modern slavery reporting, it is important for Senex to develop a fit-for-purpose approach based on internal cross-functional collaboration and leveraging appropriate existing processes and frameworks where possible",0,0,0,0,0,0,0,0,0,0,0 11201,81,During the year Senex undertook the following measures to address risks in modern slavery,0,0,0,0,0,0,0,0,0,0,0 11201,82,"Modern slavery working group A group of relevant Senex specialists (Risk, Legal, Contracts and Procurement, Government and Stakeholder Relations) prepared this statement and, with support from Executives, undertook tasks as required to achieve our ambition statement",0,0,0,0,0,0,0,1,0,0,0 11201,83,Senex Energy Pty Ltd Modern Slavery Statement FY22,0,0,0,0,0,0,0,0,0,0,0 11201,84,Modern slavery ambition statement and road map,0,0,0,0,0,0,0,0,0,0,0 890,84,Consultation Wehaveundertakenbenchmarkingofpublishedmodernslaverystatementsfromsimilarorganisationsandliaisedwithseveralofourlarger supplierswhoarealsorequiredtosubmitModernSlaveryStatementstodiscusstheirapproach,0,0,0,0,0,0,0,0,0,0,0 890,85,"Thisconsultationandresearchhasprovided usefulinsightsontheapproachesofotherorganisations,andhasinformedourownapproachtoensureitisappropriateandeffectivelytailored toreflectourorganisationalcontext",0,0,0,0,0,0,0,0,0,0,0 890,86,"Movingforward,thedevelopmentoftheStrategywillinvolveaworkinggroupofrepresentativesofkeyareasoftheorganisationtoprovide insightandoversightondeliveryofthestrategy",0,0,0,0,0,0,0,0,0,0,0 890,87,Anyotherrelevantinformation Thedevelopmentofthe201920ModernSlaveryStatementhasbeencompiledincloseconsultationwiththeProcurementteam,0,0,0,0,0,0,0,0,0,0,0 890,88,"Asrequired, otherareasoftheorganisationhavebeenconsulted",0,0,0,0,0,0,0,0,0,0,0 890,89,TheapproachforapprovalofthisStatementhasinvolvedregularreviewswiththeChiefFinancialOfficerassponsoroftheStatementthroughout development,0,0,0,0,0,0,0,0,0,0,0 890,90,TheExecutiveTeamandAuditandRiskCommitteehavealsobeenconsultedontheapproach,0,0,0,0,0,0,0,0,0,0,0 890,91,Thefinaldraftwasapprovedby theBoardon24November2020,1,0,0,0,0,0,0,0,0,0,0 3708,104,Internal Accountability: The Adobe Group takes non-compliance with the,0,0,0,0,0,0,0,0,0,0,0 3708,105,______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 9,0,0,0,0,0,0,0,0,0,0,0 3708,106,RBA Code on slavery and trafficking seriously,0,0,0,0,0,0,0,0,0,0,0 3708,107,"The Adobe Group will investigate any alleged instances of non-conformance with the RBA Code, and will initiate corrective action plans in a timely manner, including appropriate disciplinary action, for any identified violations of this policy",0,0,0,0,0,0,0,0,1,0,0 3708,108,"Capacity-Building/Training: The Adobe Group encourages suppliers to utilise RBA's Learning Academy which contains online learning modules that cover the RBA Code of Conduct, as well as modules specifically related to the California Transparency in Supply Chains Act",0,0,0,0,0,0,0,1,0,0,0 3708,109,"In addition, there are modules on hiring and related topics that are particularly relevant to these issues",0,0,0,0,0,0,0,1,0,0,0 3708,110,Modules can be assigned to both internal staff and suppliers and learning can be tracked,0,0,0,0,0,0,0,1,0,0,0 3708,111,The RBA Code is a fundamental part of the Adobe Groups efforts to help mitigate the risk of slavery and human trafficking taking place in its supply chains and business,0,0,0,0,0,0,0,0,0,0,0 6676,7,This statement has been prepared by HT1 Pty Ltd (The Harris HMC Group) and developed in accordance with the requirements of the Australian Modern Slavery Act 2018 (Cth) (the Act),0,0,1,0,0,0,0,0,0,0,0 6676,8,"It details how The Harris HMC Group has commenced identifying, assessing, and addressing modern slavery risks in our supply chain and operations during the year ending 30 June 2021",0,0,0,0,0,0,0,0,0,0,0 6676,9,"The Harris HMC Group recognises the importance of protecting human rights of all people, including our employees, customers, communities and those within our supply chain",0,0,0,0,0,0,0,0,0,0,0 6676,10,This is our first Statement in accordance to the Act,0,0,0,0,0,0,0,0,0,0,0 6676,11,We are in the early stages of engagement with subcontractors and suppliers to provide initial clarity around their operations,0,0,0,0,0,0,0,0,0,0,0 6676,12,"In the 2022 financial year, we intend to increase our engagement with additional suppliers and subcontractors",0,0,0,0,0,0,0,0,0,1,0 6676,13,"At the date of this statement, The Harris HMC Group had not identified any instances of modern slavery in our operations or supply chain",0,0,0,0,0,0,1,0,0,0,0 6676,14,This Modern Slavery Statement is approved by The Harris HMC Group Board of Directors on 15th December 2021,1,0,0,0,0,0,0,0,0,0,0 11201,85,Senex is committed to transparent governance and management to address the risks of modern slavery in our operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 11201,86,"Senex has to the extent practicable, continued with its modern slavery roadmap, and ambition statement",0,0,0,0,0,0,0,0,0,0,0 11201,87,"Due to reduced activities during FY22, there has been less opportunity to make significant progress against the road map",0,0,0,0,0,0,0,0,0,0,0 11201,88,"As activities ramp up in 2023, Senex proposes to increase resources to progress its modern slavery road map",0,0,0,0,0,0,0,0,0,0,0 11201,89,Our road map for this reporting period included,0,0,0,0,0,0,0,1,0,0,0 11201,90,conducting training to educate key staff (Legal and Contracts and Procurement) and suppliers and provide tools for staff to better identify examples of modern slavery,0,0,0,0,0,0,0,1,0,0,0 11201,91,encouraging staff to raise any concerns that an activity may be at risk of involving modern slavery (in line with Senexs Code of Conduct and Whistleblower Policy),0,0,0,0,0,0,0,1,0,0,0 11201,92,continually reviewing Senex policies and procedures and ensuring risk management of modern slavery is appropriately covered (in line with our governance standards),0,0,0,0,0,0,0,0,0,1,0 890,92,______________________________ TheMostReverendDrPhilipLFreier BoardChair Date:22/12/2020,0,1,0,0,0,0,0,0,0,0,0 949,0,"ITOCHU Australia Modern Slavery and Human Trafficking Statement 2020 This is a modern slavery statement, issued pursuant to the Australian Modern Slavery Act 2018 (Cth), by ITOCHU Australia Ltd ABN 63 000 192 790 (IAL), ITOCHU Minerals & Energy of Australia Pty Ltd ABN 44 009 256 259 (IMEA), ICRA OC Pty Ltd ABN 41 106 260 593 (ICRA OC), ICRA Cumnock Pty Ltd ABN 82 129 006 819 (ICRA Cumnock), ICRA MC Pty Ltd ABN 77 147 657 074 (ICRA MC), IM Iron Holding Pty Ltd ABN 35 168 776 421 (IMIH) and ITOCHU Iron Ore Australia Pty Ltd ABN 49 134 669 408 (IIOA) for the Financial Year ending 31 March 2020",0,0,0,0,0,0,0,0,0,0,0 949,1,"IAL, IMEA, ICRA OC, ICRA Cumnock, ICRA MC, IMIH and IIOA (collectively ITOCHU Australia) are each reporting entities and this statement includes the supply chains of the entities owned or controlled by ITOCHU Australia",0,0,1,0,0,0,0,0,0,0,0 949,2,"ITOCHU Australias structure, operations and supply chain IAL is a 100%-owned subsidiary of ITOCHU Corporation (ITC) in Japan, which is one of the leading general trading companies, or so-called sogo shosha",0,0,0,1,1,0,0,0,0,0,0 949,3,IAL operates as a trader of general commodities and holds some minority investments,0,0,0,0,1,0,0,0,0,0,0 949,4,"The company is involved in the trading of primary and natural commodities and divides its operations into divisions which include coal, metals & mineral resources, machinery, general merchandise, chemicals and foods",0,0,0,0,1,0,0,0,0,0,0 949,5,"As part of its trading operations IAL procures goods in these sectors from Australia and Asia, primarily through the ITC group",0,0,0,0,0,1,0,0,0,0,0 949,6,"IMEA is owned by ITC and IAL and owns a number of subsidiaries including ICRA OC, ICRA Cumnock, ICRA MC, IMIH and IIOA",0,0,0,1,0,0,0,0,0,0,0 3708,112,"This disclosure includes the efforts the Adobe Group has taken in its own business, as well as with its suppliers, to oppose the use of slavery and human trafficking in its supply chains",0,0,0,0,0,0,0,0,0,0,0 3708,113,Each Adobe Group Entity requires all of its employees to complete a Code of Business Conduct training every two years,0,0,0,0,0,0,0,1,0,0,0 3708,114,"As part of this training, employees provide a written acknowledgement that they have read the Code and that they understand and will comply with the Code",0,0,0,0,0,0,0,1,0,0,0 3708,115,Each Adobe Group Entity enrolls all of its employees in this training,0,0,0,0,0,0,0,1,0,0,0 3708,116,The Adobe Group liaises regularly with its direct supplier and conducts monthly visits to review the production area and the area where products are scrapped,0,0,0,0,0,0,0,0,0,1,0 3708,117,"While these visits are principally to check manufacturing and recycling practices, they are carried out by Adobe Group employees who have been trained in the Labour Standards and are expected to report anything which appears to contravene the Adobe Groups standards",0,0,0,0,0,0,0,0,0,1,0 3708,118,Supplier Due Diligence Screening process,0,0,0,0,0,0,0,0,0,0,0 3708,119,The Adobe Group maintains company policies and procedures to guide its actions and establish operating controls to minimise risk exposure for the corporate group,0,0,0,0,0,0,0,1,0,0,0 6676,15,Dale Kennedy Managing Director,0,1,0,0,0,0,0,0,0,0,0 6676,16,"OUR COMPANY Business Structure This statement is for HT1 Pty Ltd and its related entities Harris HMC Interiors Pty Ltd, Harris HMC Interiors (VIC) Pty Ltd, Harris HMC Construction Pty Ltd, HDP (VIC) Pty Ltd, HMC Div 6 Pty Ltd, UBOS Australia Pty Ltd",0,0,0,1,0,0,0,0,0,0,0 6676,17,"An integrated construction group, spanning a breadth of industry sectors each similar supply chains: Construction solutions across education, commercial, residential, government, health, aged care and industrial sectors",0,0,0,0,1,0,0,0,0,0,0 6676,18,"Fit-out and refurbishment projects for Education, Government, Health and Commercial clients",0,0,0,0,1,0,0,0,0,0,0 6676,19,"Programmed and reactive commercial maintenance services to local councils, public companies and public spaces",0,0,0,0,1,0,0,0,0,0,0 6676,20,Programmed and reactive electrical services across Melbourne,0,0,0,0,1,0,0,0,0,0,0 6676,21,"The Harris HMC Group business address is 52 Henderson Street, North Melbourne, VIC 3051",0,0,0,1,0,0,0,0,0,0,0 6676,22,"We employ 246 staff under permanent, fixed term, part time and casual contracts, or under enterprise agreements",0,0,0,1,0,0,0,0,0,0,0 11201,93,"Training In order to respond to the risks of modern slavery, Senex promotes activities to raise awareness and educate its employees",0,0,0,0,0,0,0,1,0,0,0 11201,94,Training to educate key staff (Legal and Contracts and Procurement) was limited during the reporting period to those directly involved in procurement and contractual supply arrangements,0,0,0,0,0,0,0,1,0,0,0 11201,95,This was due to the reduced level of procurement during the year,0,0,0,0,0,0,0,0,0,0,0 11201,96,Supply Chain Management Senex continued to build and rely on its newly established centralised digital repository of contracts and agreements,0,0,0,0,0,0,0,1,0,0,0 11201,97,"Used alongside the new Stakeholder Management System, this repository facilitates better management of information and enables a higher level of strategic engagement with our suppliers",0,0,0,0,0,0,0,1,0,0,0 11201,98,Senex Energy Pty Ltd Modern Slavery Statement FY22,0,0,0,0,0,0,0,0,0,0,0 11201,99,"Review of template agreements To ensure we meet our obligations under the Act, further review of Senexs template agreements for the supply of goods and services was undertaken",0,0,0,0,0,0,0,0,0,1,0 11201,100,These agreements now include provisions addressing modern slavery and request of information from suppliers,0,0,0,0,0,0,0,1,0,0,0 949,7,"IMEA is a minority owner of major iron ore joint ventures in the Pilbara region and also has minority coal joint venture interests in New South Wales, Queensland and Indonesia",0,0,0,0,1,0,0,0,0,0,0 949,8,"IMEA is in joint ventures with major international mining entities, including BHP and Glencore",0,0,0,0,1,0,0,0,0,0,0 949,9,"These major mining entities have sophisticated procurement policies, including to address modern slavery risks",0,0,0,0,0,0,0,0,0,0,0 949,10,Other entities owned and controlled by ITC have operations in Australia but are not owned or controlled by ITOCHU Australia and are not included in this statement,0,0,0,1,0,0,0,0,0,0,0 949,11,"In addition to ITOCHU Australia's investment and trading activities, ITOCHU Australia has offices in Sydney, Brisbane and Perth and procures office space and associated services, IT hardware and software and consumables",0,0,0,0,1,0,0,0,0,0,0 949,12,"Risks of modern slavery practices, actions taken and assessment of effectiveness As set out above, ITOCHU Australia's operations primarily involve non-managed joint venture interests, and ITOCHU Australia is not in a position to control or change the supply chains for those investments",0,0,0,0,1,0,0,0,0,0,0 949,13,"ITOCHU Australia's trading arrangements are primarily with ITC entities, who are in compliance with ITC group policies on human rights, modern slavery and human trafficking, as set out below",0,0,0,0,0,1,0,1,0,0,0 949,14,ITOCHU Australia's trading arrangements include agricultural products from Australia and fish products from Asia,0,0,0,0,0,1,0,0,0,0,0 3708,120,"The supplier due diligence procedure sets out the process for onboarding new suppliers and contains the actions required before Adobe Group Entities can do business with any supplier, to ensure",0,0,0,0,0,0,0,1,0,0,0 3708,121,______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 10,0,0,0,0,0,0,0,0,0,0,0 3708,122,that the Adobe Group has reviewed any identified risks in the relationship or services and the relevant Adobe Group Entities have taken the appropriate measures to address those risks,0,0,0,0,0,0,0,1,0,0,0 3708,123,"Adobes Vendor Risk Management Office (VRMO) is responsible for managing this program and collabourates with Adobes Ethics & Compliance Office, which conducts due diligence activities on suppliers using a risk-based approach",0,0,0,0,0,0,0,1,0,0,0 3708,124,"The program incorporates, among other requirements, supplier screening and re-screening risk assessments to understand the qualifications and associations of the Adobe Groups suppliers",0,0,0,0,0,0,0,1,0,0,0 3708,125,"As part of the Adobe Groups supplier onboarding process, suppliers are asked to: complete a Compliance questionnaire and a formal declaration as well as provide required documentation via Adobes Vendor Information Management Portal; acknowledge abidance by the Adobe Business Partner Code of Conduct, which requires that they comply fully with key principles such as observing and complying with local and international laws and regulations relating to anti-corruption and anti-bribery as well as human rights, and requirements on the use and disclosure of any personal information in delivery of services; and disclose any known conflict of interest",0,0,0,0,0,0,0,1,0,0,0 3708,126,"The Adobe supplier ethics and compliance review additionally requires suppliers to certify key information regarding their enterprise/business, compliance practices, and policies",0,0,0,0,0,0,0,1,0,0,0 3708,127,The Adobe Compliance Office may conduct enhanced due diligence based on the declarations provided by the suppliers or other information related to the suppliers,0,0,0,0,0,0,0,1,0,0,0 6676,23,"All items outlined within this Statement are applicable across all entities; from the initial risk- scoping exercise conducted with the assistance of external partners, to the Supply Chain Assessment and subsequent risk-reduction policies and procedures",0,0,0,0,0,0,0,0,0,0,0 6676,24,Reporting Period The Harris HMC Group operated on the 2020/2021 financial year reporting period in accordance with the Act,0,0,0,0,0,0,0,0,0,0,0 6676,25,Modern Slavery Statement 2021,0,0,0,0,0,0,0,0,0,0,0 6676,26,"BUSINESS STRUCTURE OVERVIEW DIAGRAM Figure 1 (above): The Harris HMC Groupss business structure, as relevant to this Modern Slavery Statement",0,0,0,0,0,0,0,0,0,0,0 6676,27,"With the relevant functions shared between them, this Statement covers Harris HMC Interiors Pty Ltd, Harris HMC Interiors (VIC) Pty Ltd, Harris HMC Construction Pty Ltd, HDP (VIC) Pty Ltd, HMC Div 6 Pty Ltd, UBOS Australia Pty Ltd",0,0,0,1,0,0,0,0,0,0,0 6676,28,Entity ACN ABN HT1 Pty Ltd (100% Shareholder) 644 551 100 83 644 551 100 HMC Div 6 Pty Ltd 644 550 890 16 644 550 890 Harris HMC Interiors (VIC) Pty Ltd 130 177 614 77 130 177 614 Harris HMC Interiors Pty Ltd 006 262 979 56 006 262 979 Harris HMC Construction Pty Ltd 119 426 952 79 119 426 952 HDP (VIC) Pty Ltd 614 032 530 41 614 032 530 UBOS Australia Pty Ltd 136 370 440 74 136 370 440 HT1 Pty Ltd (100% Shareholder) HMC Div 6 Pty Ltd Harris HMC Interiors (VIC) Pty Ltd Harris HMC Interiors Pty Ltd Harris HMC Construction Pty Ltd HDP (VIC) Pty Ltd UBOS Australia Pty Ltd 5 Modern Slavery Statement 2021,0,0,0,1,0,0,0,0,0,0,0 6676,29,IDENTIFYING AND TAKING ACTION TO ADDRESS MODERN SLAVERY RISKS HT1s Operations The Harris HMC Group considers that we have a low risk of modern slavery in the employment of our employees given the entirety of our direct workforce is located in Australia and has one of the lowest modern slavery estimated prevalence scores globally1,0,0,0,0,0,0,1,0,0,0,0 6676,30,Suppliers The Harris HMC Group considers the risk of exposure to modern slavery practices in our supply chain is greater than in our own operations,0,0,0,0,0,0,1,0,0,0,0 11201,101,"External legal counsel reviewed and updated the Request for Proposal document to further refine the assessment of social responsibility and sustainability issues, including modern slavery",0,0,0,0,0,0,0,0,0,1,0 11201,102,"Independent whistleblower service Senex is committed to a supportive workplace environment and employees and stakeholders are encouraged to raise concerns regarding conduct occurring at, or in relation to Senex",0,0,0,0,0,0,0,1,0,0,0 11201,103,"We continue to promote our independent, confidential external whistleblower service, where our contractors and suppliers can freely raise concerns",0,0,0,0,0,0,0,1,0,0,0 11201,104,"Information on the whistleblower service is provided on our website, and in our Whistleblower Policy",0,0,0,0,0,0,0,1,0,0,0 11201,105,"In 2022, there were no reports of modern slavery related misconduct",0,0,0,0,0,0,0,0,0,1,0 11201,106,"COVID-19 impact During 2022, we remained focused on the safety and wellbeing of our employees, contractors, and communities",0,0,0,0,0,0,0,0,0,0,0 11201,107,We continued our stringent protocols and effective business continuity measures ensured Senex could continue to operate safely and effectively,0,0,0,0,0,0,0,0,0,0,0 11201,108,"As restrictions began to ease, there was a gradual increase in travel and activity on site, resulting in increased spending with suppliers",0,0,0,0,0,0,0,0,0,0,0 949,15,"Fish products from Asia have a potential for modern slavery risk, and ITOCHU Australia manages this risk in part through its selection of international global groups that it requests",0,0,0,0,0,0,1,1,0,0,0 949,16,to comply with ITC policies (including in relation to modern slavery),0,0,0,0,0,0,0,1,0,0,0 949,17,"ITC's policies, and ITOCHU Australia's actions, are described below",0,0,0,0,0,0,0,0,0,0,0 949,18,ITOCHU Australia regularly requests its employees to visit the premises of major suppliers and customers,0,0,0,0,0,0,0,1,0,0,0 949,19,During these visits employees are asked to physically identify and report any evidence which might identify modern slavery in a suppliers or customers supply chain,0,0,0,0,0,0,0,1,0,0,0 949,20,Our Policy on Modern Slavery and Human Trafficking ITOCHU Australia is committed to limiting the risk of modern slavery occurring within its own business and its supply chains,0,0,0,0,0,0,0,0,0,0,0 949,21,ITC participates in the United Nations Global Compact and applies the concepts of the United Nations Guiding Principles on Business and Human Rights and such concepts flow down to ITOCHU Australia,0,0,0,0,0,0,0,1,0,0,0 949,22,ITOCHU Australias existing policies contain provisions have the goal of seeking to ensure that there is no slavery or human trafficking in any part of its business or supply chain,0,0,0,0,0,0,0,1,0,0,0 3708,128,Suppliers are re-screened periodically based on their initial risk rating and are required to provide an updated Compliance questionnaire and a company declaration to the Adobe Group,0,0,0,0,0,0,0,1,0,0,0 3708,129,Supplier Contracting,0,0,0,0,0,0,0,0,0,0,0 3708,130,"The Adobe Group includes specific language in its third party contracts requiring suppliers to comply with its Business Partner Code of Conduct, which states Adobe Groups requirements of its suppliers with regards to local and international laws and regulations relating to anti- corruption and anti-bribery, wages, hours and conditions of employment, discrimination and occupational health/safety",0,0,0,0,0,0,0,1,0,0,0 3708,131,"Contractual terms with suppliers also require that the suppliers do not utilise child, slave, prisoner or any other form of forced, bonded or involuntary labour, or engage in abusive employment or corrupt business practices, in the supply of goods or provision of services",0,0,0,0,0,0,0,1,0,0,0 3708,132,______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 11,0,0,0,0,0,0,0,0,0,0,0 3708,133,"Governance Programs, Policies and Codes",0,0,0,0,0,0,0,0,0,0,0 3708,134,"In order to support compliance and address modern slavery risks throughout its business, the Adobe Group has in place the following governance programs, policies and codes within its ecosystem",0,0,0,0,0,0,0,0,0,0,0 3708,135,INITIATIVE/PROGRAM ACTIONS Adobe Code of Business Conduct,0,0,0,0,0,0,0,0,0,0,0 6676,31,The activities that we have undertaken to date seek to obtain a greater understanding of these potential exposures,0,0,0,0,0,0,0,0,0,0,0 6676,32,"In 2021, The Harris HMC Group completed an initial modern slavery assessment of 15 directly engaged suppliers, ranking them by spend2",0,0,0,0,0,0,0,1,0,0,0 6676,33,"These priority subcontractors and suppliers were then invited to participate in the iPro Modern Slavery Assessment, enabling The Harris HMC Group to collect additional information on their approach to managing modern slavery risk",0,0,0,0,0,0,0,1,0,0,0 6676,34,The total number of suppliers that participated in the modern slavery declaration was 86.7% - 13 out of 15,0,0,0,0,0,0,0,0,0,1,0 6676,35,The 13 suppliers that completed the declaration have been evaluated as per the following risk score categorisation,0,0,0,0,0,0,0,0,0,0,0 6676,36,Risk Level Low Risk (no perceived inherent risk) Low Risk (adequate risk control) Medium Risk High Risk Suppliers 1 (7.7%) 2 (15.4%) 3 (23.1%) 4 (53.8%) 6 Modern Slavery Statement 2021,0,0,0,0,0,0,1,0,0,0,0 6676,37,"Walk Free Foundation, Global Slavery Index 2018",0,0,0,0,0,0,0,0,0,0,0 6676,38,The Harris HMC Group recognises that value of spend does not necessarily correlate with modern slavery risk,0,0,0,0,0,0,0,0,0,0,0 11201,109,Effectiveness,0,0,0,0,0,0,0,0,0,0,0 11201,110,"We will use the existing Senex Enterprise Risk Management framework to manage modern slavery risk, including identifying, assessing, addressing, and monitoring effectiveness of risk management",0,0,0,0,0,0,0,0,0,0,0 11201,111,This Statement is approved by the Board of Senex Energy Pty Ltd in their capacity as the principal governing body of Senex on 22 November 2022,1,0,0,0,0,0,0,0,0,0,0 11201,112,Jhoon Soo Jho Chair Senex Energy Pty Ltd,0,1,0,0,0,0,0,0,0,0,0 11377,0,A u s t r a l a s i a s l a r g e s t i n s u r a n c e l a w f i r m Modern Slavery Statement FY22 1 JULY 2021 30 JUNE 2022,0,0,0,0,0,0,0,0,0,0,0 11377,1,"Modern Slavery Statement (FY22) MODERN SLAVERY STATEMENT This statement outlines: SECTION 1: Introduction This statement is made pursuant to the Modern Slavey Act 2018 (Cth) by Wotton & Kearney Holdings Ltd (ABN 60 632 647 306) on behalf of itself and its two wholly owned subsidiaries, Wotton + Kearney Pty Ltd (ABN 94 632 932 131) and Pinsani Pty Limited (ABN 84 099 079 802), which operate as part of the Wotton + Kearney group",0,0,0,1,0,0,0,0,0,0,0 11377,2,"The statement sets out the actions taken by the Wotton + Kearney group (Wotton + Kearney) to address modern slavery risks in our supply chains and operations for the financial year ending 30 June 2022, and will be reviewed and updated annually",0,0,0,0,0,0,0,0,0,0,0 11377,3,"This is Wotton + Kearneys first Modern Slavery Statement, pursuant to our obligations under section 13 of the Modern Slavery Act 2018 (Cth)",0,0,0,0,0,0,0,0,0,0,0 949,23,ITOCHU Australia incorporate policies from ITC,0,0,0,0,0,0,0,1,0,0,0 949,24,Such policies include,0,0,0,0,0,0,0,1,0,0,0 949,25,ITOCHU groups Corporate Philosophy and Code of Conduct (https://www.itochu.co.jp/en/about/mission/),0,0,0,0,0,0,0,0,0,0,0 949,26,Human Rights Policy of the ITOCHU Group (https://www.itochu.co.jp/en/csr/society/human_rights/),0,0,0,0,0,0,0,0,0,0,0 949,27,Individual Policy related to Human Rights (https://www.itochu.co.jp/en/csr/society/human_rights/#h2_03),0,0,0,0,0,0,0,0,0,0,0 949,28,Human Rights Due Diligence (https://www.itochu.co.jp/en/csr/society/human_rights/#h2_04),0,0,0,0,0,0,0,0,0,0,0 949,29,The United Nations Global Compact (https://www.itochu.co.jp/en/csr/itochu/activity/global_compact/index.html),0,0,0,0,0,0,0,0,0,0,0 949,30,Sustainability Action Guidelines for Supply Chains (https://www.itochu.co.jp/en/csr/society/value_chain/policy/#h2_01),0,0,0,0,0,0,0,0,0,0,0 3708,136,Adobes Code of Business Conduct describes the Adobe Group's commitment to integrity as a fundamental part of the Adobe Groups culture and how we do business,0,0,0,0,0,0,0,0,0,0,0 3708,137,"The Code of Business Conduct is based on the groups Core Values: Innovative, involved, Exception and Genuine; the latter value includes integrity, respect, honesty, quality, responsibility and fairness",0,0,0,0,0,0,0,0,0,0,0 3708,138,"The Adobe Groups commitment to being fair and honest is how we maintain trust and credibility with our employees, customers, business partners, stockholders, and communities where we operate",0,0,0,0,0,0,0,0,0,0,0 3708,139,The Adobe Groups personnel are trained at regular intervals on the principles embodied within the Adobe Code of Business Conduct and other relevant internal policies,0,0,0,0,0,0,0,1,0,0,0 3708,140,The Adobe Group employees are held accountable for their actions and are subject to disciplinary action for failing to adhere to the Adobe Groups policies and procedures,0,0,0,0,0,0,0,1,0,0,0 3708,141,"The Adobe Group also maintains company-wide accountability and grievance mechanisms (such as Adobes Business Ethics Hotline), which are available to both employees and external business partners, customers and suppliers to raise any concerns regarding unethical or illegal conduct, including where they relate to modern slavery and human trafficking",0,0,0,0,0,0,0,1,0,0,0 3708,142,"Adobe Business Partner Code of Conduct The Business Partner Code of Conduct sets out the Adobe Groups expectations for our business partners, suppliers, vendors, contractors, consultants and all other providers of goods and services to conduct business responsibly, with integrity, honesty and transparency and to comply fully with key principles, including respect for human rights and ensuring they observe and comply with local and international principles and laws relating to human rights",0,0,0,0,0,0,0,1,0,0,0 3708,143,The Adobe Group requires all business partners and suppliers to agree to our Business Partner Code of Conduct or have an,0,0,0,0,0,0,0,1,0,0,0 6676,39,"However, we nonetheless consider value of spend to be a useful preliminary reference point to prioritise our risk assessment efforts as it allows us to identify procurement activities and relationships where we may be able to exert the greatest influence",0,0,0,0,0,0,0,0,0,0,0 6676,40,"Supply Chain Risks The Harris HMC Group acknowledges we have identified the following aspects of our supply chain and associated risks: Trades and subcontracting Operational procurement Imported construction materials Trades and Subcontracting The Harris HMC Group engage specialist trades for works including structural, electrical and plumbing",0,0,0,0,0,1,1,0,0,0,0 6676,41,"The Harris HMC Group engage approximately 765 subcontractor businesses at any time, with approximately 1550 contracts let in the year ending 30 June 2021",0,0,0,0,0,1,0,0,0,0,0 6676,42,% of these subcontractors and suppliers are located within Australia,0,0,0,0,0,1,0,0,0,0,0 6676,43,"We acknowledge that we recruit through an agency or labour hire company, which increases the risk factor as we are not directly involved through this process",0,0,0,0,0,0,1,0,0,0,0 6676,44,Operational Procurement Additional to subcontractor and/or supplier procurement we source a varied range of goods and services including: Construction materials Plant and equipment hire Professional engineering services Workforce labour hire Business and services and products including cleaning 7 Modern Slavery Statement 2021,0,0,0,0,0,1,0,0,0,0,0 6676,45,"TIER 1 SUPPLIERS COUNTRIES OF OPERATION Imported Construction Materials Many of our construction materials are imported, sourced, processed and assembled offshore and may involve multiple countries, which may increase the risk of modern slavery",0,0,0,0,0,1,1,0,0,0,0 6676,46,We continue to work with our suppliers for greater transparency around modern slavery issues,0,0,0,0,0,1,0,0,0,0,0 11377,4,We have chosen to make a voluntary statement and to take action to address modern slavery risks in our supply chains and operations,0,0,0,0,0,0,0,0,0,0,0 11377,5,"SECTION 1: Introduction SECTION 2: Structure, Operations and Supply Chain SECTION 3: Modern Slavery Risks in Wotton + Kearneys Operations and Supply Chain SECTION 4: Actions to Assess and Address Modern Slavery Risks SECTION 5: Measuring the Effectiveness of our ongoing Modern Slavery Response",0,0,0,0,0,0,0,0,0,0,0 11377,6,MODERN SLAVERY STATEMENT What is Modern Slavery? Wotton + Kearney is committed to respecting human rights and addressing modern slavery,0,0,0,0,0,0,0,0,0,0,0 11377,7,"In 2018 and 2019, Wotton + Kearney partnered with International Justice Mission, the largest anti-slavery organisation in the world, to raise awareness about modern slavery amongst our staff, clients, and broader network",0,0,0,0,0,0,0,1,0,0,0 11377,8,The partnership educated us about the scale of modern slavery there are more than 50 million slaves globally today and the importance of a business response,0,0,0,0,0,0,0,0,0,0,0 11377,9,Modern slavery is a broad concept relating to systematic abuse of fundamental human rights in contemporary workforces,0,0,0,0,0,0,0,0,0,0,0 11377,10,"It is generally accepted as encompassing eight types of serious exploitation namely: trafficking in persons, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruiting for labour or service and the worst forms of child labour",0,0,0,0,0,0,0,0,0,0,0 11377,11,Modern slavery breaches the most fundamental freedoms and human rights of individuals,0,0,0,0,0,0,0,0,0,0,0 949,31,Internal Information Reporting System (Hotlines) (https://www.itochu.co.jp/en/about/governance_compliance/compliance/) ITOCHU Australia recognises these policies and engages in business in accordance with the principles under these polices,0,0,0,0,0,0,0,1,0,0,0 949,32,"Development of the Policy and Guideline In Financial Year 2020, ITOCHU Australia has included an anti-slavery policy within its own compliance manual, stating its commitment to limit the risk of modern slavery occurring within its own business",0,0,0,0,0,0,0,1,0,0,0 949,33,"ITOCHU Australia expects all who have, or seek to have, a business relationships with the company to familiarise themselves with ITOCHU Australias anti-slavery policy and to act in a way that is consistent with its values",0,0,0,0,0,0,0,1,0,0,0 949,34,ITOCHU Australia will conduct further risk assessments to determine which parts of the business and which supply chains are most at risk from modern slavery so efforts can be focused on the areas that are most at risk,0,0,0,0,0,0,0,1,0,0,0 949,35,"ITOCHU Australia will only do business with organisations who fully comply with its anti-slavery policy, or those who are taking verifiable steps towards compliance",0,0,0,0,0,0,0,1,0,0,0 949,36,"Training ITOCHU Australia works to spread understanding of the relationship between activities and human rights through in-house training programs for organisational heads, individuals assigned overseas, and all employees based in Australia",0,0,0,0,0,0,0,1,0,0,0 949,37,ITOCHU Australia also continues to provide training to raise awareness and educate its employees in addressing the risk of modern slavery and human trafficking of any form,0,0,0,0,0,0,0,1,0,0,0 949,38,Further Steps ITOCHU Australia intend to take the following steps,0,0,0,0,0,0,0,1,0,0,0 3708,144,______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 12,0,0,0,0,0,0,0,0,0,0,0 3708,145,INITIATIVE/PROGRAM ACTIONS equivalent policy,0,0,0,0,0,0,0,1,0,0,0 3708,146,"Under the Adobe Partner General Terms, our business partners and suppliers must comply with the principles in the Adobe Business Partner Code of Conduct",0,0,0,0,0,0,0,1,0,0,0 3708,147,Adobe Partner Ethics & Compliance Reviews,0,0,0,0,0,0,0,0,0,0,0 3708,148,"The Adobe Groups business partners are required to submit themselves to risk assessments and due diligence, and many are required to take compliance training",0,0,0,0,0,0,0,1,0,0,0 3708,149,"In addition, business partners must agree to the principles embodied within the Adobe Business Partner Code of Conduct (Business Partner Code of Conduct)",0,0,0,0,0,0,0,1,0,0,0 3708,150,The Business Partner Code of Conduct discourages unethical labour practices including the use of forced or involuntary labour of any kind,0,0,0,0,0,0,0,1,0,0,0 3708,151,Adobe Supplier Ethics & Compliance Reviews The Adobe Groups Vendor Risk Management Office (VRMO) and Ethics & Compliance Office have in place a Supplier Ethics & Compliance review process to identify and assess supplier risks,0,0,0,0,0,0,0,1,0,0,0 6676,47,Noting that we are currently focused on assisting our Tier 1 supply chain with the understanding and transparency where we are of highest influence,0,0,0,0,0,1,0,0,0,0,0 6676,48,Country Australia New Zealand Hong Kong Suppliers 14 2 1 Tier 1 in the supply chain represents suppliers with whom we have a direct relationship,0,0,0,0,0,1,0,0,0,0,0 6676,49,Modern Slavery Statement 2021,0,0,0,0,0,0,0,0,0,0,0 6676,50,TIER 2 SUPPLIERS COUNTRIES OF OPERATION Country Australia China New Zealand Brazil Canada Chile Indonesia Israel Italy South Korea Spain United Arab Emirates United Kingdom of Great Britain and Northern Ireland Vietnam Suppliers 10 3 2 1 1 1 1 1 1 1 1 1 1 1 Tier 2 represents suppliers of our Tier 1 suppliers,0,0,0,0,0,1,0,0,0,0,0 6676,51,Modern Slavery Statement 2021,0,0,0,0,0,0,0,0,0,0,0 6676,52,"MITIGATION AND REMEDIATING RISKS ASSOCIATED WITH MODERN SLAVERY Committed to continuous improvement, The Harris HMC Groups modern slavery path will consist of the following planned actions that will be reported against in subsequent statements: Assess and implement a purpose driven online modern slavery training module with specific emphasis on the construction industry",0,0,0,0,0,0,0,1,0,0,0 6676,53,Provide periodic modern slavery awareness training for The Harris HMC Group employees,0,0,0,0,0,0,0,1,0,0,0 6676,54,"Review, update and implement Modern Slavery Policy and draft associated policies likely to incorporate Supplier Code of Conduct, Procurement Policy and Human Rights Policy",0,0,0,0,0,0,0,1,0,1,0 11377,12,Wotton + Kearney rejects all forms of modern slavery and recognises that modern slavery is never acceptable in any of its forms,0,0,0,0,0,0,0,0,0,0,0 11377,13,Wotton + Kearney has resolved to voluntarily report under the Modern Slavery Act 2018 (Cth) and to take action to address modern slavery risks in our supply chains and operations,0,0,0,0,0,0,0,0,0,0,0 11377,14,"SECTION 2: Structure, Operations and Supply Chain Founded in 2002, Wotton + Kearney has grown from two partners to be one of Australasias undisputed leaders in the provision of legal services to the insurance industry with more than 450 staff across offices in Adelaide, Brisbane, Canberra, Melbourne, Perth and Sydney in Australia",0,0,0,1,1,0,0,0,0,0,0 11377,15,"For more information about our services, please click here",0,0,0,0,0,0,0,0,0,0,0 11377,16,"Under the Modern Slavery Act 2018 (Cth), Wotton & Kearney Holdings Ltd (ABN 60 632 647 306) is a reporting entity pursuant to section 5(1)",0,0,1,0,0,0,0,0,0,0,0 11377,17,"Wotton & Kearney Holdings Ltd is an unlisted public company limited by shares, incorporated and domiciled in Australia",0,0,0,1,0,0,0,0,0,0,0 11377,18,Wotton + Kearney Pty Ltd (ABN 94 632 932 131) is an incorporated legal practice registered in Australia,0,0,0,1,0,0,0,0,0,0,0 11377,19,Pinsani Pty Ltd (ABN 84 099 079 802) is a limited company registered in Australia,0,0,0,1,0,0,0,0,0,0,0 949,39,To continue to develop in-house training programs for all employees to educate and raise awareness,0,0,0,0,0,0,0,1,0,0,0 949,40,- To continue to improve reporting mechanism systems to aid people in noticing red flags or concerns about any sort of action or behaviours that reflect modern slavery and human trafficking,0,0,0,0,0,0,0,1,0,0,0 949,41,- Having provisions for contracted suppliers to hold their own suppliers to the same standards,0,0,0,0,0,0,0,1,0,0,0 949,42,- Reserve the right to terminate any contractual arrangement if there is breach of this policy,0,0,0,0,0,0,0,0,1,0,0 949,43,ITOCHU Australia has consulted with each of its subsidiaries about this policy,0,0,0,0,0,0,0,0,0,0,1 949,44,"This statement is approved by the Boards of ITOCHU Australia, and signed by an authorised director",1,1,0,0,0,0,0,0,0,0,0 949,45,"Daisuke Inoue Managing Director and CEO 24th December, 2020",0,1,0,0,0,0,0,0,0,0,0 991,0,Modern Slavery Statement 2020,0,0,0,0,0,0,0,0,0,0,0 3708,152,"The process incorporates supplier screening and risk assessments to understand the qualifications and associations of the Adobe Groups suppliers, including but not limited to: o business reputation, and relationship, if any, with public sector officials; o engagement details including nature of goods and / or services being provided; engagement with public sector officials on behalf of an Adobe Group Entity; o existence of policies, procedures prohibiting bribery, forced labour etc; and o determination of red flags and appropriate remediation",0,0,0,0,0,0,0,1,0,0,0 3708,153,Responsible Business Alliance (RBA) The Adobe Group commits publicly to the Responsible Business Alliance Code of Conduct (Code) and actively pursues conformance to the Code and its standards as a total supply chain initiative,0,0,0,0,0,0,0,1,0,0,0 3708,154,"The Adobe Group also requires business partners and suppliers to agree to our Business Partner Code of Conduct which outlines necessary management systems to ensure workers' rights are protected and includes abiding by its Labour Standards Freely Chosen Employment, Child Labour Avoidance, Lawful Employment, Non-Discrimination or Harassment, Freedom of Association, Safe Conditions, Working Hours, and Wage and Benefits",0,0,0,0,0,0,0,1,0,0,0 3708,155,______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 13,0,0,0,0,0,0,0,0,0,0,0 3708,156,"The Adobe Groups management, including management of Adobe Australia, believe that the policies and procedures in place appropriately address modern slavery risks for Adobe Australia",0,0,0,0,0,0,0,0,0,0,0 3708,157,Areas of opportunity,0,0,0,0,0,0,0,0,0,0,0 3708,158,"During Adobe Australias next reporting period, we are aiming to evaluate our options to update our policies and procedures to address modern slavery risks",0,0,0,0,0,0,0,1,0,0,0 3708,159,We also plan to conduct additional risk mapping and evaluation of our program,0,0,0,0,0,0,0,1,0,0,0 6676,55,Develop and roll out action plans to subcontractors and suppliers identified as high risk,0,0,0,0,0,0,0,1,0,0,0 6676,56,Request third party labour providers acknowledgement of no recruitment fees paid by workers to the recruiter,0,0,0,0,0,0,0,1,0,0,0 6676,57,Have contracts of employment or engagement in place with workers and ensure copies of the workers contracts are readily available,0,0,0,0,0,0,0,1,0,0,0 6676,58,Complete a Modern Slavery Assessment prior to onboarding new suppliers and subcontractors with the support of iPro,0,0,0,0,0,0,0,1,0,0,0 6676,59,iPro is an Australian-based software company specialising in digital solutions for Contractor Compliance and ESG responsibilities,0,0,0,0,0,0,0,0,0,0,0 6676,60,Modern Slavery Statement 2021,0,0,0,0,0,0,0,0,0,0,0 6676,61,The Harris HMC Group 52 Henderson Street North Melbourne VIC 3051 P +61 3 9328 8900 E enquiries@harrishmc.com.au,0,0,0,0,0,0,0,0,0,0,0 7068,0,Finbar Group Limited,0,0,0,0,0,0,0,0,0,0,0 11377,20,The principal activity of the group is the provision of legal services in Australia,0,0,0,0,1,0,0,0,0,0,0 11377,21,"Wotton + Kearney Limited (NZBN 9429031331227), is a separately constituted and regulated legal entity registered in New Zealand, with offices in Auckland and Wellington",0,0,0,1,1,0,0,0,0,0,0 11377,22,Wotton + Kearney procures goods and services for the purpose of providing legal services,0,0,0,0,0,1,0,0,0,0,0 11377,23,The key categories of goods and services in our supply chain include,0,0,0,0,0,1,0,0,0,0,0 11377,24,Occupancy of premises and parking,0,0,0,0,0,1,0,0,0,0,0 11377,25,Computer and IT services,0,0,0,0,0,1,0,0,0,0,0 11377,26,Business services and products such as printing,0,0,0,0,0,1,0,0,0,0,0 11377,27,"Professional services such as accounting, legal and travel services",0,0,0,0,0,1,0,0,0,0,0 991,1,Contents Our Commitment 3 Our Company 4 Our Supply Chain 6 Areas of Risk 7 Consultation 8 Our Actions 9 Future Actions 14 2 | Sims Limited Modern Slavery Statement 2020,0,0,0,0,0,0,0,0,0,0,0 991,2,Our Commitment We believe that upholding human rights is vital to ethical business conduct,0,0,0,0,0,0,0,0,0,0,0 991,3,It drives our development of a responsible supply chain and creation of a safe and fair workplace,0,0,0,0,0,0,0,0,0,0,0 991,4,"We are committed to respecting, promoting and upholding fundamental human rights as set out in the Universal Declaration of Human Rights defined for business in the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, the United Nations Guiding Principles on Business and Human Rights, and in the International Labour Organisation Core Conventions on Labour Standards",0,0,0,0,0,0,0,0,0,0,0 991,5,"This statement, pursuant to the Australian Modern Slavery Act 2018 (Cth) and section 54 of the Modern Slavery Act 2015 (UK), sets out the actions taken by Sims Limited (Sims)* to address modern slavery risks in our business and supply chain for the financial year ending 30 June 2020",0,0,0,0,0,0,0,0,0,0,0 991,6,"Modern slavery practices include trafficking in persons, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruiting for labour or services, and the worst forms of child labour, where children are subject to slavery or similar practices, or engaged in hazardous work",0,0,0,0,0,0,0,0,0,0,0 991,7,"Commonwealth Modern Slavery Act 2018 Guidance for Reporting Entities, p",0,0,0,0,0,0,0,0,0,0,0 991,8,*This statement is a joint statement on behalf of Sims Limited and Sims Group Australia Holdings Limited in accordance with the Australian Modern Slavery 2018 (Cth),0,0,0,0,0,0,0,0,0,0,0 3708,160,"As we enhance our assessment, we will continue to identify, prioritize and respond to risks",0,0,0,0,0,0,0,0,0,0,0 3708,161,We will give an update in our next Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 3708,162,How we measure the effectiveness of what we are doing,0,0,0,0,0,0,0,0,0,0,0 3708,163,This section addresses the mandatory criterion of describing how the reporting entity assesses the effectiveness of its actions (and the actions of any entity that the reporting entity owns or controls) to assess and address modern slavery risks (section 16(1)(e) Modern Slavery Act),0,0,0,0,0,0,0,0,0,0,0 3708,164,We wish to keep track of our progress in addressing modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 3708,165,Adobe Australia has identified actions and outcomes that our assessment of effectiveness could be based on,0,0,0,0,0,0,0,0,0,0,0 3708,166,Type of activities Action Outcomes Current activities,0,0,0,0,0,0,0,1,0,0,0 3708,167,"Procurement Activities Assess suppliers using RBA Maplecroft Risk Assessment tool, Supplier Self-Assessment Questionnaire and VAP Adobe Group has a better understanding of its supply chains and risks",0,0,0,0,0,0,0,1,0,0,0 7068,1,Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 7068,2,Developing Better Lifestyles,0,0,0,0,0,0,0,0,0,0,0 7068,3,Table of Contents,0,0,0,0,0,0,0,0,0,0,0 7068,4,Identifying the reporting entity,0,0,0,0,0,0,0,0,0,0,0 7068,5,"Structure, operations, and supply chain",0,0,0,0,0,0,0,0,0,0,0 7068,6,Structure,0,0,0,0,0,0,0,0,0,0,0 7068,7,Operations,0,0,0,0,0,0,0,0,0,0,0 7068,8,Supply Chain,0,0,0,0,0,0,0,0,0,0,0 11377,28,"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",0,0,0,0,0,0,1,1,0,0,0 11377,29,The analysis identified our top 50 suppliers across our top 15 risk industry categories based on spend,0,0,0,0,0,0,1,0,0,0,0 11377,30,"Risk was determined based on the industry, amount spent and the geographical location of the products or services",0,0,0,0,0,0,1,0,0,0,0 11377,31,The overall risks of modern slavery occurring in our supply chains and operations have been assessed as being relatively low,0,0,0,0,0,0,1,0,0,0,0 11377,32,"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",0,0,0,0,0,0,0,0,0,0,0 11377,33,The most elevated risk of modern slavery in Wotton + Kearneys operations and supply chains fall within the industries on the right,0,0,0,0,0,0,1,0,0,0,0 11377,34,"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",0,0,0,0,0,0,1,0,0,0,0 11377,35,"Forced labour restrictions of movement, intimidation, threats, including human trafficking",0,0,0,0,0,0,1,0,0,0,0 991,9,"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",0,0,1,0,0,0,0,0,0,0,0 991,10,"Sims Metal Management Finance Limited Sims Group UK Intermediate Holdings Limited Sims Recycling Solutions Holdings, Inc",0,0,0,0,0,0,0,0,0,0,0 991,11,"Sims Recycling Solutions, Inc",0,0,0,0,0,0,0,0,0,0,0 991,12,Sims Global Commodities Pte Ltd,0,0,0,0,0,0,0,0,0,0,0 991,13,Sims Group Holdings 1 Pty Ltd,0,0,0,0,0,0,0,0,0,0,0 991,14,Sims Group Holdings 2 Pty Ltd,0,0,0,0,0,0,0,0,0,0,0 991,15,Sims Metal Management USA GP Sims Group USA Holdings Corporation Sims Group Global Trade Corporation Sims Limited Modern Slavery Statement 2020 | 3,0,0,0,0,0,0,0,0,0,0,0 991,16,"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",0,0,0,0,1,0,0,0,0,0,0 3708,168,Supplier Audits Adobe Group has a better understanding of its supply chains and risks,0,0,0,0,0,0,0,0,0,0,0 3708,169,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,0,0,0,0,0,0,0,1,0,0,0 3708,170,Adobe Groups Supplier Ethics & Integrity Program requiring suppliers to certify key information about their Suppliers better understand Adobe Groups expectations of business conduct,0,0,0,0,0,0,0,0,0,0,0 3708,171,______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 14,0,0,0,0,0,0,0,0,0,0,0 3708,172,Type of activities Action Outcomes compliance practices and policies,0,0,0,0,0,0,0,1,0,0,0 3708,173,"Having contractual terms requiring compliance with laws and that no forced, bonded or involuntary labour used",0,0,0,0,0,0,0,1,0,0,0 3708,174,Suppliers better understand expectations of Adobe Group in relation to modern slavery,0,0,0,0,0,0,0,0,0,0,0 3708,175,"Capacity building and awareness raising Encouraging suppliers to use RBAs Learning Academy, which includes modules on the RBA Code of Conduct",0,0,0,0,0,0,0,1,0,0,0 7068,9,Identifying risks of modern slavery,0,0,0,0,0,0,0,0,0,0,0 7068,10,Operations,0,0,0,0,0,0,0,0,0,0,0 7068,11,Supply Chain,0,0,0,0,0,0,0,0,0,0,0 7068,12,Taking action against modern slavery,0,0,0,0,0,0,0,0,0,0,0 7068,13,Overview,0,0,0,0,0,0,0,0,0,0,0 7068,14,Operations,0,0,0,0,0,0,0,0,0,0,0 7068,15,Supply chain,0,0,0,0,0,0,0,0,0,0,0 7068,16,Measuring effectiveness,0,0,0,0,0,0,0,0,0,0,0 11377,36,"Deceptive recruitment practices workers promised certain jobs, benefits, or conditions",0,0,0,0,0,0,1,0,0,0,0 11377,37,Child labour where children are engaged in hazardous work,0,0,0,0,0,0,1,0,0,0,0 11377,38,"Debt bondage the payment of excessive recruitment fees or associated costs, and retention of identity documents",0,0,0,0,0,0,1,0,0,0,0 11377,39,"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",0,0,0,0,0,0,1,0,0,0,0 11377,40,"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",0,0,0,0,0,0,1,0,0,0,0 11377,41,"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",0,0,0,0,0,0,1,0,0,0,0 11377,42,"In addition, outsourcing and subcontracting creates a heightened risk of vulnerability for workers because there is less visibility and control over the contractual arrangements",0,0,0,0,0,0,1,0,0,0,0 11377,43,Recruitment services Recruitment services can pose a risk on employees by,0,0,0,0,0,0,1,0,0,0,0 991,17,"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",0,0,0,0,0,0,0,0,0,0,0 991,18,We work toward realising this purpose through each of our business divisions and our joint ventures,0,0,0,0,0,0,0,0,0,0,0 991,19,"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",0,0,0,0,1,0,0,0,0,0,0 991,20,Ltd (transforming material left over from metal recycling into useful products),0,0,0,0,1,0,0,0,0,0,0 991,21,"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",0,0,0,1,1,0,0,0,0,0,0 991,22,"Our global workforce consists of more than 4,000 employees across more than 147 managed sites",0,0,0,1,1,0,0,0,0,0,0 991,23,"Our personnel are primarily employees, but we also utilise temporary/ short-term workers, as well as contractors",0,0,0,0,1,1,0,0,0,0,0 991,24,"We have 21 agents in Asia Pacific, Europe, South America and the Caribbean",0,0,0,0,1,1,0,0,0,0,0 3708,176,Suppliers have a better awareness of RBA Code of Conduct expectations and understand expectations of Adobe Group in relation to modern slavery,0,0,0,0,0,0,0,0,0,0,0 3708,177,Requiring Adobe Group employees to undertake Code of Business Conduct training Our employees better understand the expectations in the Code of Business Conduct,0,0,0,0,0,0,0,1,0,0,0 3708,178,Supplier activities Liaising with its supplier and conducting monthly visits to review production area Increase in supplier engagement and better awareness of Adobes expectations,0,0,0,0,0,0,0,0,0,1,0 3708,179,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,0,0,0,0,0,0,0,1,0,0,0 3708,180,Future activities,0,0,0,0,0,0,0,0,0,0,0 3708,181,Policies and procedures Evaluate potential updates to our policies and procedures to address modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 3708,182,Updates may improve the Adobes business partners understanding of Adobes expectations,0,0,0,0,0,0,0,0,0,0,0 3708,183,Consultation,0,0,0,0,0,0,0,0,0,0,0 7068,17,Consultation,0,0,0,0,0,0,0,0,0,0,0 7068,18,Approval,0,0,0,0,0,0,0,0,0,0,0 7068,19,"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",0,0,0,1,0,0,0,0,0,0,0 7068,20,"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",0,0,1,0,0,0,0,0,0,0,0 7068,21,"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",1,1,0,0,0,0,0,0,0,0,0 7068,22,"Structure, operations, and supply chain Structure Finbar is an Australian property development and property investment company located in Perth, Western Australia (WA)",0,0,0,0,1,0,0,0,0,0,0 7068,23,Its core focus is developing medium to high-density residential apartments and commercial properties,0,0,0,0,1,0,0,0,0,0,0 7068,24,"Developments, project management, sales, rental and other associated functions are undertaken by fully owned subsidiaries of Finbar and Finbars joint venture entities",0,0,0,0,1,0,0,0,0,0,0 11377,44,restricting workers freedom of movement,0,0,0,0,0,0,1,0,0,0,0 11377,45,"withholding, destroying, concealing, or denying access to their workers identification documents, passports, work permits or travel documents",0,0,0,0,0,0,1,0,0,0,0 11377,46,requiring workers to pay recruitment fees,0,0,0,0,0,0,1,0,0,0,0 11377,47,using wage deductions as a disciplinary measure Occupancy of premises and parking The highest risk categories include cleaning and security services,0,0,0,0,0,0,1,0,0,0,0 11377,48,Examples of risks include,0,0,0,0,0,0,1,0,0,0,0 11377,49,the use of foreign workers or temporary or unskilled labour; and,0,0,0,0,0,0,1,0,0,0,0 11377,50,the procurement of uniforms and other goods potentially manufactured using cotton in countries outside of Australia and New Zealand,0,0,0,0,0,0,1,0,0,0,0 11377,51,"MODERN SLAVERY STATEMENT Understanding the impact and risk of causing, contributing to or being directly linked to modern slavery",0,0,0,0,0,0,0,0,0,0,0 991,25,Sims holds a 50 percent interest in four active entities,0,0,0,0,1,0,0,0,0,0,0 991,26,"Sims manages two of these entities, Richmond Steel Recycling (Canada) and Rondout Iron and Metal Co (United States)",0,0,0,0,1,0,0,0,0,0,0 991,27,"The other two, SA Recycling LLC (United States) and LMS Energy Pty",0,0,0,0,1,0,0,0,0,0,0 991,28,"Ltd (Australia), are not managed by Sims",0,0,0,0,1,0,0,0,0,0,0 991,29,"These joint ventures have 124 sites located in Canada, the United States and Australia at 30 June 2020",0,0,0,0,1,0,0,0,0,0,0 991,30,| Sims Limited Modern Slavery Statement 2020,0,0,0,0,0,0,0,0,0,0,0 991,31,"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",0,0,0,0,1,0,0,0,0,0,0 991,32,"Our Supply Chain Our trade supply chain is flat, and it solely consists of metal and electronics recycling suppliers and subcontractors",0,0,0,0,0,1,0,0,0,0,0 3708,184,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),0,0,0,0,0,0,0,0,0,0,0 3708,185,"Given that Business Catalyst Systems Pty Ltd has no operations, consultation with this entity is not relevant",0,0,0,0,0,0,0,0,0,0,1 3708,186,"Adobe Australia has consulted with Adobe Inc., Adobe Ireland and Adobe Singapore when preparing this Statement",0,0,0,0,0,0,0,0,0,0,0 3708,187,Consultations occurred by email communications and discussions between the entities key stakeholders,0,0,0,0,0,0,0,0,0,0,0 3708,188,Any other relevant information,0,0,0,0,0,0,0,0,0,0,0 3708,189,This section addresses the mandatory criterion of any other relevant information (section 16(1)(g) Modern Slavery Act),0,0,0,0,0,0,0,0,0,0,0 3708,190,______________________________________________________________________________ ADOBE 2020 STATEMENT FOR THE AUSTRALIA MODERN SLAVERY ACT 15,0,0,0,0,0,0,0,0,0,0,0 3708,191,Other reporting obligations,0,0,0,0,0,0,0,0,0,0,0 7068,25,This statement is made in respect of Finbar Group Limited (ultimate holding company) and its wholly owned and controlled entities,0,0,0,1,0,0,0,0,0,0,0 7068,26,Refer to Appendix A for a listing of the Companys wholly owned and controlled entities as at 30 June 2020,0,0,0,0,0,0,0,0,0,0,0 7068,27,Operations Finbars operations are primarily focused on the development of residential apartments in the Perth metropolitan area,0,0,0,0,1,0,0,0,0,0,0 7068,28,"Finbar also holds residential property investments in Karratha as well as commercial property investments in Karratha, South Perth, and East Perth",0,0,0,0,1,0,0,0,0,0,0 7068,29,"At 30 June 2021, Finbar employed 31 staff engaged across its Perth and Karratha offices",0,0,0,1,1,0,0,0,0,0,0 7068,30,All work undertaken is administrative or managerial in nature,0,0,0,0,1,0,0,0,0,0,0 7068,31,All employees are directly employed by Finbar Group Limited,0,0,0,0,1,0,0,0,0,0,0 7068,32,Supply Chain Finbar operates in WA with a localised immediate supply chain,0,0,0,0,0,1,0,0,0,0,0 11377,52,Mapping our supply chain and analysing it for modern slavery risk,0,0,0,0,0,0,0,1,0,0,0 11377,53,Developing and rolling out a modern slavery questionnaire for our suppliers,0,0,0,0,0,0,0,1,0,0,0 11377,54,Performing risk assessments of new suppliers,0,0,0,0,0,0,0,1,0,0,0 11377,55,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,0,0,0,0,0,0,0,1,0,0,0 11377,56,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,0,0,0,0,0,0,0,0,0,0,0 11377,57,"We will monitor and track our progress through a process of reviews, oversight, and tracking KPIs",0,0,0,0,0,0,0,0,0,1,0 11377,58,"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",0,0,0,0,0,0,0,0,0,1,0 11377,59,Number of modern slavery questionnaires completed,0,0,0,0,0,0,0,0,0,1,0 991,33,"Metal suppliers generally fall into three categories: casual suppliers, dealers and industrial suppliers",0,0,0,0,0,1,0,0,0,0,0 991,34,"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",0,0,0,0,0,1,0,0,0,0,0 991,35,Sims Municipal Recyclings suppliers are limited to collection service providers in each of the municipalities where we operate,0,0,0,0,0,1,0,0,0,0,0 991,36,For our operations producing renewable energy through methane capture the trade suppliers are the landfills owners where we operate,0,0,0,0,1,1,0,0,0,0,0 991,37,"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",0,0,0,0,0,1,0,0,0,0,0 991,38,Modern Slavery Risk Assessment Process PURCHASES IN HIGHER RISK COUNTRIES,0,0,0,0,0,0,0,0,0,0,0 991,39,"% 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",0,0,0,0,0,1,0,1,0,0,0 991,40,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,0,0,0,0,0,0,0,0,0,0,0 3708,192,Entities in the Adobe group have been subject to other jurisdictions reporting obligations,0,0,0,0,0,0,0,0,0,0,0 3708,193,Adobe Inc has provided transparency statements under the California Transparency in Supply Chains Act of 2010,0,0,0,0,0,0,0,0,0,0,0 3708,194,Adobe Systems Software Ireland Ltd has reported under the United Kingdom (UK) Modern Slavery Act 2015,0,0,0,0,0,0,0,0,0,0,0 3708,195,We consider the implementation of these reporting regimes as important developments in combatting modern slavery and human trafficking around the world,0,0,0,0,0,0,0,0,0,0,0 3708,196,Impact of COVID-19,0,0,0,0,0,0,0,0,0,0,0 3708,197,"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",0,0,0,0,0,0,0,0,0,0,0 3708,198,We also had to divert resources to keep our people and customers safe during the pandemic,0,0,0,0,0,0,0,0,0,0,0 3708,199,"Accordingly, some of the measures which we had originally planned to help identify and address modern slavery risks have been postponed",0,0,0,0,0,0,1,0,0,0,0 7068,33,Finbar engaged 353 suppliers over the FY21 reporting period,0,0,0,0,0,1,0,0,0,0,0 7068,34,The majority of these suppliers a total of 336 are based in Australia,0,0,0,0,0,1,0,0,0,0,0 7068,35,"The remaining suppliers are based, or have relevant operations, in the United States, the United Kingdom, New Zealand and Israel",0,0,0,0,0,1,0,0,0,0,0 7068,36,"Most of Finbars supply chain is comprised of professional services providers, such as consultancy, legal and financial services",0,0,0,0,0,1,0,0,0,0,0 7068,37,Finbar has also engaged a smaller number of suppliers to assist with its,0,0,0,0,0,1,0,0,0,0,0 7068,38,"operations, including business services, cleaning, hospitality, office and IT supplies, and security",0,0,0,0,0,1,0,0,0,0,0 7068,39,"Finbars remaining suppliers are largely based in the construction and real estate sectors, or have been engaged for repair and maintenance of its properties",0,0,0,0,0,1,0,0,0,0,0 7068,40,"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",0,0,0,0,0,0,1,1,0,0,0 11377,60,Number of new and existing suppliers screened,0,0,0,0,0,0,0,0,0,1,0 11377,61,Assigning suppliers with a risk rating following a risk assessment Reviewing our policies and procedures,0,0,0,0,0,0,0,1,0,1,0 11377,62,Number of suppliers who have incorporated modern slavery provisions in contracts and/or our Modern Slavery Supplier Code of Conduct,0,0,0,0,0,0,0,0,0,1,0 11377,63,Annual review of our Modern Slavery Policy and Modern Slavery Grievance Policy,0,0,0,0,0,0,0,0,0,1,0 11377,64,"Number of recorded modern slavery incidents, the type of human rights issue raised and the outcome Building staff awareness and capacity",0,0,0,0,0,0,0,0,0,1,0 11377,65,Number and percentage of staff trained in identifying and addressing modern slavery,0,0,0,0,0,0,0,0,0,1,0 11377,66,Number of key personnel who completed targeted training,0,0,0,0,0,0,0,0,0,1,0 11377,67,Number of training sessions conducted (included format and topics covered) Reviewing our policies and procedures,0,0,0,0,0,0,0,0,0,1,0 991,41,"We endeavour to avoid being complicit in, or encouraging, activities that may result in human rights abuses",0,0,0,0,0,0,0,0,0,0,0 991,42,"As such, we performed a risk assessment of our operations and supply chain globally",0,0,0,0,0,0,1,0,0,0,0 991,43,"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",0,0,0,0,0,1,1,0,0,0,0 991,44,"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",0,0,0,0,0,1,1,0,0,0,0 991,45,"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",0,0,0,0,0,0,0,0,0,0,0 991,46,"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",0,0,0,0,0,1,1,0,0,0,0 991,47,Recruitment/placement agencies,0,0,0,0,0,0,0,0,0,0,0 991,48,Contractors,0,0,0,0,0,1,1,0,0,0,0 3752,0,Anti-Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 3752,1,Financial Year 2019-2020,0,0,0,0,0,0,0,0,0,0,0 3752,2,"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",0,0,0,0,0,0,0,1,0,0,0 3752,3,"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",0,0,0,0,0,0,0,0,0,0,0 3752,4,"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",0,0,0,0,0,0,0,0,0,0,0 3752,5,"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",0,0,0,0,0,0,0,0,0,0,0 3752,6,"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",0,0,0,0,0,0,0,1,0,0,0 3752,7,We are committed to a compliance culture within the St Hilliers Group and to continuous improvement in compliance performance,0,0,0,0,0,0,0,0,0,0,0 7068,41,Finbar has implemented systems and standards to ensure that terms and conditions of engagement of labour meet or exceed legislative requirements in Western Australia,0,0,0,0,0,0,0,1,0,0,0 7068,42,Finbar also engages several suppliers to deliver aspects of its operations,0,0,0,0,0,1,0,0,0,0,0 7068,43,"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",0,0,0,0,0,0,1,0,0,0,0 7068,44,"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",0,0,0,0,0,1,1,0,0,0,0 7068,45,office and IT supplies and equipment,0,0,0,0,0,1,1,0,0,0,0 7068,46,"business services, facilities management and managing office space (eg, security and cleaning services)",0,0,0,0,0,1,1,0,0,0,0 7068,47,hospitality and catering; and,0,0,0,0,0,1,1,0,0,0,0 7068,48,"construction, repair and maintenance",0,0,0,0,0,1,1,0,0,0,0 11377,68,Developing and implementing a Modern Slavery Policy,0,0,0,0,0,0,0,1,0,0,0 11377,69,Developing a Modern Slavery Grievance Policy,0,0,0,0,0,0,0,1,0,0,0 11377,70,Incorporating modern slavery provisions into new procurement contracts,0,0,0,0,0,0,0,1,0,0,0 11377,71,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,0,0,0,0,0,0,0,1,0,0,0 11377,72,Launching an anti-slavery training module for all staff,0,0,0,0,0,0,0,1,0,0,0 11377,73,Delivering tailored training to the Board,0,0,0,0,0,0,0,1,0,0,0 11377,74,Delivering tailored training to key personnel involved in procurement and / or supplier contracts,0,0,0,0,0,0,0,1,0,0,0 11377,75,"Creating a modern slavery information page on the staff intranet with links to training, policies, and other resources",0,0,0,0,0,0,0,1,0,0,0 991,49,Cleaning services,0,0,0,0,0,1,1,0,0,0,0 991,50,Personal protective equipment/ uniform providers,0,0,0,0,0,1,1,0,0,0,0 991,51,Construction,0,0,0,0,0,1,1,0,0,0,0 991,52,Chartered vessels Supplier Risk We have identified suppliers in regions and specific industries that are at higher risk of modern slavery,0,0,0,0,0,1,1,0,0,0,0 991,53,"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",0,0,0,0,0,1,1,0,0,0,0 991,54,"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",0,0,0,0,0,1,1,0,0,0,0 991,55,"The workers in these industries can be from vulnerable populations (not highly skilled, migrants, of low socioeconomic, culturally and linguistically diverse backgrounds)",0,0,0,0,0,0,1,0,0,0,0 991,56,Customer Risk Our customers may present a modern slavery risk,0,0,0,0,0,0,0,0,0,0,0 3752,8,"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",0,0,0,0,0,0,0,0,0,0,0 3752,9,We are committed to supporting Australias international reputation as an active participant in the international movement against modern slavery,0,0,0,0,0,0,0,0,0,0,0 3752,10,"Cover photo by Shivendu Shukla, photo below by Jack Sloop, on Unsplash",0,0,0,0,0,0,0,0,0,0,0 3752,11,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],0,0,0,0,0,0,0,1,0,0,0 3752,12,"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",0,0,0,0,0,0,0,1,0,0,0 3752,13,"Workers must not be subject to physical or verbal abuse, threats or intimidation",0,0,0,0,0,0,0,1,0,0,0 3752,14,Workers must not be required to work excessive hours and all workers should enjoy sufficient rest periods,0,0,0,0,0,0,0,1,0,0,0 3752,15,"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",0,0,0,0,0,0,0,1,0,0,0 7068,49,"Within the construction of development properties, suppliers to Finbars building contractor use labour engaged through third-party providers and subcontractors, which combined with a workforce including higher rates of migrant and unskilled labour, increases risks of modern slavery",0,0,0,0,0,0,1,0,0,0,0 7068,50,Finbar does not have direct supervision over the third-party workforce or transparency over the terms and conditions of the engagement of these workers,0,0,0,0,0,0,1,0,0,0,0 7068,51,"Notwithstanding, Finbar is prioritising its construction industry suppliers for direct engagement over the next reporting periods to better understand the extent of risk and ensure that suppliers are identifying and addressing risks of modern slavery in their own operations and supply chains",0,0,0,0,0,0,0,1,0,0,0 7068,52,"The Company will also commit to more deeply reviewing its direct supplier list, applying risk assessment criteria including industry, geography and spend criteria to identify those suppliers that may be classified as higher risk of modern slavery, requiring closer engagement",0,0,0,0,0,0,0,1,0,0,0 7068,53,Supply Chain Finbars overseas based suppliers are largely based in countries that are considered low risk by the Global Slavery Index 2018 (GSI),0,0,0,0,0,0,1,0,0,0,0 7068,54,"However, it recognises that its suppliers may, in turn, utilise suppliers, or source or produce their goods and services in countries which may include those identified by the Global Slavery Index as having a higher risk of modern slavery",0,0,0,0,0,0,1,0,0,0,0 7068,55,"In light of this, Finbar will engage with its suppliers during the next two reporting periods to determine which jurisdictions their suppliers source from, to better understand their supply chains, and to determine whether they have appropriate policies in place",0,0,0,0,0,0,0,1,0,0,0 7068,56,Finbar has also considered the sector specific risks in respect of its Australian based suppliers,0,0,0,0,0,0,0,0,0,0,0 11377,76,"MODERN SLAVERY STATEMENT CONSULTATION AND STATEMENT APPROVAL Because of the shared management and governance of Wotton & Kearney Holdings Ltd, Wotton + Kearney Pty Ltd and Pinsani Pty Ltd, the preparation of this statement was inherently consultative",0,0,0,0,0,0,0,0,0,0,1 11377,77,"In accordance with section 13 of the Modern Slavery Act 2018 (Cth), this statement was approved by the Board of Wotton & Kearney Holdings Ltd on 27 October 2022 and is signed by David Kearney, Director and Chief Executive Partner",1,1,0,0,0,0,0,0,0,0,0 11377,78,"Signed: David Kearney Chief Executive Partner Wotton + Kearney Australian offices Adelaide Hub Adelaide, 89 Pirie Street Adelaide, SA 5000 T: +61 8 8473 8000 Brisbane Level 23, 111 Eagle Street Brisbane, QLD 4000 T: +61 7 3236 8700 Canberra Suite 4.01, 17 Moore Street Canberra, ACT 2601 T: +61 2 5114 2300 Melbourne Level 15, 600 Bourke Street Melbourne, VIC 3000 T: +61 3 9604 7900 Perth Level 49, 108 St Georges Terrace Perth, WA 6000 T: +61 8 9222 6900 Sydney Level 26, 85 Castlereagh Street Sydney, NSW 2000 T: +61 2 8273 9900 New Zealand offices Auckland Level 18, Crombie Lockwood Tower 191 Queen Street, Auckland 1010 T: +64 9 377 1854 Wellington Level 13, Harbour Tower 2 Hunter Street, Wellington 6011 T: +64 4 499 5589 www.wottonkearney.com.au",0,1,0,0,1,0,0,0,0,0,0 11499,0,MCP Wholesale Investments Trust FY22 Modern Slavery Statement For Financial Year ending 30 June 2022 Page 1 of 4 | MCP Wholesale Investments Trust | FY22 Modern Slavery Statement Reporting Entity This statement is submitted under section 13 of the Modern Slavery Act 2018 (Cth) for the MCP Wholesale Investments Trust ABN 67 528 545 446 (WIT or the Trust),0,0,1,0,0,0,0,0,0,0,0 11499,1,"This Statement has been prepared by the trustee The Trust Company Limited, ABN 59 004 027 749 (Trustee) and approved by the Board of Directors of the Trustee on 14 December 2022",1,0,0,0,0,0,0,0,0,0,0 11499,2,Mark Smith Director The Trust Company Limited Consultation There are no subsidiaries or entities owned or controlled by MCP Wholesale Investments Trust which the Trustee is required to consult with to prepare this Statement,0,1,0,0,0,0,0,0,0,0,1 11499,3,"This Statement was developed in consultation with the investment manager, Metrics Credit Partners Pty Ltd for the Trust (Investment Manager) Structure, Operations and Supply Chain Structure The Trust is an unregistered managed investment scheme domiciled in Australia and was constituted on 26 September 2017 and has been in operation since 5 October 2017",0,0,0,1,0,0,0,0,0,0,0 11499,4,"The investment strategy of the Trust is to create a diversified exposure to Australian corporate loans generally reflecting market activity diversified by borrower, industry and credit quality",0,0,0,0,0,0,0,0,0,0,0 991,57,We could be inadvertently linked to slavery-like practices as we sell to them,0,0,0,0,0,0,0,0,0,0,0 991,58,"Operations Risk While no region is immune to modern slavery practices, certain geographies present higher risk",0,0,0,0,0,0,1,0,0,0,0 991,59,We operate in such a region in Papua New Guinea,0,0,0,0,0,0,1,0,0,0,0 991,60,We also use agents to facilitate sales in certain regions of the world,0,0,0,0,0,0,1,0,0,0,0 991,61,These agents are typically located and work in countries that are being assessed as higher risk to have modern slavery practices,0,0,0,0,0,0,1,0,0,0,0 991,62,We supplement our workforce by hiring temporary workers and contractors,0,0,0,0,0,1,1,0,0,0,0 991,63,There is an increased risk for poor labour practices to exist if we do not manage our relationships with third-party labour hire agencies and contractors well,0,0,0,0,0,0,1,0,0,0,0 991,64,SALES IN HIGHER RISK COUNTRIES: APAC Region PAPUA NEW GUINEA <1% of Total Sales CHINA/HONG KONG 10% of Total Sales PAKISTAN 1% of Total Sales EMEA Region EGYPT 1% of Total Sales,0,0,0,0,0,1,0,0,0,0,0 3752,16,If child labour is identified Suppliers must establish appropriate remediation measures and implement effective systems to prevent the use of child labour in the future,0,0,0,0,0,0,0,1,0,0,0 3752,17,"Suppliers and subcontractors must provide safe and hygienic working conditions for all workers with sufficient and accessible fire exits from all production, warehouse and dormitory buildings",0,0,0,0,0,0,0,1,0,0,0 3752,18,Workers must also be provided with clean and hygienic washroom and canteen facilities and have regular access to clean drinking water,0,0,0,0,0,0,0,1,0,0,0 3752,19,Workers must not be required to operate dangerous machinery and suitable Personal Protective Equipment should be provided at all times,0,0,0,0,0,0,0,1,0,0,0 3752,20,The structure and layout of all buildings should be compliant with local regulations and designed to avoid any risk to workers,0,0,0,0,0,0,0,1,0,0,0 3752,21,All hazardous chemicals should be stored in appropriate conditions with suitable labels and secondary containers to prevent spillage,0,0,0,0,0,0,0,0,0,0,0 3752,22,"If serious or fatal accidents have occurred, then Suppliers will be required to demonstrate that all appropriate steps have been taken to avoid the risk of similar accidents occurring in future",0,0,0,0,0,0,0,0,0,0,0 3752,23,Photo by Pop and Zebra on Unsplash,0,0,0,0,0,0,0,0,0,0,0 7068,57,Approximately one third 34.6% of Finbars first tier suppliers are based in industries that are generally considered low risk for modern slavery,0,0,0,0,0,0,1,0,0,0,0 7068,58,These include professional services from the following sectors,0,0,0,0,0,1,1,0,0,0,0 7068,59,legal and consultancy,0,0,0,0,0,1,1,0,0,0,0 7068,60,financial,0,0,0,0,0,1,1,0,0,0,0 7068,61,real estate; and,0,0,0,0,0,1,1,0,0,0,0 7068,62,"media, marketing and PR",0,0,0,0,0,1,1,0,0,0,0 7068,63,Finbar considers that several of its other first tier suppliers are low risk from a sector-based perspective,0,0,0,0,0,0,1,0,0,0,0 7068,64,These include,0,0,0,0,0,0,1,0,0,0,0 11499,5,The Trust will invest in and alongside the wholesale trusts which are managed by the Investment Manager,0,0,0,0,1,0,0,0,0,0,0 11499,6,WIT owns no real property and has no employees,0,0,0,1,1,0,0,0,0,0,0 11499,7,"As at 30 June 2022, the Trust had A$3.295bn net assets under management",0,0,0,0,1,0,0,0,0,0,0 11499,8,Operations The primary operation of the Trust is the investment in directly originated secured loans and debt instruments,0,0,0,0,1,0,0,0,0,0,0 11499,9,Perpetual Limiteds subsidiary The Trust Company Linited is the Trustee for the MCP Wholesale Investment Trust,0,0,0,0,1,0,0,0,0,0,0 11499,10,"Perpetual Corporate Trust (PCT) PCT provides a broad range of fiduciary, agency and digital products to the debt capital markets and managed funds industries both domestically and internationally",0,0,0,0,1,0,0,0,0,0,0 11499,11,"Debt Market Services includes Responsible Entity, document custodian, agency, trust management, accounting, standby servicing, and reporting solutions",0,0,0,0,1,0,0,0,0,0,0 11499,12,"Perpetual Digital provides data services, industry roundtables, and our new Perpetual Intelligence platform-as-a-service products supporting the banking and financial services industry",0,0,0,0,1,0,0,0,0,0,0 991,65,% APAC 41 EMEA 35 AMER 24 Sales to Customers Per Region 12% of our sales are linked to higher risk regions Sims Limited Modern Slavery Statement 2020 | 7,0,0,0,0,0,0,0,0,0,0,0 991,66,"Consultation Assessing Sims operations and supply chain for modern slavery risks required a cross-functional dialogue that involved the Risk, Ethics and Compliance team, as well as the Human Resources, Finance and Operations teams",0,0,0,0,0,0,0,1,0,0,0 991,67,"Sims also sought guidance from non-governmental human rights-focused organisations, such as Walk Free by the Minderoo Foundation, Antislavery International, Liberty Shared, Human Rights Watch and the Human Rights Commission of Pakistan",0,0,0,0,0,0,0,1,0,0,0 991,68,We have briefed our Board of Directors and executive leadership team on modern slavery risks and engaged them in the drafting of our Modern Slavery Statement,0,0,0,0,0,0,0,1,0,0,0 991,69,"Externally, Sims sought to learn from our shareholders about their concerns and expectations regarding corporate responsibility on Sims part, including activities designed to prevent Sims from contributing to the system of modern slavery",0,0,0,0,0,0,0,0,0,0,0 991,70,"Sims employees also participate in local, national and international trade associations, which provide insight into such issues as gender equality, and environmental and sustainability topics, all of which impact modern slavery risks",0,0,0,0,0,0,0,1,0,0,0 991,71,We provide Code of Conduct training to all our employees each year,0,0,0,0,0,0,0,0,0,0,0 991,72,| Sims Limited Modern Slavery Statement 2020,0,0,0,0,0,0,0,0,0,0,0 3752,24,"Dormitories and living accommodation, if provided, must include sufficient fire alarm systems and fire exits and must not be adjoined in any way to production and storage areas",0,0,0,0,0,0,0,1,0,0,0 3752,25,Suppliers and subcontractors must pay living wages that are at least compliant with local minimum wage regulations and sufficient to meet basic needs,0,0,0,0,0,0,0,1,0,0,0 3752,26,"Suppliers and subcontractors must maintain accurate employment records for all employees, including current and resigned temporary and permanent workers, and be transparent and cooperative during the inspection of wages and working hours records",0,0,0,0,0,0,0,1,0,0,0 3752,27,"Bribery, corruption and similar unethical business practices are not tolerated by the Group and suppliers and subcontractors must not engage in such activities",0,0,0,0,0,0,0,1,0,0,0 3752,28,Photo by Nathan Waters on Unsplash,0,0,0,0,0,0,0,0,0,0,0 3752,29,"About the St Hilliers Group St Hilliers is one of Australias leading, private, integrated property and construction groups, based in Sydney and Brisbane",0,0,0,0,1,0,0,0,0,0,0 3752,30,It carries out construction projects all over the Australian mainland,0,0,0,0,1,0,0,0,0,0,0 3752,31,Our Operations principally involve,0,0,0,0,1,0,0,0,0,0,0 7068,65,"public and regulatory bodies (eg, local councils or tax authorities); and",0,0,0,0,0,0,1,0,0,0,0 7068,66,utilities and postage,0,0,0,0,0,0,1,0,0,0,0 7068,67,"Taking action against modern slavery Overview Modern slavery continues to remain a global issue, affecting approximately 40 million victims around the world (as estimated by the United Nations and Walk Free Foundation)",0,0,0,0,0,0,0,0,0,0,0 7068,68,"Finbar respects the human rights of every person involved in its operations, supply chain and the community in which it operates",0,0,0,0,0,0,0,0,0,0,0 7068,69,"It will not accept any form of modern slavery in the conduct of its operations and in its supply chain and is committed to ensuring that all workers are treated fairly, ethically and with respect",0,0,0,0,0,0,0,0,0,0,0 7068,70,"To date, the Group has not identified any instances of modern slavery in its operations or supply chain and is committed to addressing risks of modern slavery to which it may be exposed",0,0,0,0,0,0,1,0,0,0,0 7068,71,"Operations To mitigate against modern slavery risks in its operations, Finbar is committed to",0,0,0,0,0,0,0,1,0,0,0 7068,72,"engaging its employees under fair, just, and ethical employment contracts",0,0,0,0,0,0,0,1,0,0,0 11499,13,"Managed Funds Services provides services including independent responsible entity, wholesale trustee, custodian, investment management and accounting",0,0,0,0,1,0,0,0,0,0,0 11499,14,Supply chain The Trusts supply chain consists of direct service providers,0,0,0,0,0,1,0,0,0,0,0 11499,15,These suppliers are all located in Australia,0,0,0,0,0,1,0,0,0,0,0 11499,16,Procurement categories for service providers include,0,0,0,0,0,0,0,0,0,0,0 11499,17,Trustee,0,0,0,0,0,0,0,0,0,0,0 11499,18,Investment Managers,0,0,0,0,0,0,0,0,0,0,0 11499,19,Auditor,0,0,0,0,0,0,0,0,0,0,0 11499,20,Tax Agent,0,0,0,0,0,0,0,0,0,0,0 991,73,"Our Actions We work hard to stay abreast of developments in the area of human rights, such as safety in the workplace, fair wages and equal treatment",0,0,0,0,0,0,0,0,0,0,0 991,74,"At a minimum, we comply with all applicable local laws, regulations and standards of the countries in which we operate, and we strive to exceed basic compliance",0,0,0,0,0,0,0,0,0,0,0 991,75,"In FY20, Sims Limited implemented a global governance structure focused on increasing the effectiveness of current and future efforts to protect human rights in our operations and supply chain",0,0,0,0,0,0,0,0,0,0,0 991,76,Sims Risk & Compliance Group has been tasked with providing centralised leadership and guidance related to these efforts,0,0,0,0,0,0,0,1,0,0,0 991,77,"It spearheaded the issuance of our Supplier Code of Conduct in FY20, and will drive future improvements to and training on policies and procedures",0,0,0,0,0,0,0,1,0,0,0 991,78,Our Code of Conduct details our commitment to human rights,0,0,0,0,0,0,0,1,0,0,0 991,79,"This includes specific policies for the protection of rights for employees, including",0,0,0,0,0,0,0,1,0,0,0 991,80,"the right to equal opportunity and non-discrimination, regardless of ethnicity, gender, religion, age, sexual orientation, health status or other such protected classifications",0,0,0,0,0,0,0,1,0,0,0 3752,32,"Property development (including design, programming, marketing and sales) in the commercial, industrial, retail and residential sectors; and",0,0,0,0,1,0,0,0,0,0,0 3752,33,"Building and construction (including design) in each of those sectors, across mainland Australia",0,0,0,0,1,0,0,0,0,0,0 3752,34,Currently the Group engages some 140 staff,0,0,0,1,0,0,0,0,0,0,0 3752,35,At St Hilliers we are committed to supporting the many diverse communities in which we live and work across the country,0,0,0,0,0,0,0,0,0,0,0 3752,36,Our partners include: Legacy / The Kids Cancer Project / Meals on Wheels / Property Industry Foundation / Mates4Mates / SwichOn Inc / Randwick Rugby Club / Kids West Charity/ Cancer Council,0,0,0,0,0,0,0,0,0,0,0 3752,37,St Hilliers have been operating for more than 30 years and we have built this business by ensuring our clients expectations and our delivery are consistent,0,0,0,0,0,0,0,0,0,0,0 3752,38,About the Reporting Entities Our Structure: The Group is broadly divided into Property and Contracting arms,0,0,0,1,0,0,0,0,0,0,0 3752,39,"The entities which have reporting obligations under the Modern Slavery Act 2018 (Cwlth) and are making this statement jointly are in the Contracting part of the Group, being as follows",0,0,1,1,0,0,0,0,0,0,0 7068,73,"not partaking in high risk or unethical labour engagement practices, including by ensuring that it does not",0,0,0,0,0,0,0,1,0,0,0 7068,74,use migrant or seasonal labour,0,0,0,0,0,0,0,1,0,0,0 7068,75,charge employees to work through recruitment fees or imposing fines,0,0,0,0,0,0,0,1,0,0,0 7068,76,retain employee original identification documents or preventing employees from moving freely,0,0,0,0,0,0,0,1,0,0,0 7068,77,use child labour; or,0,0,0,0,0,0,0,1,0,0,0 7068,78,undertake deceptive recruiting practices,0,0,0,0,0,0,0,1,0,0,0 7068,79,"Given the higher likelihood of modern slavery in the cleaning industry, over the coming reporting period Finbar will engage directly with its cleaning contractor as a priority to understand its policies and processes for ensuring compliance with all relevant labour laws and regulations and for identifying, assessing and addressing risks of modern slavery",0,0,0,0,0,0,1,1,0,0,0 7068,80,"Supply chain To reduce exposure to modern slavery risk in its supply chain, Finbar has commenced direct engagement with its major supplier of building services during the current reporting period",0,0,0,0,0,0,0,1,0,0,0 11499,21,Administrator,0,0,0,0,0,0,0,0,0,0,0 11499,22,Custodian,0,0,0,0,0,0,0,0,0,0,0 11499,23,Independent Valuer,0,0,0,0,0,0,0,0,0,0,0 11499,24,Registry Provider,0,0,0,0,0,0,0,0,0,0,0 11499,25,Legal Counsel,0,0,0,0,0,0,0,0,0,0,0 11499,26,Distribution Partners/ Channels Modern Slavery Risks The Trustee understands that modern slavery risk can occur in operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 11499,27,The Trustee considers risk assessment a critical process to identifying the inherent risk of modern slavery across the MCP Wholesale Investments Trust,0,0,0,0,0,0,0,0,0,0,0 11499,28,Defining modern slavery risks Modern slavery is serious exploitation that undermines a persons freedom,0,0,0,0,0,0,0,0,0,0,0 991,81,"the right to personal security, including protection against improper and unlawful harassment, as well as against retaliation for employees who report non- conformance with government regulations, company policies and codes of conduct",0,0,0,0,0,0,0,1,0,0,0 991,82,"the right to a safe and healthy workplace for each and every employee, regardless of status",0,0,0,0,0,0,0,1,0,0,0 991,83,"the right to competitive remuneration, supporting the concept of competitive pay for work performed; and",0,0,0,0,0,0,0,1,0,0,0 991,84,all other legal rights in respect of the workplace granted to our people in the regions in which we operate,0,0,0,0,0,0,0,1,0,0,0 991,85,All of our employees are trained to act in accordance with our Code of Conduct and to raise any concerns or breaches to management or through our hotline,0,0,0,0,0,0,0,1,0,0,0 991,86,Our hotline allows employees and third parties to anonymously report breaches or concerns in all jurisdictions where we operate,0,0,0,0,0,0,0,1,0,0,0 991,87,We address all reports,0,0,0,0,0,0,0,1,0,0,0 991,88,"We provide new refresher training on our Code of Conduct to all employees annually, including detailed guidance for key areas on a rotating basis",0,0,0,0,0,0,0,1,0,0,0 3752,40,"STH Holdings Pty Ltd ABN 71 069 565 331, which is the holding company for the Contracting part of the group and does not trade",0,0,1,0,0,0,0,0,0,0,0 3752,41,"its subsidiary St Hilliers Pty Ltd ABN 78 003 819 681, which does not trade and is the parent of the trading company St Hilliers Contracting Pty Ltd ABN 66 082 729 039",0,0,1,1,0,0,0,0,0,0,0 3752,42,St Hilliers is a closely held Group and the same directors and managers are involved and work directly with all the reporting entities and their subsidiaries in relation to these issues,0,0,0,1,0,0,0,0,0,0,0 3752,43,Photo by Shane McLendon on Unsplash,0,0,0,0,0,0,0,0,0,0,0 3752,44,"Benefits of Combatting Modern Slavery There are many benefits in combatting Modern Slavery, including",0,0,0,0,0,0,0,0,0,0,0 3752,45,helping to protect vulnerable workers,0,0,0,0,0,0,0,0,0,0,0 3752,46,helping to prevent and remedy severe human rights violations,0,0,0,0,0,0,0,0,0,0,0 3752,47,protecting and enhancing the Groups reputation and brand,0,0,0,0,0,0,0,0,0,0,0 7068,81,The builder is participating in the dialogue process and has indicated its commitment to reducing modern slavery in its own supply chain,0,0,0,0,0,0,0,1,0,0,0 7068,82,Finbar recognises that continuous improvement is key to reducing the risk of modern slavery,0,0,0,0,0,0,0,0,0,0,0 7068,83,"To this end, it is committed to undertaking the following actions during the coming reporting periods",0,0,0,0,0,0,0,0,0,0,0 7068,84,"Continue to directly engage with its major builder, as well as seek to extend this engagement to other major suppliers that have been identified as high-risk following supply chain mapping, screening and risk assessment",0,0,0,0,0,0,0,1,0,0,0 7068,85,"This will allow Finbar to determine the extent of these suppliers anti-modern slavery actions, and to ensure these suppliers are monitoring their own operations and supply chains for risks",0,0,0,0,0,0,0,0,0,0,0 7068,86,Establish roles across the Group that will have responsibility for managing risks of Modern Slavery,0,0,0,0,0,0,0,1,0,0,0 7068,87,"Finbar will establish a modern slavery team comprised of the Company Secretary (reporting to the Board), the Development Manager and General Manager of Project Coordination",0,0,0,0,0,0,0,1,0,0,0 7068,88,"This team will report quarterly to the Board advising progress, particularly of the data gathered from the Groups suppliers in respect of their suppliers",0,0,0,0,0,0,0,0,0,0,0 11499,29,"In a situation where modern slavery occurs, a person cannot refuse or leave due to threats, violence, cohesion, abuse of power, or deception1",0,0,0,0,0,0,0,0,0,0,0 11499,30,"Modern slavery occurs in a variety of forms, there are eight types including human trafficking, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruiting for labour or services and the worst forms of child labour2",0,0,0,0,0,0,0,0,0,0,0 11499,31,"Modern slavery risk means the potential for the Trust to cause, contribute to, or be directly linked to modern slavery through their operation or supply chain",0,0,0,0,0,0,0,0,0,0,0 11499,32,"The Trust recognises that COVID-19, conflict and climate change driving migration has exacerbated modern slavery risks for people in vulnerable situations3",0,0,0,0,0,0,0,0,0,0,0 11499,33,"Risk assessment methodology In FY22, the Trustee collected information on the Trusts supply chain to include in a modern slavery risk assessment",0,0,0,0,0,0,0,1,0,0,0 11499,34,"Specifically, the Trustee investigated the service providers that we have a direct relationship with",0,0,0,0,0,0,0,1,0,0,0 11499,35,The service providers were then assessed for inherent modern slavery risks and an inherent risk profile was determined for each entity,0,0,0,0,0,0,0,1,0,0,0 11499,36,Inherent risk is the level of risk before any actions are taken to manage the risks impact or likelihood,0,0,0,0,0,0,0,0,0,0,0 991,89,"In addition, posters are displayed at all of our sites and visible to both employees and visitors",0,0,0,0,0,0,0,1,0,0,0 991,90,Drafted and issued the Sims Limited Supplier Code of Conduct to codify our expectations for the business conduct of our suppliers and partners and the support we will provide for them,0,0,0,0,0,0,0,1,0,0,0 991,91,Developed training to further build understanding of and address modern slavery risk Conducted Code of Conduct training Established a global governance structure to support centralised and standardised administration and response,0,0,0,0,0,0,0,1,0,0,0 991,92,Signed the World Business Council for Sustainable Development call to action on human rights to help promote the protection of human rights in business sustainability plans,0,0,0,0,0,0,0,1,0,0,0 991,93,"Developed targeted training for employees with a higher likelihood of contact with modern slavery, such as those in procurement, human resources and site management",0,0,0,0,0,0,0,0,0,0,0 991,94,"Continued to provide an independent hotline available to employees and third parties for anonymously reporting breaches, concerns or asking questions",0,0,0,0,0,0,0,1,0,0,0 991,95,2020 Progress Sims Limited Modern Slavery Statement 2020 | 9,0,0,0,0,0,0,0,0,0,0,0 991,96,"Addressing Operational Risks To help address risks within our operations, we developed both general awareness training and targeted training for employees with a higher likelihood of contact with modern slavery, such as those in procurement, human resources and site management",0,0,0,0,0,0,0,1,0,0,0 3752,48,protecting and growing the Groups client base as more clients seek out businesses with higher ethical standards,0,0,0,0,0,0,0,0,0,0,0 3752,49,improved investor confidence,0,0,0,0,0,0,0,0,0,0,0 3752,50,greater staff retention and loyalty based on values and respect; and,0,0,0,0,0,0,0,0,0,0,0 3752,51,"developing more responsive, stable and innovative supply chains",0,0,0,0,0,0,0,0,0,0,0 3752,52,"Our Supply Chains Currently, due to the Covid 19 pandemic, supply chains are mostly intra Australia",0,0,0,0,0,1,0,0,0,0,0 3752,53,"Our construction operations utilise Australian-based professional services (architects, surveyors) and subcontractors (concreters, tilers, carpenters, bricklayers) local to the Australian project site, where possible",0,0,0,0,0,1,0,0,0,0,0 3752,54,"These operations also use products and raw materials from our suppliers, which are currently Australian-based",0,0,0,0,0,1,0,0,0,0,0 3752,55,Historically we did source materials or products internationally,0,0,0,0,0,1,0,0,0,0,0 7068,89,"Review existing policies, systems and practices to identify areas for improvement and articulate an effective framework for identifying, assessing and addressing risks of modern slavery",0,0,0,0,0,0,0,0,0,1,0 7068,90,"This will be integrated with the Groups risk management framework and will incorporate a mechanism for employees, contractors and members of the public to report instances or risks of modern slavery and unlawful or unethical conduct associated with Finbars operations",0,0,0,0,0,0,0,1,0,0,0 7068,91,Developing procurement and on boarding processes to improve supply chain visibility,0,0,0,0,0,0,0,1,0,0,0 7068,92,"As part of this process, the Company has commenced developing a Supplier Self-Assessment Questionnaire designed to capture supplier information, supporting the identification of potential modern slavery risks and labour rights issues",0,0,0,0,0,0,0,1,0,0,0 7068,93,Suppliers with high risk and low visibility results will be requested to complete a detailed modern slavery and labour rights supplier SAQ,0,0,0,0,0,0,0,1,0,0,0 7068,94,Implementation of supplier minimum standards and incorporation of anti-modern slavery requirements in key supplier contracts,0,0,0,0,0,0,0,1,0,0,0 7068,95,"Undertaking training in respect of risks of modern slavery, actions that can be taken at the time of procurement to minimise the risks and available reporting mechanisms",0,0,0,0,0,0,0,1,0,0,0 7068,96,Measuring effectiveness,0,0,0,0,0,0,0,0,0,0,0 11499,37,"International Labour Organization (ILO), Walk Free, and International Organization for Migration (IOM), 2022",0,0,0,0,0,0,0,0,0,0,0 11499,38,"Global Estimates of Modern Slavery: Forced Labour and Forced Marriage, 13",0,0,0,0,0,0,0,0,0,0,0 11499,39,"As defined in the Australian Modern Slavery Act 2018 (Cth) 3 International Labour Organization (ILO), Walk Free, and International Organization for Migration (IOM), 2022",0,0,0,0,0,0,0,0,0,0,0 11499,40,Global Estimates of Modern Slavery: Forced Labour and Forced Marriage Page 2 of 4 | MCP Wholesale Investments Trust | FY22 Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 11499,41,Page 3 of 4 | MCP Wholesale Investments Trust | FY22 Modern Slavery Statement Risk Assessment Results Supply Chain The Trustees FY22 risk assessment did not identify any high-risk service providers,0,0,0,0,0,0,1,0,0,0,0 11499,42,All service providers are categorised as low to medium as all service providers operate and are domiciled in Australia,0,0,0,0,0,0,1,0,0,0,0 11499,43,Actions to Address Modern Slavery Risks Due Diligence Risk assessment The Trustees annual risk assessment was conducted to assess WITs inherent modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 11499,44,"Supply Chain As the Trustee for the Trust, The Trust Company Limited owns the relationships with the direct service providers which are used by the Trust",0,0,0,0,0,0,0,1,0,0,0 991,97,"By increasing awareness among our employees, we empower them to help us fight these practices",0,0,0,0,0,0,0,0,0,0,0 991,98,Freedom of association is one vehicle to protect the rights for employees,0,0,0,0,0,0,0,1,0,0,0 991,99,Our employees throughout Europe are free to be represented by a works council and/or union without any obligation to report or inform their decision to the company,0,0,0,0,0,0,0,1,0,0,0 991,100,"Given the levels of voluntary disclosure, we estimate approximately 5 percent representation of our UK employee population and less than 5 percent representation for the rest of our European employees following the sale of our electronic compliance scheme operations in the latter half of FY20",0,0,0,0,0,0,0,0,0,1,0 991,101,"Based on disclosed participation, 45 percent of employees in Australia and New Zealand are covered under collective bargaining agreements, and 38 percent in North America",0,0,0,0,0,0,0,0,0,1,0 991,102,All these percentages provide us with a rough estimate that collective bargaining agreements represent approximately 29 percent of our global workforce,0,0,0,0,0,0,0,0,0,1,0 991,103,We have identified Papua New Guinea as presenting a high risk of modern slavery,0,0,0,0,0,0,1,0,0,0,0 991,104,Our efforts to detect and prevent modern slavery in our Papua New Guinea operations take many forms,0,0,0,0,0,0,0,1,0,0,0 3752,56,Our offices use products which may be sourced from overseas such as computers and other office equipment,0,0,0,0,0,1,0,0,0,0,0 3752,57,The MS risk in operations and supply chains of St Hilliers Contracting and any subsidiaries is currently considered to be low,0,0,0,0,0,0,1,0,0,0,0 3752,58,What We Have Done We have: (1) adopted an Anti-Modern Slavery Program; (2) arranged to have the Program externally reviewed at least once a year and more often if there are relevant legislative changes; (3) Included in all our Group construction work contracts (such as Professional services agreements and subcontracts) provisions requiring the other party to comply with relevant Australian anti-modern slavery legislation as well as with St Hilliers Code of Ethical Practice and not be involved in modern slavery; (4) appointed an AMS Officer; (5) undertaken a high-level review of our likely modern slavery risks in our supply chains,0,0,0,0,0,0,0,1,0,1,0 3752,59,"What We Are Working On o making our contractors and suppliers aware that they must not themselves, either directly or through their supply chains, be involved in any facet of modern slavery, that such involvement may result in termination of their contract, and that we may at any time require further information to satisfy us that they have no such involvement",0,0,0,0,0,0,0,1,1,0,0 3752,60,"o making our staff, our contractors and suppliers aware of our Anti-Modern Slavery Policy and that breach of that Policy, our Anti-Modern Slavery Program or the related procedures will be taken seriously and may result in disciplinary action or dismissal",0,0,0,0,0,0,0,1,0,0,0 3752,61,o complying with the law and aiming for best practice,0,0,0,0,0,0,0,0,0,0,0 3752,62,o maintaining a high standard of record keeping to assist in reporting to the regulator and in the investigation of possible modern slavery practices in our supply chain,0,0,0,0,0,0,0,1,0,0,0 3752,63,o continuing to develop our anti modern slavery program and appropriate business unit procedures in order to reflect our current legal obligations from time to time,0,0,0,0,0,0,0,1,0,0,0 7068,97,"As Finbar develops and implements the abovementioned framework for identifying, assessing and addressing risks of modern slavery, it will incorporate processes for monitoring and improving the effectiveness of its actions",0,0,0,0,0,0,0,0,0,0,0 7068,98,Initially these will be focussed on,0,0,0,0,0,0,0,0,0,0,0 7068,99,Quarterly review and reporting to the Board on modern slavery compliance program development,0,0,0,0,0,0,0,0,0,1,0 7068,100,Training completion rates and assessment scores of participants,0,0,0,0,0,0,0,0,0,1,0 7068,101,"The number of suppliers who have been directly engaged, and who have been requested, and completed an SAQ",0,0,0,0,0,0,0,0,0,1,0 7068,102,The numbers of new contracts incorporating supplier minimum standards,0,0,0,0,0,0,0,0,0,1,0 7068,103,Awareness of reporting mechanisms among employees and suppliers,0,0,0,0,0,0,0,0,0,1,0 7068,104,Identification and collaboration with industry groups or communities of interest who are engaged in identifying risks of modern slavery,0,0,0,0,0,0,0,0,0,1,0 11499,45,"Therefore, The Trust Company Limited is subject to the same policies, due diligence and remediation process to address modern slavery as the Perpetual Group",0,0,0,0,0,0,0,1,0,0,0 11499,46,"This includes adherence to our Modern Slavery Framework which sets out the programs, processes and tools in place to ensure compliance with the Modern Slavery Act",0,0,0,0,0,0,0,1,0,0,0 11499,47,The Trust Company Limited employees have taken part in modern slavery training and employees have access to Perpetual Groups grievance mechanism,0,0,0,0,0,0,0,1,0,0,0 11499,48,"Investments (Due Diligence by the Investment Manager) Metrics Credit Partners, the Investment Manager for Trust, remains committed to incorporating Environmental, Social and Governance (ESG) considerations into their investment analysis and decision-making process",0,0,0,0,0,0,0,0,0,0,0 11499,49,Metrics does not knowingly procure any goods or services from suppliers which are involved in modern slavery or environmental and social practices which fall below the standards expected by the community,0,0,0,0,0,0,0,0,0,0,0 11499,50,"Metrics Responsible Investment, Environmental, Social and Governance Policy (ESG Policy) outlines in more details their approach to incorporating responsible investment, environmental, social and governance factors into investment management activities",0,0,0,0,0,0,0,1,0,0,0 11499,51,The ESG Policy incorporates the following key policies,0,0,0,0,0,0,0,1,0,0,0 11499,52,Environment Policy,0,0,0,0,0,0,0,1,0,0,0 991,105,"We support our employees there by paying above minimum wage rates, and by providing lunch daily to all employees",0,0,0,0,0,0,0,1,0,0,0 991,106,"Sims maintains strong environmental, health and safety systems and routinely monitors and assesses them in order to protect people at each of our sites",0,0,0,0,0,0,0,1,0,0,0 991,107,"Employees also have multiple grievance mechanisms they can use for reporting concerns, including our independent third- party hotline, direct access to line managers, and remote access to Human Resources, Legal, Ethics and Compliance, the CEO and the Board of Directors",0,0,0,0,0,0,0,1,0,0,0 991,108,"At minimum, we promote these mechanisms during annual training by prominently displaying hotline posters in high traffic areas and on our intranet",0,0,0,0,0,0,0,1,0,0,0 991,109,"Annual reviews for site managers include an assessment of their core competencies, including showing respect to others and integrity, along with their progress toward stated goals and financial performance",0,0,0,0,0,0,0,0,0,1,0 991,110,"Managers routinely visit the Papua New Guinea sites, informally monitoring and assessing working conditions and managerial behaviour while reviewing operations",0,0,0,0,0,0,0,0,0,1,0 991,111,Executive management from Australia also visited the sites in FY20 to assess operations and observe conditions,0,0,0,0,0,0,0,0,0,1,0 991,112,"As part of our efforts to prevent causing or contributing to practices of modern slavery, we screen and train the agents we use to broker sales in certain regions of the world on our Code of Conduct",0,0,0,0,0,0,0,1,0,0,0 3752,64,The above can be summarised as developing: (a) due diligence obligations to identify the parts of the Groups business and supply chains where there is a MS risk and identify if any modern slavery offence is occurring; (b) employee training and monitoring; (c) establishing remediation processes; and (d) record-keeping obligations to demonstrate the steps taken in relation to the above matters,0,0,0,0,0,0,0,1,0,0,0 3752,65,Photo by Timon Studler on Unsplash,0,0,0,0,0,0,0,0,0,0,0 3752,66,"Risk-Based Approach We adopt a risk-based approach in combatting modern slavery, having regard to the nature, size and complexity of the St Hilliers Group business and the modern slavery risk relevant to the provision of the particular service",0,0,0,0,0,0,0,1,0,0,0 3752,67,"We are working to assess existing risks and the risks of contracting with new contractors or suppliers, and monitor transactions with them, using a risk-based approach which includes: (a) training employees and agents to be alert to Modern Slavery risks; (b) tailoring due diligence processes for contractors or suppliers according to our analysis of the Modern Slavery risk associated with those corporations (or corporate groupings) depending on type of provider, and the services, geographies or supply channels involved; (c) taking internal or external advice as to Modern Slavery risks and adapting policies, procedures, and our Program as appropriate",0,0,0,0,0,0,0,1,0,1,0 3752,68,Board Approval This statement was approved by the Board on 20 May 2021 for lodgement on the Register,1,0,0,0,0,0,0,0,0,0,0 3752,69,Signed,0,0,0,0,0,0,0,0,0,0,0 3752,70,Timothy Gavin Casey Sole Director & Secretary,0,1,0,0,0,0,0,0,0,0,0 3786,0,Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 7068,105,"Consultation Consultation between the Finbar Group occurs primarily in the shared functions and resources, for example the legal, finance and procurement teams are shared across the group",0,0,0,0,0,0,0,0,0,0,1 7068,106,"This has facilitated the assessment process, and ensures that actions taken to identify and address modern slavery risks are consistent across the Finbar entities",0,0,0,0,0,0,0,0,0,0,1 7068,107,Approval Approved by the Board of Finbar Group Limited on 20 December 2021,1,0,0,0,0,0,0,0,0,0,0 7068,108,Darren John Pateman Managing Director,0,1,0,0,0,0,0,0,0,0,0 7068,109,Appendix A This statement applies to Finbar Group Limited (ultimate holding company) and its wholly owned and controlled entities,0,0,0,1,0,0,0,0,0,0,0 7068,110,A listing of those entities as at 30 June 2020 follows,0,0,0,1,0,0,0,0,0,0,0 7068,111,"Company Percentage Ownership Country of Incorporation ACN Registered Office Finbar Group Limited N/A Australia 009 113 473 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 1 Mends Street Pty Ltd 100 Australia 600 082 111 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 2 Homelea Court Springs Pty Ltd 100 Australia 166 992 123 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 31 Rowe Avenue Pty Ltd 100 Australia 162 808 951 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 32 Riversdale Road Pty Ltd 100 Australia 608 160 354 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 36 Chester Avenue Pty Ltd 100 Australia 147 167 084 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 43 McGregor Road Pty Ltd 100 Australia 167 107 075 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 5-7 Harper Terrace Pty Ltd 100 Australia 600 071 056 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 63 Adelaide Terrace Pty Ltd 100 Australia 600 029 070 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 88 Terrace Road Pty Ltd",0,0,0,0,0,0,0,0,0,0,0 7068,112,"Australia 123 678 491 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 96 Mill Point Road Pty Ltd 100 Australia 168 258 455 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 172 Railway Parade West Leederville Pty Ltd 100 Australia 166 342 954 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 175 Adelaide Terrace Pty Ltd 100 Australia 120 144 834 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 239 Great Eastern Highway Pty Ltd 100 Australia 166 919 508 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 241 Railway Parade Pty Ltd 100 Australia 165 413 016 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 262 Lord Street Pty Ltd 100 Australia 147 846 286 Level 6, 181 Adelaide Terrace East Perth, WA, 6004",0,0,0,0,0,0,0,0,0,0,0 11499,53,Social Policy,0,0,0,0,0,0,0,1,0,0,0 11499,54,Governance Policy,0,0,0,0,0,0,0,1,0,0,0 11499,55,Diversity and Inclusion Policy,0,0,0,0,0,0,0,1,0,0,0 11499,56,Modern Slavery Policy,0,0,0,0,0,0,0,1,0,0,0 11499,57,"Responsible Investment Policy Metrics Credit Partners have acknowledged and confirmed that as the Investment Manager for Trust, they have adequate investment due diligence processes in place",0,0,0,0,0,1,0,1,0,0,0 11499,58,Measuring the Effectiveness of Actions Outlined below is the key progress made by the Responsible Entity on behalf of WIT in FY22 and the actions for FY23,0,0,0,0,0,0,0,0,0,0,0 11499,59,FY22 progress,0,0,0,0,0,0,0,0,0,0,0 11499,60,Mapped WIT supply chain to identify the different sectors service providers are from; and,0,0,0,0,0,0,0,1,0,0,0 991,113,Agents are thoroughly vetted via a third-party system for possible sanctions as well as risks of corruption prior to contracting their services,0,0,0,0,0,0,0,1,0,0,0 991,114,"We provide them with our Code of Conduct, and conduct in-depth training on key risk areas such as bribery and fraud",0,0,0,0,0,0,0,1,0,0,0 991,115,They are required to acknowledge their understanding of our Code and their obligation to comply with it,0,0,0,0,0,0,0,1,0,0,0 991,116,We periodically recertify our agents to ensure they continue to meet our standards,0,0,0,0,0,0,0,1,0,1,0 991,117,They have to complete a questionnaire and sign off on our Code of Conduct,0,0,0,0,0,0,0,1,0,0,0 991,118,Safety Safety will always be our first priority,0,0,0,0,0,0,0,0,0,0,0 991,119,Webelieve that all incidents are preventable and we arecommitted to a goalof zero injuries,0,0,0,0,0,0,0,0,0,0,0 991,120,Transparency We ensure a sense of appropriate transparency in everything we do,0,0,0,0,0,0,0,0,0,0,0 3786,1,Modern Slavery Statement FY2020,0,0,0,0,0,0,0,0,0,0,0 3786,2,Solargain PV Pty Ltd 1 Introduction Solargain PV Pty Ltd (ABN 90 132 725 501) is pleased to submit this Modern Slavery Statement pursuant to the Modern Slavery Act 2018 (Cth) in respect of the financial year 1 July 2019 to 30 June 2020 (FY20 Reporting Period),0,0,1,0,0,0,0,0,0,0,0 3786,3,This statement covers the activities of Solargain PV Pty Ltd (ACN 132 725 501) and its owned and controlled entity Solargain (QLD) Pty Ltd (ACN 152 166 160),0,0,0,1,0,0,0,0,0,0,0 3786,4,"In this Modern Slavery Statement, Solargain PV Pty Ltd and its controlled entities are referred to as Solargain",0,0,0,0,0,0,0,0,0,0,0 3786,5,"Addressing modern slavery risks is a business critical issue, as not only is it the right thing to do, it will also improve the integrity and quality of business operations and supply chains",0,0,0,0,0,0,0,0,0,0,0 3786,6,"Structure and Operations Solargain is an Australian Private Company first registered in August 2008, headquartered in Malaga, Western Australia with operations throughout Australia",0,0,0,1,1,0,0,0,0,0,0 3786,7,Solargain is one of the largest integrated solar power and solar hot water companies in Australia,0,0,0,0,1,0,0,0,0,0,0 3786,8,Specialising in residential and commercial retail installations as well as wholesale supply to the renewable energy sector,0,0,0,0,1,0,0,0,0,0,0 7068,113,"James Street Pty Ltd 100 Australia 163 732 812 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 280 Lord Street Pty Ltd 100 Australia 163 025 401 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 Finbar Applecross Pty Ltd 100 Australia 613 769 734 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 Finbar Commercial Pty Ltd 100 Australia 637 052 861 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 Finbar Finance Pty Ltd 100 Australia 124 752 647 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 Finbar Fund Pty Ltd 100 Australia 600 378 783 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 Finbar Karratha Pty Ltd 100 Australia 142 784 192 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 Finbar Port Hedland Pty Ltd 100 Australia 159 884 652 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 Finbar Project Management Pty Ltd 100 Australia 111 730 208 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 Finbar to Rent Pty Ltd 100 Australia 629 248 282 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 Finbar Sales Pty Ltd 100 Australia 640 562 778 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 Finbar Sub 104 Pty Ltd 100 Australia 608 161 057 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 Finbar Sub 107 Pty Ltd 100 Australia 637 051 720 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 Finbar Executive Rentals Pty Ltd 100 Australia 630 981 225 Level 6, 181 Adelaide Terrace East Perth, WA, 6004 Lot 1 to 10 Whatley Crescent Pty Ltd 100 Australia 112 308 933 Level 6, 181 Adelaide Terrace East Perth, WA, 6004",0,0,0,1,0,0,0,0,0,0,0 7068,114,Statement Annexure Principal Governing Body Approval This modern slavery statement was approved by the Board of Finbar Group Limited on 20 December 2021,1,0,0,0,0,0,0,0,0,0,0 7068,115,"Signature of Responsible Member This modern slavery statement was signed by the Managing Director of Finbar Group Limited, Darren John Pateman, on 20 December 2021",0,1,0,0,0,0,0,0,0,0,0 7068,116,"Reporting Entity Pages Identify the reporting entity 3 Describe the structure, operations and supply chain of the reporting entity 34 Describe the risks of modern slavery practices in the operations and supply chain of the reporting entity, and any entities that the reporting entity owns or controls 45 Describe the actions taken by the reporting entity and any entity that the reporting entity owns or controls, to assess and address those risks, including due diligence and remediation processes 56 Describe how the reporting entity assesses the effectiveness of such actions 7 Describe the process of consultation with any entities that the reporting entity owns or controls 7 Any other information that the reporting entity considers relevant 89",0,0,0,0,0,0,0,0,0,0,0 7474,0,L1 CAPITAL LONG SHORT FUND MONTHLY CLASS AND L1 CAPITAL LONG SHORT FUND DAILY CLASS MODERN SLAVERY STATEMENT FOR THE YEAR ENDED 30 JUNE 2021,0,0,0,0,0,0,0,0,0,0,0 7474,1,Table of contents,0,0,0,0,0,0,0,0,0,0,0 7474,2,"Background 3 Structure, operations and supply chains of the reporting entity 3 Our Structure 3 About EQT 3 About L1 Capital Pty Ltd 3 Operations and supply chains 3 Risks of modern slavery practices in operations and supply chains of the reporting entity 4 Actions taken by the reporting entity to assess and address risks, including due diligence and remediation processes",0,0,0,0,0,0,0,0,0,0,0 7474,3,How the reporting entity assesses the effectiveness of actions to assess and address risks 6 Consultation process 6 Other relevant information 6 Approval 6,0,0,0,0,0,0,0,0,0,0,0 11499,61,Conducted annual risk assessment to determine inherent modern slavery risks Actions for FY23,0,0,0,0,0,0,0,1,0,0,0 11499,62,Monitor emerging global trends in modern slavery and include anything relevant for the FY23 risk assessment,0,0,0,0,0,0,0,0,0,1,0 11499,63,Page 4 of 4 | MCP Wholesale Investments Trust | FY22 Modern Slavery Statement Appendix Appendix 1: Australian Modern Slavery Act Mandatory Reporting Criteria The following table describes the location of each mandatory reporting criteria within the FY22 Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 11499,64,"Mandatory Reporting Criteria Location in Statement Identify the reporting entity Reporting Entity, Page 1 Describe the reporting entitys structure, operations, and supply chains Structure, Operations and Supply Chain, Page 1 and 2 Describe the risks of modern slavery practices in the operations and supply chains of the reporting entity and any entities the reporting entity owns or controls Modern Slavery Risks, Page 2 and 3 Describe the actions taken by the reporting entity and any entity that the reporting entity owns or controls to assess and address these risks, including due diligence and remediation processes Actions to Address Modern Slavery Risks, Page 3 Describe how the reporting entity assesses the effectiveness of actions being taken to assess and address modern slavery risks Measuring the Effectiveness of Actions, Page 3 Describe the process of consultation and any entities the reporting entity owns or controls Consultation, Page 1",0,0,0,0,0,0,0,0,0,0,0 11660,0,OBJECTIVE.COM Modern Slavery Statement - 2022 Objective Corporation Limited,0,0,0,0,0,0,0,0,0,0,0 11660,1,Document ID: A2602420 Version: 1.0 Date: 21 December 2022,0,0,0,0,0,0,0,0,0,0,0 11660,2,2022 Copyright Objective Corporation Limited,0,0,0,0,0,0,0,0,0,0,0 11660,3,Commercial in Confidence,0,0,0,0,0,0,0,0,0,0,0 991,121,Integrity We conduct all business with integrity and adhereto the highest standard of ethical business conduct,0,0,0,0,0,0,0,0,0,0,0 991,122,Our core values underpin everything we do how we act and behave,0,0,0,0,0,0,0,0,0,0,0 991,123,| Sims Limited Modern Slavery Statement 2020,0,0,0,0,0,0,0,0,0,0,0 991,124,"Respect We will treat each other,our customers, visitors and community members with respect and dignity",0,0,0,0,0,0,0,0,0,0,0 991,125,Excellence We commit to excellence in everything we do and champion continuous development and sharing of best practices across the company,0,0,0,0,0,0,0,0,0,0,0 991,126,Social Responsibility We aim to be the worlds safest and most responsible recycling andrecovery company,0,0,0,0,0,0,0,0,0,0,0 991,127,Sims Limited Modern Slavery Statement 2020 | 11,0,0,0,0,0,0,0,0,0,0,0 991,128,Addressing Supply Chain Risks Sims activities for detecting and preventing modern slavery in our supply chain focus primarily on due diligence,0,0,0,0,0,0,0,0,0,0,0 3786,9,"Our business covers the supply, installation and servicing of solar PV systems, energy storage systems and hot water systems, as well as the wholesale supply of solar products and the trading of renewable energy certificates",0,0,0,0,1,0,0,0,0,0,0 3786,10,Solargain includes the trading names SG Wholesale and Service My Solar,0,0,0,1,0,0,0,0,0,0,0 3786,11,Currently there is no trading activity in the Solargain (QLD) Pty Ltd entity,0,0,0,0,1,0,0,0,0,0,0 3786,12,"In addition to our direct company operations, Solargain engages a number of small businesses in regional locations throughout Australia as Authorised Distributors",0,0,0,0,0,1,0,0,0,0,0 3786,13,"Solargain employees a diverse range of people in operational, technical, sales, administration and professional roles",0,0,0,0,1,0,0,0,0,0,0 3786,14,"As of 30th June 2020, Solargain had approximately 165 direct employees operating from more than 10 sites across Australia",0,0,0,1,1,0,0,0,0,0,0 3786,15,Our employees are employed under a contract and where applicable in accordance with and reference to relevant awards,0,0,0,0,1,0,0,0,0,0,0 3786,16,Supply Chain The products and services (including labour) that contribute to Solargains products and service offerings include suppliers within Australia and overseas,0,0,0,0,0,1,0,0,0,0,0 7474,4,Background This document is a Modern Slavery Statement (Statement) issued by Equity Trustees Limited ABN 46 004 031 298 (ETL) in its capacity as the responsible entity of the L1 Capital Long Short Fund Monthly Class and the L1 Capital Long Short Fund Daily Class (the Fund) in accordance with the Modern Slavery Act 2018 (Cth) (the Act) and has been approved by the Board of ETL as its principal governing body,1,0,1,0,0,0,0,0,0,0,0 7474,5,"This Statement discloses ETL and the Funds commitment and steps taken in identifying and addressing modern slavery risks within its business and supply chain, which includes the activities we will implement in 2021",0,0,0,0,0,0,0,0,0,0,0 7474,6,"Structure, operations and supply chains of the Reporting Entity Fund Structure The Fund is a registered managed investment scheme, ARSN 615 353 556",0,0,0,1,0,0,0,0,0,0,0 7474,7,ETL is the responsible entity of the Fund,0,0,0,1,0,0,0,0,0,0,0 7474,8,Its investors are classified as retail and wholesale clients pursuant to the Corporations Act (Cth) 2001,0,0,0,0,0,0,0,0,0,0,0 7474,9,The Board of Directors of ETL govern the Funds operations,0,0,0,1,0,0,0,0,0,0,0 7474,10,Its investments and investment strategy are managed by L1 Capital Pty Ltd (L1 Capital) pursuant to an investment management agreement between ETL and L1 Capital,0,0,0,1,0,0,0,0,0,0,0 7474,11,The Fund conducts all business activities in accordance with high levels of ethical and professional standards and in accordance with relevant laws in Australia,0,0,0,0,0,0,0,0,0,0,0 11660,4,PAGE 21 December 2022 | Document ID: A2602420 | OBJECTIVE.COM 2 INTRODUCTION This Modern Slavery Statement (Statement) is prepared by Objective Corporation Limited (ABN 16 050 539 350) and covers the reporting period 1st July 2021 to 30 June 2022 (FY2022),0,0,0,0,0,0,0,0,0,0,0 11660,5,"This is our first Statement under the Australian Modern Slavery Act 2018 (Cth) (Act), which addresses the mandatory criteria set out in section 16 of the Act (Mandatory Criteria)",0,0,0,0,0,0,0,0,0,0,0 11660,6,Objective is committed to acting with integrity in all our business dealings and operations and we fully expect our suppliers to meet the same high standards that we set for ourselves,0,0,0,0,0,0,0,0,0,0,0 11660,7,We have a zero-tolerance attitude to Modern Slavery for ourselves and our supply chain,0,0,0,0,0,0,0,0,0,0,0 11660,8,MODERN SLAVERY STATEMENT MANDATORY CRITERIA,0,0,0,0,0,0,0,0,0,0,0 11660,9,"Identity of reporting entity (Mandatory Criteria 16(1)(a)) For the purposes of the Act, the reporting entity is Objective Corporation Limited (ABN 16 050 539 350) (OCL), whose registered office is at Level 30, 177 Pacific Highway, North Sydney, NSW 2060, Australia",0,0,1,1,0,0,0,0,0,0,0 11660,10,"However, although this Statement is only required for OCL as the reporting entity, it also applies to all of OCLs subsidiary entities, a complete list of which is set out in the attached Annexure A (together referred to as Objective, we, us, our)",0,0,0,0,0,0,0,0,0,0,0 11660,11,"Structure, operations and supply chains (Mandatory Criteria 16(1)(b)) Structure Objective Corporation Limited is an Australian public company, listed on the Australian Securities Exchange (ASX: OCL), and is headquartered in Sydney, Australia",0,0,0,1,0,0,0,0,0,0,0 991,129,"For example, Sims Lifecycle Services performs downstream vendor audits annually on high risk vendors through a combination of desktop and on-site audits",0,0,0,0,0,0,0,0,0,1,0 991,130,"In FY20, 208 vendors were audited remotely and 66 via site visits, providing 89 percent coverage",0,0,0,0,0,0,0,0,0,1,0 991,131,On-site audits are usually conducted every three years,0,0,0,0,0,0,0,0,0,0,0 991,132,"This may be extended to every five years if the vendor can produce evidence of the ongoing effectiveness of its controls, such as passing e-waste certification audits (eg ISO, R2 and NAID)",0,0,0,0,0,0,0,0,0,0,0 991,133,"When chartering vessels, our due diligence focuses on ethics and compliance red flags, including the countries of ownership as well as operation, the registered and beneficial owners, commercial operators, technical managers and if there are any EU, HM Treasury (UK), Office of Assets Control (OFAC) and OFAC non-SDN sanctions against these parties or the vessel in order to ensure the vessel meets our standards for quality and is operated in a manner that respects human rights",0,0,0,0,0,0,0,1,0,0,0 991,134,We include our customers in the selection process so they may ensure the vessel meets their standards as well,0,0,0,0,0,0,0,1,0,0,0 991,135,"We continuously look to improve our processes to identify, address and prevent human rights violations, including modern slavery risks in our operations and our supply chain",0,0,0,0,0,0,0,0,0,0,0 991,136,"In pursuit of this, we issued the Sims Limited Supplier Code of Conduct to codify our expectations for the business conduct of our suppliers and partners",0,0,0,0,0,0,0,1,0,0,0 3786,17,"In FY20, 65 per cent of the total spend was for products manufactured overseas and procured from suppliers with operational representation within Australia or through Australian distributors",0,0,0,0,0,1,0,0,0,0,0 3786,18,"The suppliers we engage with are primarily based on long term arrangements and are located in a number of countries including China, South Korea, Austria, Mexico, Indonesia, Malaysia and Australia",0,0,0,0,0,1,0,0,0,0,0 3786,19,Our supply chain includes the following products and services,0,0,0,0,0,1,0,0,0,0,0 3786,20,Modern Slavery Statement FY2020,0,0,0,0,0,0,0,0,0,0,0 3786,21,"Solargain PV Pty Ltd 2 Support Services accounting and finance services, marketing, IT services, consultants",0,0,0,0,0,1,0,0,0,0,0 3786,22,engineering and legal and procurement,0,0,0,0,0,1,0,0,0,0,0 3786,23,"Construction Installation Services residential and commercial Solar PV, energy storage and hot water systems installations and maintenance Product and Material Supply, including products that are manufactured overseas and supplied either direct from overseas manufacturers or via distributors located in Australia",0,0,0,0,0,1,0,0,0,0,0 3786,24,Solargain does not manufacture any goods itself,0,0,0,0,0,1,0,0,0,0,0 7474,12,The Fund is committed to mitigating the risk of modern slavery in the business and supply chains of the Fund and the assets in which it invests,0,0,0,0,0,0,0,0,0,0,0 7474,13,About Equity Trustees ETL is a wholly owned subsidiary of EQT Holdings Ltd which is a diversified financial services company publicly listed on the Australian Securities Exchange (ASX: EQT),0,0,0,1,0,0,0,0,0,0,0 7474,14,ETL holds an Australian Financial Services Licence (AFSL) no,0,0,0,0,1,0,0,0,0,0,0 7474,15,It acts as a trustee and responsible entity for a range of managed investment schemes and unit trusts of which the Fund is one,0,0,0,0,1,0,0,0,0,0,0 7474,16,"ETLs registered office is Level 1, 575 Bourke Street, Melbourne, VIC 3000, Australia",0,0,0,1,0,0,0,0,0,0,0 7474,17,About L1 Capital L1 Capital is a global investment manager founded L1 Capital in Melbourne in 2007 by Raphael Lamm and Mark Landau with the launch of the Australian Equities strategy,0,0,0,0,1,0,0,0,0,0,0 7474,18,"They have grown the firm through the selective cultivation of new strategies, adding the Long Short equities in 2014, then adding Global Opportunities (multi-strategy hedge fund managed from Miami) in 2015, UK Residential Property (managed from London) in 2017, International Equities (managed from Sydney) in 2018, and Catalyst equities (best ideas, concentrated Australian equities with an activist overlay managed from Melbourne) in 2021",0,0,0,0,1,0,0,0,0,0,0 7474,19,"Today, the firm manages $4.5 billion in funds under management (FuM) for a range of investors including large superannuation funds, pension funds, asset consultants, financial planning groups, family offices, high net worth individuals and retail investors",0,0,0,0,1,0,0,0,0,0,0 11660,12,"All of OCLs subsidiary entities (as at 30 June 2022) are set out in the attached Annexure A, which are each 100% directly owned by OCL",0,0,0,1,0,0,0,0,0,0,0 11660,13,Operations Objective is a leading provider of digital government software solutions that drive stronger communities and nations,0,0,0,0,1,0,0,0,0,0,0 11660,14,"Our solutions offer rich functionality focused on content management, planning and building processes and regulatory compliance",0,0,0,0,1,0,0,0,0,0,0 11660,15,"We develop software solutions to help government workers work smarter with secure access to the information they need to make decisions, anywhere on any device",0,0,0,0,1,0,0,0,0,0,0 11660,16,Our clients are primarily government sector entities including many large departments and agencies but also include commercial entities operating in financial services and highly regulated industries,0,0,0,0,1,0,0,0,0,0,0 11660,17,"As at 30 June 2022, we had a headcount of around 450 people, and our operations included 15 offices globally: Australia: Sydney, Wollongong, Melbourne, Brisbane, Adelaide, Canberra, Perth New Zealand: Wellington, Palmerston North United Kingdom: London, Edinburgh",0,0,0,1,1,0,0,0,0,0,0 11660,18,2022 Copyright Objective Corporation Limited,0,0,0,0,0,0,0,0,0,0,0 11660,19,Commercial in Confidence,0,0,0,0,0,0,0,0,0,0,0 991,137,Our Supplier Code of Conduct can be found at www.simsltd.com/governance/,0,0,0,0,0,0,0,0,0,0,0 991,138,"Working with External Stakeholders Our commitment to respecting, promoting and upholding fundamental human rights goes beyond meeting regulatory requirements",0,0,0,0,0,0,0,0,0,0,0 991,139,"We understand that our business affects human rights through our daily interactions with employees, suppliers, customers, partners and communities",0,0,0,0,0,0,0,0,0,0,0 991,140,We also understand that our business can bring positive change to the lives of people who are affected by our operations,0,0,0,0,0,0,0,1,0,0,0 991,141,That is the reason why our CEO signed the World Business Council for Sustainable Developments Call to Action for Business Leadership on Human Rights to support and promote the realisation of human rights for all,0,0,0,0,0,0,0,1,0,0,0 991,142,We strongly support efforts in our industry to ban practices that enable human rights violations,0,0,0,0,0,0,0,0,0,0,0 991,143,We support the Australian governments efforts to address the issues raised in the final report produced by the black economy taskforce,0,0,0,0,0,0,0,1,0,0,0 991,144,"In todays modern digital economy, there is no need for large cash transactions to take place",0,0,0,0,0,0,0,1,0,0,0 3786,25,"Our material supply chain is represented as: 65% - direct overseas manufacturers/suppliers (all with an Australian office) 5% - products manufactured overseas, sourced though an independent Australian distributor 30% - Generic other supplies and services, including subcontractors and indirect suppliers",0,0,0,0,0,1,0,0,0,0,0 3786,26,Solargain employs its own in-house installers (including electricians and plumbers),0,0,0,0,1,0,0,0,0,0,0 3786,27,"We also rely on the use of independent contractor installers and plumbers, all of whom are small businesses",0,0,0,0,0,1,0,0,0,0,0 3786,28,Modern Slavery Risk Solargain recognises that modern slavery may impact our business activities and we are committed to our responsibility for reducing the risk that we might contribute to modern slavery through parts of our business operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 3786,29,"The majority of Solargains purchases are for solar PV and hot water systems and components, all of which are manufactured overseas",0,0,0,0,0,1,0,0,0,0,0 3786,30,"Due to the products, product raw materials and the manufacturers geographical location these may have higher prevalence of modern slavery risks",0,0,0,0,0,0,1,0,0,0,0 3786,31,"There is also some risk indirectly through the equipment used in corporate services (computers, laptops mobile phones and uniforms and safety equipment)",0,0,0,0,0,0,1,0,0,0,0 3786,32,"From Solargains Australian operational view, the risk of modern slavery in the workforce is low",0,0,0,0,0,0,0,0,0,0,0 7474,20,The firm remains 100% owned by its senior staff,0,0,0,0,1,0,0,0,0,0,0 7474,21,L1 Capital holds an AFSL no,0,0,0,0,1,0,0,0,0,0,0 7474,22,It acts as investment manager for a range of managed investment schemes and unit trusts,0,0,0,0,1,0,0,0,0,0,0 7474,23,"L1 Capitals registered office is Level 28, 101 Collins Street, Melbourne, VIC 3000, Australia",0,0,0,1,0,0,0,0,0,0,0 7474,24,"Operations and supply chains The Funds investment objective is to achieve strong, positive, risk-adjusted returns over the long term (in AUD terms)",0,0,0,0,0,0,0,0,0,0,0 7474,25,The Funds investment strategy is to conduct bottom up company research to identify mispriced securities,0,0,0,0,1,0,0,0,0,0,0 7474,26,The Fund may hold long or short stock positions (or derivatives) to profit from this mispricing,0,0,0,0,1,0,0,0,0,0,0 7474,27,Securities will be listed (or expected to list) on a global stock exchange,0,0,0,0,1,0,0,0,0,0,0 11660,20,"PAGE 21 December 2022 | Document ID: A2602420 | OBJECTIVE.COM 3 United States of America: Marietta GA, Washington DC, Charlotte NC Asia-Pacific: Singapore Our procurement and human resources functions are largely centralised at our Sydney headquarters, which provides us with greater visibility over our supply chain and workforce",0,0,0,0,1,0,0,0,0,0,0 11660,21,Our total revenue for FY2022 was AU$107 million,0,0,0,0,1,0,0,0,0,0,0 11660,22,"Our software solutions are developed, marketed and sold by Objective personnel directly employed by us",0,0,0,0,1,0,0,0,0,0,0 11660,23,We do not outsource any of our software development nor do we operate any call-centres,0,0,0,0,1,1,0,0,0,0,0 11660,24,"Supply Chain Our key suppliers include: data centre IT hosting service providers; technology (eg laptops, monitors, etc.) and internet suppliers; office space landlords; and business software application suppliers, and they are commonly direct suppliers of products and services to us",0,0,0,0,0,1,0,0,0,0,0 11660,25,"In FY2022, we engaged directly with close to 200 suppliers, the vast majority of which were located in either Australia, the United Kingdom or the United States of America",0,0,0,0,0,1,0,0,0,0,0 11660,26,"Risks of modern slavery practices in Objectives operations and supply chain (Mandatory Criteria 16(1)(c)) In 2022, Objectives legal department undertook a risk assessment regarding any possible presence of Modern Slavery in our operations as well as in the operations of our key suppliers",0,0,0,0,0,0,1,0,0,0,0 11660,27,"In respect of our own operations, we did not identify any presence of Modern Slavery",0,0,0,0,0,0,1,0,0,0,0 991,145,"In the Australian scrap metal recycling industry, the widespread use of cash, primarily by small to mid-tier market participants, is a fundamental enabler of illegal activity, such as tax evasion, money laundering and organised crime many of which are linked to human rights violations",0,0,0,0,0,0,0,1,0,0,0 991,146,We work with community partners to help solve challenges,0,0,0,0,0,0,0,0,0,0,0 991,147,"In Australia, we are supporting reconciliation efforts to improve the economic, health and social opportunities for Aboriginal and Torres Strait Islander people and their communities",0,0,0,0,0,0,0,0,0,0,0 991,148,We have developed a REFLECT Reconciliation Action Plan (RAP) with the support of a newly established RAP Working Group that represents employees from the region,0,0,0,0,0,0,0,0,0,0,0 991,149,The Sims Metals RAP was published and shared on the dedicated Respect & Inclusion page on our intranet,0,0,0,0,0,0,0,0,0,0,0 991,150,Information is also included in the regions new hire welcome pack,0,0,0,0,0,0,0,0,0,0,0 991,151,"We are committed to the prohibition and elimination of child, forced and compulsory labour throughout the communities in which we operate",0,0,0,0,0,0,0,1,0,0,0 991,152,Our human rights Downstream vendor audits conducted by Sims Lifecycle Services have included a focus on social responsibility since 2010,0,0,0,0,0,0,0,1,0,0,0 3786,33,"Apart from our direct employees, a large number of our suppliers are subcontractors who are small business operators with a majority of them working within their businesses",0,0,0,0,0,1,0,0,0,0,0 3786,34,We are seeking to engage with suppliers who lack awareness of modern slavery risks in order to help them improve their awareness,0,0,0,0,0,0,0,1,0,0,0 3786,35,Actions and Due Diligence to assess Modern Slavery Risk Solargain is committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain,0,0,0,0,0,0,0,0,0,0,0 3786,36,"Having a direct purchasing relationship with a majority of the manufactures, we request the same high standards from all of our suppliers and other business partners",0,0,0,0,0,0,0,1,0,0,0 3786,37,"Solargain prohibits the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, and we request that our suppliers hold themselves and their suppliers to the same accord",0,0,0,0,0,0,0,1,0,0,0 3786,38,Due Diligence Solargain has undertaken an initial internal risk assessment to identify any key modern slavery risks that exist within our operations and supply chains,0,0,0,0,0,0,0,1,0,0,0 3786,39,Following the risk,0,0,0,0,0,0,0,1,0,0,0 3786,40,Modern Slavery Statement FY2020,0,0,0,0,0,0,0,0,0,0,0 7474,28,"In preparing this statement, the Funds direct supply chain has been considered",0,0,0,0,0,0,0,0,0,0,0 7474,29,"The Funds operations and supply chains involve custody and administration of assets and also include several support functions including marketing and communication and governance, risk and compliance services",0,0,0,0,1,1,0,0,0,0,0 7474,30,These support functions are provided by ETL and other external service providers,0,0,0,0,0,1,0,0,0,0,0 7474,31,Internal policies and procedures in relation to the selection of service providers are followed and service providers are typically selected after a due diligence (financial & operational) process which includes risk assessments and thorough reviews with internal subject matter experts,0,0,0,0,0,0,0,1,0,0,0 7474,32,"ETL, as Responsible Entity of the Fund, has entered into agreements with each of the service providers which govern the nature and scope of the services to the Fund",0,0,0,0,0,1,0,0,0,0,0 7474,33,Mainstream Fund Services Pty Limited is the administrator of the Fund,0,0,0,0,0,1,0,0,0,0,0 7474,34,Credit Suisse Securities (Europe) Limited & Morgan Stanley & Co,0,0,0,0,0,1,0,0,0,0,0 7474,35,International plc are the custodians of the Fund assets,0,0,0,0,0,1,0,0,0,0,0 11660,28,"This was predominantly due to us not outsourcing any software development work, and we have a sophisticated human resources function that is responsible for managing the hire of all employees and contractors",0,0,0,0,0,0,1,0,0,0,0 11660,29,We assessed the risk of Modern Slavery in our operations as low given that our operations require skilled work performed by Objectives employees and contractors,0,0,0,0,0,0,1,0,0,0,0 11660,30,"In respect of our supply chain, we assessed the risk as relatively low, due to: the nature of the goods and services we acquire in connection with our business; us typically contracting directly with the supplier (which provides more visibility over worker arrangements and the types of supply being made and by whom); the operations and nature of most of our suppliers; the highly technical operations and nature of our business; many of our key suppliers have their own anti-Modern Slavery practices and statements; and the fact that the vast majority of our suppliers are primarily located in Australia, the United Kingdom or the United States of America",0,0,0,0,0,0,1,0,0,0,0 11660,31,2022 Copyright Objective Corporation Limited,0,0,0,0,0,0,0,0,0,0,0 11660,32,Commercial in Confidence,0,0,0,0,0,0,0,0,0,0,0 11660,33,"PAGE 21 December 2022 | Document ID: A2602420 | OBJECTIVE.COM 4 However, whilst we see the risk as relatively low, we do acknowledge that there are certain more risk- prone areas in our supply chain, where there is the potential for Modern Slavery to exist, as follows: Office Cleaning: Noting the nature of work in this sector, and the use of less skilled or migrant labour, we acknowledge that there is an inherent risk of labour exploitation with these suppliers; and Hardware Suppliers: whilst most of our hardware suppliers (eg laptop and monitor suppliers) are located in lower risk countries, we note that the manufacturing of the hardware, including some components, may occur in higher risk countries; and there is limited ability to practically determine whether any Modern Slavery exists at the component level",0,0,0,0,0,0,1,0,0,0,0 11660,34,"We manage these risk areas as follows: In regards to Office Cleaning, we typically have to use the office cleaners dictated by the landlord of our offices; however, most of these landlords are large reputable organisations (that have published Modern Slavery statements), and our offices are mostly situated in lower risk countries, so we see the risk as relatively low; and In regards to Hardware Suppliers, we use large reputable global brands of equipment, and rely on their Modern Slavery practices and statements to limit the risk",0,0,0,0,0,0,1,1,0,0,0 11660,35,Actions taken to assess and address risks (Mandatory Criteria 16(1)(d)) Accountability for addressing Modern Slavery risk in our operations and those of our suppliers is multi- departmental,0,0,0,0,0,0,0,0,0,0,0 991,153,"This includes areas such as labour conditions, child labour and compensation systems",0,0,0,0,0,0,0,1,0,0,0 991,154,| Sims Limited Modern Slavery Statement 2020,0,0,0,0,0,0,0,0,0,0,0 991,155,policy reflects our commitment to act ethically and with integrity in all our business relationships and to implement and enforce effective systems and controls to avoid purchasing products that rely on inappropriate labour processes,0,0,0,0,0,0,0,1,0,0,0 991,156,"Assessing Effectiveness A review of the outcomes from Sims due diligence and monitoring programs including hotline reporting, site visits and performance reviews for FY20 did not identify any specific instances of modern slavery harm",0,0,0,0,0,0,1,0,0,1,0 991,157,We have identified potential risk areas within our operations or supply chain as outlined in this statement,0,0,0,0,0,0,0,0,0,0,0 991,158,Impact of COVID-19 The COVID-19 pandemic impacted human rights around the world,0,0,0,0,0,0,1,0,0,0,0 991,159,"While peoples health and safety were obviously impacted, less obvious impacts include: lost incomes; necessary goods becoming scarce; travel and contact restrictions causing people to become isolated, affecting their mental health; formal education becoming challenging or non-existent; and non-emergency medical care becoming more difficult to obtain",0,0,0,0,0,0,1,0,0,0,0 991,160,The related financial pressures made many people more vulnerable to the risks of modern slavery as they sought new sources of income,0,0,0,0,0,0,1,1,0,0,0 3786,41,"Solargain PV Pty Ltd 3 assessment, Solargain is either implementing or improving our process to address these risks",0,0,0,0,0,0,0,1,0,0,0 3786,42,"Solargain undertakes an internal supplier assessment for all major suppliers as part of our due diligence, which is completed on an ongoing and regular basis",0,0,0,0,0,0,0,1,0,0,0 3786,43,"An assessment of modern slavery risk is being incorporated into the supplier assessment, which will include a modern slavery questionnaire to be completed by suppliers and submitted to Solargain annually",0,0,0,0,0,0,0,1,0,0,0 3786,44,"In the FY20 reporting period, major suppliers were requested to advise Solargain in relation to any of their modern slavery risks",0,0,0,0,0,0,0,1,0,0,0 3786,45,The modern slavery assessment will be expanded to contractors in the FY21 reporting period,0,0,0,0,0,0,0,1,0,0,0 3786,46,Solargain also undertakes factory inspections of major suppliers,0,0,0,0,0,0,0,1,0,0,0 3786,47,This is to meet with manufactures and inspect facilities to review quality and ethical practices,0,0,0,0,0,0,0,1,0,0,0 3786,48,"In 2019/2020 this included inspection of facilities in Austria, China, South Korea and Australia",0,0,0,0,0,0,0,1,0,0,0 7474,36,"The administrator and custodians have operations in Australia and a number of international jurisdictions including North America, Europe and Asia, as part of global groups of companies",0,0,0,0,0,1,0,0,0,0,0 7474,37,"Risks of modern slavery practices in operations and supply chains of the Reporting Entity Modern slavery has been defined by the Act to includes eight types of serious exploitation, including",0,0,0,0,0,0,0,0,0,0,0 7474,38,Trafficking in persons,0,0,0,0,0,0,0,0,0,0,0 7474,39,Slavery,0,0,0,0,0,0,0,0,0,0,0 7474,40,Servitude,0,0,0,0,0,0,0,0,0,0,0 7474,41,Forced labour,0,0,0,0,0,0,0,0,0,0,0 7474,42,Forced marriage,0,0,0,0,0,0,0,0,0,0,0 7474,43,Debt bondage,0,0,0,0,0,0,0,0,0,0,0 11660,36,The Board of Directors of OCL is ultimately responsible for Objectives efforts to avoid Modern Slavery in our operations and those of our supply chain,0,0,0,0,0,0,0,1,0,0,0 11660,37,Our legal department has raised awareness at the executive level for senior business managers to support this initiative,0,0,0,0,0,0,0,1,0,0,0 11660,38,"Notwithstanding that the risks of the presence of Modern Slavery in our operations and those of our supply chain are assessed as relatively low, we have taken the following actions to address the risks: Modern Slavery Position Statement: we have provided a copy of this Statement to all of our employees and contractors, globally, and also made it publicly available on all of our websites to raise awareness and as a clear expression of our commitment to avoid the presence of Modern Slavery in our operations and those of our supply chain",0,0,0,0,0,0,1,1,0,0,0 11660,39,"Supplier Code of Conduct: we are in the process of creating a Supplier Code of Conduct (which includes provisions around our expectations and requirement that there is no Modern Slavery within the operations of our suppliers); and this will be published on our websites, again as a clear expression of our commitment to avoiding the presence of Modern Slavery in the operations of our supply chain",0,0,0,0,0,0,0,1,0,0,0 11660,40,"Our legal department manages the engagement of all suppliers, from a contractual perspective, and wherever possible they will require the Supplier Code of Conduct (or anti-Modern Slavery clauses) to form part of our contract with any new supplier going forwards",0,0,0,0,0,0,0,1,0,0,0 11660,41,Modern Slavery Risk Assessment: our legal department performed a Modern Slavery Risk Assessment in respect of our operations as well as our supply chain,0,0,0,0,0,0,0,1,0,0,0 11660,42,"Whistleblowing Policy: we have a well-established Whistleblowing policy, under which concerns about our operations, or those of our supply chain, can be disclosed by Objective workers without fear of retaliation",0,0,0,0,0,0,0,1,0,0,0 11660,43,Modern Slavery Questionnaire / Due Diligence,0,0,0,0,0,0,0,1,0,0,0 991,161,"Recognising this, we implemented precautionary measures for our employees and visitors to keep our sites open, swiftly shifted to working from home arrangements for a large portion of our workforce, and sought to maintain continuity in our commercial arrangements with suppliers to the greatest extent possible",0,0,0,0,0,0,0,1,0,0,0 991,162,"As local jurisdictions imposed lockdowns, our business was particularly affected in the U.S., UK and New Zealand, where we had to close a number of our sites and furlough a number of employees",0,0,0,0,0,0,0,0,0,0,0 991,163,"To alleviate some of the financial burden placed on our employees, we administered all government-provided relief mechanisms available to our employees, and where there were none, introduced company-funded emergency relief programs and continued healthcare coverage for employees negatively impacted",0,0,0,0,0,0,0,0,0,0,0 991,164,Further information on the measures taken can be found in our 2020 Sustainability Report at www.simsltd.com,0,0,0,0,0,0,0,0,0,0,0 991,165,"A number of planned actions were delayed due to employees being furloughed, temporary site closures, and redirecting our focus in taking actions to preserve and protect the company and our employees",0,0,0,0,0,0,0,0,0,1,0 991,166,Sims Lifecycle Solutions completed only 89 percent of the scheduled downstream vendor audits due to travel restrictions and revised priorities,0,0,0,0,0,0,0,0,0,1,0 991,167,Annual Code of Conduct training had been launched in January 2020 and 93% of all employees completed it,0,0,0,0,0,0,0,0,0,1,0 991,168,"However, the resources needed to drive it to 100 percent completion were retasked to supporting our COVID-19 response",0,0,0,0,0,0,0,0,0,1,0 3786,49,Plan for Remediation,0,0,0,0,0,0,0,0,0,0,0 3786,50,"Although Solargain is a major retailer in the Australian solar market, the Australian market only represents 2-3% of the global solar market, and as such we lack leverage over international manufacturers",0,0,0,0,0,0,0,0,0,0,0 3786,51,"In this way, we are reliant on the global renewable energy industry and governments to apply influence over the manufacturers and suppliers policies and processes in relation to modern slavery",0,0,0,0,0,0,0,0,0,0,0 3786,52,"Indirectly however, Solargain through its larger business partnerships is working towards offering only those products where the manufacturers comply with modern slavery obligations",0,0,0,0,0,0,0,1,0,0,0 3786,53,"Where it is identified that a manufacturer has engaged in modern slavery, where unable to work with the supplier to improve their modern slavery practices, Solargain will cease purchasing from that supplier",0,0,0,0,0,0,0,0,1,0,0 3786,54,"Solargain will provide education and training for suppliers as to the existence of the Modern Slavery Act (Cth) and invite them to make their own statements, policies and procedures",0,0,0,0,0,0,0,1,0,0,0 3786,55,We will also provide awareness training to employees to equip them with the knowledge to identify modern slavery risks,0,0,0,0,0,0,0,1,0,0,0 3786,56,Solargain has implemented a Modern Slavery Policy as part of our continued effort to have in place effective systems and controls to ensure modern slavery is not taking place anywhere within our own business or our supply chain,0,0,0,0,0,0,0,1,0,0,0 7474,44,The worst forms of child labour,0,0,0,0,0,0,0,0,0,0,0 7474,45,Deceptive recruiting for labour services,0,0,0,0,0,0,0,0,0,0,0 7474,46,We acknowledge the following types of modern slavery risks and their indicators that can exist in the Funds operations and supply chains as well as in the equity holdings of the Fund,0,0,0,0,0,0,0,0,0,0,0 7474,47,"Sector and industry risk: Certain sectors and industries may have high modern slavery risks because of their characteristics, products and processes",0,0,0,0,0,0,0,0,0,0,0 7474,48,"Indicators of this type of risk include the use of unskilled, temporary or seasonal labour, use of short-term contracts and outsourcing, use of foreign workers or temporary or unskilled labour to carry out functions which are not immediately visible (ie at nighttime) for example, security and cleaning",0,0,0,0,0,0,0,0,0,0,0 7474,49,"In respect of the Fund based on the sectors identified using the Responsible Investment Association, Australasia (RIAA) investor toolkit and the Australian Council of Superannuation Investors (ACSI) Modern Slavery Risks, Rights and Responsibilities: A Guide for Companies and Investors and the Responsible Sourcing Tool, we have identified that the Funds investments are exposed to the following categories that exhibit sector and industry risk: Security and cleaning services Catering services Hotel and other travel services Agricultural and fishing industries Apparel industry Electronics manufacturing and electronics recycling industry",0,0,0,0,0,0,1,0,0,0,0 7474,50,Food and beverage industries Health care Financial services Mining and resources,0,0,0,0,0,0,1,0,0,0,0 7474,51,"Product and services risk: where certain products and services have high modern slavery risks because of the way they are produced, provided or used",0,0,0,0,0,0,0,0,0,0,0 11660,44,2022 Copyright Objective Corporation Limited,0,0,0,0,0,0,0,0,0,0,0 11660,45,Commercial in Confidence,0,0,0,0,0,0,0,0,0,0,0 11660,46,PAGE 21 December 2022 | Document ID: A2602420 | OBJECTIVE.COM 5,0,0,0,0,0,0,0,0,0,0,0 11660,47,"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",0,0,0,0,0,0,0,1,0,0,0 11660,48,This Modern Slavery Questionnaire was provided to our top 20 key suppliers (by spend) that dont already publicly report on Modern Slavery,0,0,0,0,0,0,0,1,0,0,0 11660,49,"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",0,0,0,0,0,0,0,0,0,1,0 11660,50,"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",0,0,0,0,0,0,0,1,0,0,0 11660,51,"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",0,0,0,0,0,0,1,0,0,0,0 991,169,"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",0,0,0,0,0,0,0,0,0,1,0 991,170,These have been incorporated into our future actions and goals for FY21,0,0,0,0,0,0,0,0,0,0,0 991,171,"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",0,0,0,0,0,0,0,0,0,1,0 991,172,"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",0,0,0,0,0,0,0,0,0,0,0 991,173,Sims Limited Modern Slavery Statement 2020 | 13,0,0,0,0,0,0,0,0,0,0,0 991,174,"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",0,0,0,0,0,0,0,1,0,1,0 991,175,Revisions to the policy will be approved by the Board of Directors to underscore the importance of the topic and set expectations,0,0,0,0,0,0,0,1,0,1,0 991,176,"Addressing Operational Risks In FY20, we developed training to educate our personnel on modern slavery",0,0,0,0,0,0,0,1,0,0,0 3786,57,"In addition to the Modern Slavery Policy, Solargain will review and improve any policies and procedures relevant to actions in relation to Modern Slavery",0,0,0,0,0,0,0,0,0,1,0 3786,58,Assessment and Effectiveness Solargain will continue to review the effectiveness of our actions and refine our process for mitigating the risk of modern slavery,0,0,0,0,0,0,0,0,0,0,0 3786,59,Senior management meet annually to consider and review,0,0,0,0,0,0,0,0,0,1,0 3786,60,Whether our modern slavery risks are being appropriately identified and evaluated,0,0,0,0,0,0,0,0,0,1,0 3786,61,- The number of actions that have been implemented in relation to modern slavery,0,0,0,0,0,0,0,0,0,1,0 3786,62,- Supplier evaluations including modern slavery assessments and responses,0,0,0,0,0,0,0,0,0,1,0 3786,63,Modern Slavery Statement FY2020,0,0,0,0,0,0,0,0,0,0,0 3786,64,Solargain PV Pty Ltd 4,0,0,0,0,0,0,0,0,0,0,0 7474,52,We have not identified any significant areas of product services risk in the Funds operations or supply chains,0,0,0,0,0,0,1,0,0,0,0 7474,53,"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",0,0,0,0,0,0,0,0,0,0,0 7474,54,We have analysed the Funds investments in respect of geographic risk and have not identified any areas of significant geographic risk in its investments,0,0,0,0,0,0,1,0,0,0,0 7474,55,"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",0,0,0,0,0,0,0,0,0,0,0 7474,56,We have not identified any instances of entity risk in the Funds investments and suppliers,0,0,0,0,0,0,1,0,0,0,0 7474,57,"Actions taken by the Reporting Entity to assess and address risks, including due diligence and remediation processes",0,0,0,0,0,0,0,0,0,0,0 7474,58,The Reporting Entity is committed to continuously improving awareness and response to the risk of modern slavery in the Funds operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 7474,59,L1 Capital will undertake to do this through the following actions,0,0,0,0,0,0,0,1,0,0,0 11660,52,"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",0,0,0,0,0,0,0,0,1,0,0 11660,53,"Ultimately, we would terminate the relevant supplier arrangement if an appropriate resolution is not achieved",0,0,0,0,0,0,0,0,1,0,0 11660,54,"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",0,0,0,0,0,0,0,0,0,0,0 11660,55,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,0,0,0,0,0,0,0,0,0,0,0 11660,56,"Our legal and procurement teams work together to review our Modern Slavery processes and procedures, to evaluate their effectiveness",0,0,0,0,0,0,0,0,0,0,0 11660,57,"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",0,0,0,0,0,0,1,0,0,0,0 11660,58,"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",0,0,0,0,0,0,1,0,0,0,0 11660,59,"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",0,0,0,0,0,0,0,1,0,0,0 991,177,"In FY21, we will provide the training developed in FY20 to educate all of our personnel on modern slavery",0,0,0,0,0,0,0,1,0,0,0 991,178,"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",0,0,0,0,0,0,0,1,0,0,0 991,179,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,0,0,0,0,0,0,0,0,0,1,0 991,180,"This could include changes to oversight, communication, grievance mechanisms and more",0,0,0,0,0,0,0,0,0,1,0 991,181,Papua New Guinea Our assessment of potential modern slavery risks within our operations led us to revisit the mechanisms in place to report concerns,0,0,0,0,0,0,0,0,0,1,0 991,182,"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",0,0,0,0,0,0,1,1,0,0,0 991,183,Our current service provider does not support the local language spoken by many of our employees,0,0,0,0,0,0,1,1,0,0,0 991,184,We are in process of identifying a reporting tool that allows for anonymous reporting in this local language,0,0,0,0,0,0,0,1,0,0,0 3786,65,"Supplier factory visits, observations, and results of discussions in relation to modern slavery",0,0,0,0,0,0,0,0,0,1,0 3786,66,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,0,0,0,0,0,0,0,0,0,0,0 3786,67,During the 2020-21 financial year we are committed to continually building on and improving our modern slavery approach,0,0,0,0,0,0,0,0,0,0,0 3786,68,Approval,0,0,0,0,0,0,0,0,0,0,0 3786,69,This Statement was approved by the Board of Solargain PV Pty Ltd as the parent entity on 26th March 2021,1,0,0,0,0,0,0,0,0,0,0 3786,70,___________________,0,0,0,0,0,0,0,0,0,0,0 3786,71,____________________ Domenico Mercuri,0,0,0,0,0,0,0,0,0,0,0 3786,72,Wayne Petridis Executive Director and Secretary,0,1,0,0,0,0,0,0,0,0,0 7474,60,screening new outsourced service providers for modern slavery risks and conducting ongoing due diligence,0,0,0,0,0,0,0,1,0,0,0 7474,61,assessing the risks of modern slavery in investment portfolios as part of the investment process,0,0,0,0,0,0,0,1,0,0,0 7474,62,"analysing and understanding the Funds supply chain more deeply, exploring options to work with suppliers and partners on an increasingly collaborative basis",0,0,0,0,0,0,0,1,0,0,0 7474,63,developing measures to assess the effectiveness of the steps taken to enhance the Funds understanding and capacity to identify and address modern slavery risks,0,0,0,0,0,0,0,0,0,1,0 7474,64,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,0,0,0,0,0,0,0,0,0,1,0 7474,65,maintaining a Modern Slavery Register to track any incidents of modern slavery,0,0,0,0,0,0,0,0,0,1,0 7474,66,ensuring that the Fund does not commence commercial arrangements with entities that contravene the UN Guiding Principles on Business and Human Rights,0,0,0,0,0,0,0,1,0,0,0 7474,67,"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",0,0,0,0,0,0,0,0,1,0,0 11660,60,2022 Copyright Objective Corporation Limited,0,0,0,0,0,0,0,0,0,0,0 11660,61,Commercial in Confidence,0,0,0,0,0,0,0,0,0,0,0 11660,62,"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",0,0,0,0,0,0,0,0,0,1,0 11660,63,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,0,0,0,0,0,0,0,0,0,0,1 11660,64,"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",0,0,0,0,0,0,0,0,0,0,1 11660,65,"Additionally, the vast majority of Objectives procurement is managed out of our Sydney headquarters",0,0,0,0,0,0,0,0,0,0,1 11660,66,"Accordingly, this Statement has been prepared in consultation with our procurement team in Sydney",0,0,0,0,0,0,0,0,0,0,1 11660,67,"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",0,0,0,0,0,0,0,0,0,0,1 991,185,2021 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 2020,0,0,0,0,0,0,0,1,0,0,0 991,186,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,0,0,0,0,0,0,0,1,0,0,0 991,187,We will also update our existing supplier contracts in high-risk regions,0,0,0,0,0,0,0,1,0,0,0 991,188,"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",0,0,0,0,0,0,0,1,0,1,0 991,189,"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",0,0,0,0,0,0,0,1,0,1,0 991,190,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,0,0,0,0,0,0,0,1,0,1,0 991,191,We will also define key performance indicators to assess the effectiveness of these new processes,0,0,0,0,0,0,0,0,0,1,0 991,192,"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",0,0,0,0,0,0,0,0,0,0,0 3786,73,Director,0,0,0,0,0,0,0,0,0,0,0 3847,0,"MACH Energy Australia Pty Ltd Suite 1, Level 3, 426 King Street Newcastle West NSW 2302 ACN 603 495 441",0,0,0,0,0,0,0,0,0,0,0 3847,1,t: +61 2 5517 1150 e: info@machenergy.com.au www.machenergyaustralia.com.au,0,0,0,0,0,0,0,0,0,0,0 3847,2,v1Page | 0,0,0,0,0,0,0,0,0,0,0,0 3847,3,MACH Australia Holdings Pty Ltd ACN 608 494 828,0,0,0,0,0,0,0,0,0,0,0 3847,4,MACH Energy Australia Pty Ltd ACN 608 495 441,0,0,0,0,0,0,0,0,0,0,0 3847,5,2020 Modern Slavery Report,0,0,0,0,0,0,0,0,0,0,0 3847,6,/5/2021 0 Approved Michael Howard Jason Culpeper Board Date Rev Status Prepared By Checked By Approved By,0,0,0,0,0,0,0,0,0,0,0 7474,68,"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",0,0,0,0,0,0,0,1,0,0,0 7474,69,"During the Reporting Period, ETL undertook the following actions",0,0,0,0,0,0,0,0,0,0,0 7474,70,updated the annual due diligence questionnaire to include modern slavery questions designed to identify any potential risks in the supply chains of the Fund,0,0,0,0,0,0,0,0,0,0,0 7474,71,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,0,0,0,0,0,0,0,1,0,0,0 7474,72,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,0,0,0,0,0,0,0,0,0,1,0 7474,73,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,0,0,0,0,0,0,0,0,0,1,0 7474,74,"Consultation process There are no subsidiaries or entities owned or controlled by the Reporting Entity, which is a Trust",0,0,0,0,0,0,0,0,0,0,1 7474,75,"However, the Responsible Entity of the Trust and the investment manager of the Trust consult on the preparation of this MSS",0,0,0,0,0,0,0,0,0,0,1 11660,68,Approval of this Statement (Mandatory Criteria 16(2)) This Statement was approved by the Board of Directors of Objective Corporation Limited,1,0,0,0,0,0,0,0,0,0,0 11660,69,Tony Walls Chief Executive Officer Objective Corporation Limited 20 December 2022,0,1,0,0,0,0,0,0,0,0,0 11660,70,2022 Copyright Objective Corporation Limited,0,0,0,0,0,0,0,0,0,0,0 11660,71,Commercial in Confidence,0,0,0,0,0,0,0,0,0,0,0 11660,72,"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%",0,0,0,1,0,0,0,0,0,0,0 11660,73,"* 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",0,0,0,0,0,0,0,0,0,0,0 11820,0,Introduction,0,0,0,0,0,0,0,0,0,0,0 11820,1,"Modern Slavery is an umbrella term that includes practices like slavery, servitude, human trafficking and forced labour",0,0,0,0,0,0,0,0,0,0,0 991,193,We believe that all human beings are born free and equal and should be treated with dignity and respect,0,0,0,0,0,0,0,0,0,0,0 991,194,"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",0,0,0,0,0,0,0,0,0,0,0 991,195,"By working with our employees, shareholders, supply chain and other stakeholders globally, we can drive further accountability to protect vulnerable people from harm",0,0,0,0,0,0,0,0,0,0,0 991,196,This statement was approved by the Sims Limited Board of Directors,1,0,0,0,0,0,0,0,0,0,0 991,197,"Alistair Field CEO and Managing Director, Sims Limited Geoff Brunsdon Chairman of the Board, Sims Limited Sims Limited Modern Slavery Statement 2020 | 15",0,1,0,0,0,0,0,0,0,0,0 991,198,Learn more: www.simsltd.com,0,0,0,0,0,0,0,0,0,0,0 1033,0,NetApp statement on slavery and human trafficking netapp.com /us/legal/ca-senate-bill-657.aspx,0,0,0,0,0,0,0,0,0,0,0 1033,1,"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",0,0,0,0,0,0,0,0,0,0,0 3847,7,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 2020,0,0,0,0,0,0,0,0,0,0,0 3847,8,"The following private, unlisted companies are the reporting entities for the purposes of this report and are referred to collectively as MACH Energy",0,0,1,1,0,0,0,0,0,0,0 3847,9,MACH Australia Holdings Pty Ltd ACN 608 494 828 (MAH); and,0,0,1,1,0,0,0,0,0,0,0 3847,10,MACH Energy Australia Pty Ltd ACN 608 495 441 (MEA) (a controlled subsidiary of MAH),0,0,1,1,0,0,0,0,0,0,0 3847,11,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,0,0,0,0,1,0,0,0,0,0,0 3847,12,The Mount Pleasant assets are owned 95% by MEA and 5% by J.C.D,0,0,0,0,1,0,0,0,0,0,0 3847,13,Australia Pty Ltd (JCDA),0,0,0,0,1,0,0,0,0,0,0 3847,14,"MEA and JCDA, through an unincorporated joint venture, uses two incorporated agents to conduct its business, namely",0,0,0,1,0,0,0,0,0,0,0 7474,76,"For clarity, L1 Capital is not owned or controlled by the issuer of this MSS",0,0,0,0,0,0,0,0,0,0,1 7474,77,Other relevant information No other relevant information for this reporting period,0,0,0,0,0,0,0,0,0,0,0 7474,78,"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",0,1,0,0,0,0,0,0,0,0,0 7474,79,Philip Gentry Chair Date: 23 December 2021,0,1,0,0,0,0,0,0,0,0,0 7474,80,"For clients wishing to discuss this statement, please contact your client service representative",0,0,0,0,0,0,0,0,0,0,0 7474,81,"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",0,0,0,0,0,0,0,0,0,0,0 7474,82,"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",0,0,0,1,1,0,0,0,0,0,0 7474,83,"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",0,0,0,1,1,0,0,0,0,0,0 11820,2,It is a heinous crime and a morally reprehensible act that deprives a person's liberty and dignity for anothers personal or commercial gain,0,0,0,0,0,0,0,0,0,0,0 11820,3,"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",0,0,0,0,0,0,0,0,0,0,0 11820,4,"In accordance with the Modern Slavery Act 2018, Feros Care now meets the threshold requirement for Modern Day Slavery Reporting",0,0,1,0,0,0,0,0,0,0,0 11820,5,"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",0,0,0,0,0,0,0,0,0,0,0 11820,6,Who we are Feros Care is a charitable organisation registered under the Australian Charities and Not-for-Profit Commission Act 2012 (Cth) (ACNC),0,0,0,1,0,0,0,0,0,0,0 11820,7,"Our mission is helping people live healthier, happier, better-connected lives",0,0,0,0,0,0,0,0,0,0,0 11820,8,"For over 30 years, weve been making it happen, both for older Australians and people living with disability",0,0,0,0,0,0,0,0,0,0,0 11820,9,"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",0,0,0,0,1,0,0,0,0,0,0 1033,2,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,0,0,0,0,0,0,0,0,0,0,0 1033,3,"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",0,0,0,0,0,0,0,1,0,0,0 1033,4,"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",0,0,0,0,0,0,0,1,0,0,0 1033,5,"The RBA Code prohibits the use of forced labor, including bonded, indentured labor or involuntary prison labor, human trafficking, and child labor",0,0,0,0,0,0,0,0,0,0,0 1033,6,"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",0,0,0,0,0,0,0,0,0,0,0 1033,7,The RBA Code contains specific requirements covering slavery and human trafficking and encompasses a broader vision than simply the elimination of human trafficking,0,0,0,0,0,0,0,0,0,0,0 1033,8,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,0,0,0,0,0,0,0,0,0,0,0 1033,9,"In addition to these actions, NetApp participates in RBA activities",0,0,0,0,0,0,0,1,0,0,0 3847,15,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,0,0,0,1,0,0,0,0,0,0,0 3847,16,MACH Mount Pleasant Marketing Pty Ltd ACN 625 627 965 (a wholly owned subsidiary of MEA) for logistics and sales functions,0,0,0,1,0,0,0,0,0,0,0 3847,17,Annexure A contains an overview of the corporate structure of the group,0,0,0,0,0,0,0,0,0,0,0 3847,18,Structure and Operations overview MACH Energy is in the business of developing and operating economical and efficient energy sources,0,0,0,0,1,0,0,0,0,0,0 3847,19,"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",0,0,0,0,1,0,0,0,0,0,0 3847,20,"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)",0,0,0,0,1,0,0,0,0,0,0 3847,21,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 2022,0,0,0,0,0,0,0,0,0,0,0 3847,22,R2P involves the construction of several kilometers of track as well as new materials handling infrastructure and a new train load out facility,0,0,0,0,1,0,0,0,0,0,0 7476,0,LAKEHOUSE SMALL COMPANIES FUND MODERN SLAVERY STATEMENT FOR THE YEAR ENDED 30 JUNE 2021,0,0,0,0,0,0,0,0,0,0,0 7476,1,Table of contents,0,0,0,0,0,0,0,0,0,0,0 7476,2,"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",0,0,0,0,0,0,0,0,0,0,0 7476,3,How the Lakehouse Small Companies Fund assesses the effectiveness of actions to assess and address risks 7 Consultation process 7 Other relevant information 7 Approval 8,0,0,0,0,0,0,0,0,0,0,0 7476,4,Background This document is a Modern Slavery Statement (Statement) made pursuant to section 14 of the Modern Slavery Act 2018(Cth) (the Act)in respect to the financial year ending 30 June 2021 (the Reporting Period) in relation to Lakehouse Small Companies Fund a Reporting Entity under the Act,0,0,1,0,0,0,0,0,0,0,0 7476,5,"The Statement is issued by Equity Trustees Limited ABN 46 004 031 298 (ETL or Responsible Entity) in its capacity as the Responsible Entity of the Reporting Entity in accordance with the Act and has been approved by the Board of ETL as their principal governing body This Statement discloses ETL and the Funds commitment and steps taken in identifying and addressing modern slavery risks within its business and supply chain, which includes the activities implemented in financial year ending 30 June 2021",1,0,0,0,0,0,0,0,0,0,0 7476,6,This is the first Statement for the Lakehouse Small Companies Fund,0,0,0,0,0,0,0,0,0,0,0 7476,7,"Structure, operations and supply chains of the Reporting Entity Fund Structure Lakehouse Small Companies Fund (also referred to as the Fund) is a registered managed investment scheme, ARSN 615 265 864",0,0,0,1,0,0,0,0,0,0,0 11820,10,"Our sister human services organisation, Aspire4Life, tailor inclusive planning, assessment and case management services which have the needs of the individual at their core and are delivered with respect and understanding",0,0,0,0,1,0,0,0,0,0,0 11820,11,Our service footprint covers six states and territories across eastern and southern Australia,0,0,0,0,1,0,0,0,0,0,0 11820,12,"As a result, Feros Care is supported by over a combination of direct employees, volunteers and a range of workforce contractors and suppliers of goods and services",0,0,0,0,1,0,0,0,0,0,0 11820,13,Our supply chains Feros Care procures goods and services needed for completion of day-to-day activities from a range of contracted and preferred suppliers operating in Australia,0,0,0,0,0,1,0,0,0,0,0 11820,14,"Our long-term, strategic relationships with key service partners, contractors and suppliers provide a level of stability in our supply chain and procurement processes",0,0,0,0,0,1,0,0,0,0,0 11820,15,"Our supplier selection and on- boarding procedures includes due diligence of the suppliers reputation, respect for the law, compliance with health, safety and environmental standards, and references",0,0,0,0,0,0,0,1,0,0,0 11820,16,Our supply chain arrangements include contractors and suppliers from the following key areas,0,0,0,0,0,1,0,0,0,0,0 11820,17,"Corporate Procurement inclusive of goods and services such as stationary, consumables, office equipment and information technology",0,0,0,0,0,1,0,0,0,0,0 1033,10,NetApps internal policies and practices incorporate key concepts of the RBA Code and are consistent with international labor and human rights standards,0,0,0,0,0,0,0,1,0,0,0 1033,11,NetApp is committed to complying with the changes to the U.S,0,0,0,0,0,0,0,1,0,0,0 1033,12,"Governments Federal Acquisition Regulation with regard to Ending Trafficking in Persons, and we expect our suppliers to comply",0,0,0,0,0,0,0,1,0,0,0 1033,13,(See our Purchasing Policy: Combating Trafficking in Persons.) We work with our supply chain to promote an environment in which workers may freely choose employment,0,0,0,0,0,0,0,1,0,0,0 1033,14,This focus on labor and worker rights is part of a larger effort around supply chain transparency and accountability,0,0,0,0,0,0,0,0,0,0,0 1033,15,"Structure, operations, and supply chain organization NetApp is a provider of storage and data management solutions for data-intensive enterprises",0,0,0,0,1,0,0,0,0,0,0 1033,16,"NetApp storage solutions include specialized hardware, software, and services for open network environments",0,0,0,0,1,0,0,0,0,0,0 1033,17,"We use a multichannel distribution strategy: We sell our products, solutions, and services to end-user business customers and service providers through a direct sales force and an ecosystem of partners",0,0,0,0,1,0,0,0,0,0,0 3847,23,"MACH Energy employs approximately 40 people to manage its operations by providing support through finance, human resources, environment, safety, legal, marketing, logistics, and sales functions",0,0,0,1,1,0,0,0,0,0,0 3847,24,"MACH Energys corporate (and registered) office is located in Newcastle West, NSW but personnel are also based at Mount Pleasant and in Brisbane, QLD",0,0,0,1,0,0,0,0,0,0,0 3847,25,"Description of the Supply chain By way of overview, Mount Pleasants supply chain consists of the following broad categories of suppliers",0,0,0,0,0,1,0,0,0,0,0 3847,26,"Main contractors, who are responsible for mining, coal handling and washing, transport and export of coal",0,0,0,0,0,1,0,0,0,0,0 3847,27,"Other suppliers, who are responsible for various functions at an operational and/or corporate level; and",0,0,0,0,0,1,0,0,0,0,0 3847,28,"Suppliers to R2P, who are delivering this important infrastructure construction project",0,0,0,0,0,1,0,0,0,0,0 3847,29,"Main Contractors Open cut coal mining at Mount Pleasant is conducted by Thiess Pty Ltd under a mining services contract, which represents the most significant spend for MACH Energy",0,0,0,0,0,1,0,0,0,0,0 3847,30,Operation of the coal handling and preparation plant and train load out facility is the responsibility of Sedgman Pty Ltd under an operate and maintain services contract,0,0,0,0,0,1,0,0,0,0,0 7476,8,ETL is the responsible entity of the Fund,0,0,0,1,0,0,0,0,0,0,0 7476,9,Its investors are classified as retail and wholesale clients pursuant to the Corporations Act (Cth) 2001,0,0,0,1,0,0,0,0,0,0,0 7476,10,The Board of Directors of ETL govern the Funds operations,0,0,0,1,0,0,0,0,0,0,0 7476,11,Its investments and investment strategy are managed by Lakehouse Capital Pty Ltd (Lakehouse) pursuant to an Investment Management Agreement (IMA) between ETL and Lakehouse,0,0,0,1,0,0,0,0,0,0,0 7476,12,The business activities of the Fund are conducted in accordance with high levels of ethical and professional standards and in accordance with relevant laws in Australia,0,0,0,0,0,0,0,0,0,0,0 7476,13,The Fund is committed to mitigating the risk of modern slavery in the business and supply chains of the Fund and the assets in which it invests,0,0,0,0,0,0,0,0,0,0,0 7476,14,About Equity Trustees ETL is a wholly owned subsidiary of EQT Holdings Ltd which is a diversified financial services company publicly listed on the Australian Securities Exchange (ASX: EQT),0,0,0,1,0,0,0,0,0,0,0 7476,15,ETL holds an Australian Financial Services Licence (AFSL) no,0,0,0,1,0,0,0,0,0,0,0 11820,18,"Operational Procurement inclusive of goods and services required for the care of our residents living in our villages and for our in-home community clients, personal protective equipment, linen, recruitment and training, labour hire contractors and agencies; and",0,0,0,0,0,1,0,0,0,0,0 11820,19,"Capital Works & Property including building material, equipment, body corporate and construction related services",0,0,0,0,0,0,0,0,0,0,0 11820,20,Risk assessment,0,0,0,0,0,0,0,0,0,0,0 11820,21,"Feros Care believes there is minimal risk of modern slavery in our directly employed workforce due to the existing protections and regulations in the Fair Work Act that apply to the assessment, aged care and disability support sectors, along with the presence of unions who represent employees by negotiating employment conditions",0,0,0,0,0,0,1,0,0,0,0 11820,22,"The same protections and regulations are also applicable to our preferred service partners and contractors who operate in these sectors, further reducing any risk",0,0,0,0,0,0,1,0,0,0,0 11820,23,Feros Care commenced the process of conducting a risk assessment of our supply chain once we identified we met the threshold requirement for reporting,0,0,0,0,0,0,0,0,0,0,0 11820,24,"We initially embarked on a staged approach to assessing and mapping our supply chain, commencing with our top 50 suppliers",0,0,0,0,0,0,0,1,0,0,0 11820,25,We have assessed the business services rendered by these suppliers and whether they currently report and meet Modern Day Slavery reporting requirements,0,0,0,0,0,0,0,1,0,0,0 1033,18,NetApp outsources manufacturing operations to third parties located in different countries around the world,0,0,0,0,0,1,0,0,0,0,0 1033,19,"We rely on a limited number of suppliers for materials, as well as several key subcontractors for the production of certain subassemblies and finished systems",0,0,0,0,0,1,0,0,0,0,0 1033,20,The reporting entity for the purposes of the Australian Modern Slavery Act 2018 (Cth) is NetApp Australia Pty Ltd (NetApp Australia),0,0,1,0,0,0,0,0,0,0,0 1033,21,NetApp Australia is a marketer and distributor of NetApp products in the Australian market and a provider of postsales customer support and consultancy services,0,0,0,0,1,0,0,0,0,0,0 1033,22,"NetApp Australia uses external vendors, such as marketing, professional services, real estate, and facilities suppliers, which are largely contracted through a third party",0,0,0,1,0,1,0,0,0,0,0 1033,23,It does not own or control any other legal entities,0,0,0,1,0,0,0,0,0,0,0 1033,24,"Certification and verification NetApp has taken actions to ensure transparency and to prevent abuses in our supply chain, including the following",0,0,0,0,0,0,0,0,0,0,0 1033,25,Supplier Code of Conduct,0,0,0,0,0,0,0,1,0,0,0 3847,31,The transport of coal from Mount Pleasant to either domestic customers or the Newcastle port (for export customers) is performed by Aurizon and Australian Rail Track Corporation (ARTC) under a long term contracts with MEA,0,0,0,0,0,1,0,0,0,0,0 3847,32,The rights to use either of the two coal storage and ship loading facilities at the Newcastle Port are contained in contracts with each of Newcastle Coal Infrastructure Group (NCIG) or Port Waratah Coal Services (PWCS),0,0,0,0,0,1,0,0,0,0,0 3847,33,Annexure B contains a diagrammatic representation of these main contractor activities,0,0,0,0,0,0,0,0,0,0,0 3847,34,"MACH Energy is only responsible for supplying coal to its customers on a free on board basis, meaning it does not charter vessels",0,0,0,0,1,1,0,0,0,0,0 3847,35,The main contractors referred to in this section are all Australian based and predominantly Australian owned entities,0,0,0,0,0,1,0,0,0,0,0 3847,36,These contractors have reporting responsibilities under the Modern Slavery Act and MACH Energy intends to engage more deeply with them in the next reporting period,0,0,0,0,0,0,0,1,0,0,0 3847,37,Other Suppliers MACH Energy directly engages many other suppliers of goods and services across its business to support its open cut coal mining operation at Mount Pleasant,0,0,0,0,0,1,0,0,0,0,0 3847,38,These suppliers can be grouped into the following categories,0,0,0,0,0,1,0,0,0,0,0 7476,16,It acts as a trustee and responsible entity for a range of managed investment schemes and unit trusts of which the Fund is one,0,0,0,1,0,0,0,0,0,0,0 7476,17,"ETLs registered office is Level 1, 575 Bourke Street, Melbourne, VIC 3000, Australia",0,0,0,1,0,0,0,0,0,0,0 7476,18,About Lakehouse Capital Pty Ltd Lakehouse is a proprietary limited company registered in Australia,0,0,0,1,0,0,0,0,0,0,0 7476,19,Lakehouse is wholly owned by The Motley Fool Australia Pty Ltd which is itself ultimately 100% owned by The Motley Fool Holdings (TMF),0,0,0,1,0,0,0,0,0,0,0 7476,20,Lakehouse holds an AFSL 526842,0,0,0,1,0,0,0,0,0,0,0 7476,21,It acts as investment manager for two managed investment schemes,0,0,0,1,0,0,0,0,0,0,0 7476,22,"Lakehouses registered office is Suite 3, Level 9, 20 Hunter Street, Sydney NSW 2000, Australia and employs 12 workers",0,0,0,1,0,0,0,0,0,0,0 7476,23,Operations and supply chains The Funds investment objective is to outperform the S&P/ASX Small Ordinaries Accumulation Index over rolling 5-year periods (after fees and expenses but before taxes),0,0,0,0,1,0,0,0,0,0,0 11820,26,"To date, we have identified that a significant number are already working towards or are compliant with the requirements of the Modern Slavery Act, as evidenced by publicly available policy and modern slavery statements The Procurement team has also commenced implementing initial measures to include screening of modern slavery into procurement processes",0,0,0,0,0,0,0,1,0,0,0 11820,27,Policies,0,0,0,0,0,0,0,0,0,0,0 11820,28,Feros Care is currently implementing or revising the following policies to support our approach to reducing the risk of modern slavery in our operations,0,0,0,0,0,0,0,1,0,0,0 11820,29,"Whistle Blower Protection Policy - We encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation",0,0,0,0,0,0,0,1,0,0,0 11820,30,Code of Conduct - Our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business,0,0,0,0,0,0,0,1,0,0,0 11820,31,We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain,0,0,0,0,0,0,0,1,0,0,0 11820,32,"Organisational Sustainability Policy We uphold a commitment to practices and standards designed to promote economic, social and environmentally responsible operations with the aim of achieving a holistic practice and culture of organisational sustainability whilst meeting its core purpose",0,0,0,0,0,0,0,1,0,0,0 11820,33,Procurement Policy We will revise to formally include modern slavery clauses that will also be applied to operational processes,0,0,0,0,0,0,0,1,0,0,0 1033,26,"NetApps Supplier Code of Conduct is aligned with the RBA Code and incorporates its key sections, including workers rights, the eradication of forced labor, working conditions, and supplier accountability and reporting of nonconformance",0,0,0,0,0,0,0,1,0,0,0 1033,27,"NetApp encourages and, in some cases, requires suppliers to adhere to the RBA Code of Conduct, including implementing a management system and audits and completing the RBA Self-Assessment Questionnaire (SAQ)",0,0,0,0,0,0,0,1,0,0,0 1033,28,"The SAQ, which includes an assessment of the suppliers policies and practices, helps NetApp identify whether any human trafficking risks exist",0,0,0,0,0,0,0,1,0,0,0 1033,29,NetApp expects its suppliers to read and abide by the standards outlined in NetApps Supplier Code of Conduct (including the suppliers to its Australian operations),0,0,0,0,0,0,0,1,0,0,0 1033,30,NetApp supplier and partner agreements,0,0,0,0,0,0,0,1,0,0,0 1033,31,Compliance with the RBA Code is part of NetApps standard contract language,0,0,0,0,0,0,0,1,0,0,0 1033,32,Where NetApp contracts with services suppliers who participate in a U.S,0,0,0,0,0,0,0,1,0,0,0 1033,33,"Government contract or subcontract, it flows down applicable clauses to its suppliers, such as FAR Clause 52.222-50, Combating Trafficking in Persons",0,0,0,0,0,0,0,1,0,0,0 3847,39,"Site maintenance including services such as weed and pest management, waste removal, dust suppression, water pumping, catering, supply of personal protective equipment, and cleaning",0,0,0,0,0,1,0,0,0,0,0 3847,40,"Site infrastructure such as civil works, road construction and maintenance, carpark (re)surfacing, site drainage, erosion and sediment control, and other similar services",0,0,0,0,0,1,0,0,0,0,0 3847,41,Energy such as electricity and fuel supplies,0,0,0,0,0,1,0,0,0,0,0 3847,42,"Communications including data and phone, information technology, records management and real time environmental monitoring systems",0,0,0,0,0,1,0,0,0,0,0 3847,43,"Specialist consultants including engineers, designers, tenement managers, environmental scientists, air quality analysts, and environmental auditors",0,0,0,0,0,1,0,0,0,0,0 3847,44,"Critical spare parts for the wash plant, train load out facility and materials handling infrastructure",0,0,0,0,0,1,0,0,0,0,0 3847,45,"Residential property maintenance for MACH Energys various residential land holdings there are services such as real estate managers, builders, demolition contractors, and valuers",0,0,0,0,0,1,0,0,0,0,0 3847,46,"Mining analysis this includes geological services, exploration drilling, mine planning and project management services",0,0,0,0,0,1,0,0,0,0,0 7476,24,The Funds investment strategy is to invest in a high conviction portfolio of 15 to 30 small companies listed in Australia and New Zealand,0,0,0,0,1,0,0,0,0,0,0 7476,25,"The investible universe consists of companies outside the S&P/ASX 100, though the Fund may continue to hold companies that grow into the ASX 100 as letting winners run is part of the Funds long-term strategy",0,0,0,0,1,0,0,0,0,0,0 7476,26,The Funds investment management operations include active investments across listed equities in Australia and New Zealand,0,0,0,0,1,0,0,0,0,0,0 7476,27,These are managed by one investment manager relationship domiciled in a single country (ie Australia),0,0,0,0,1,0,0,0,0,0,0 7476,28,The investment manager forms part of the Funds supply chain and is listed on the Funds website here https://www.lakehousecapital.com.au/lscf/,0,0,0,0,0,1,0,0,0,0,0 7476,29,"In preparing this statement, the Funds direct supply chain has been considered",0,0,0,0,0,0,0,0,0,0,0 7476,30,"The Funds operations and supply chains involve custody and administration of assets and also include several support functions including marketing and communication, governance, risk and compliance services and human resources",0,0,0,0,1,1,0,0,0,0,0 7476,31,These support functions are provided by ETL and other external service providers,0,0,0,0,0,1,0,0,0,0,0 11820,34,Future Commitments,0,0,0,0,0,0,0,1,0,0,0 11820,35,"In the next 12 months, Feros Care commits to the following actions",0,0,0,0,0,0,0,0,0,0,0 11820,36,"Map and assess all suppliers to determine the response and risk controls to be implemented, including",0,0,0,0,0,0,0,1,0,0,0 11820,37,consider the services rendered by the suppliers and the location of where any supplies are manufactured,0,0,0,0,0,0,0,1,0,0,0 11820,38,"the risk profile of the locations where the supplier operates or the location of where the supplies are manufactured, to determine a risk profile based on the Global Slavery Index; and",0,0,0,0,0,0,0,1,0,0,0 11820,39,whether there is a risk of the presence of vulnerable demographic groups,0,0,0,0,0,0,0,1,0,0,0 11820,40,"Update our standard procurement agreements to include contractual obligations to address modern slavery compliance for all new and existing service partners, contractors and suppliers",0,0,0,0,0,0,0,1,0,0,0 11820,41,"Develop awareness education for the workforce and our clients, residents and participants in relation to their role in eliminating modern slavery",0,0,0,0,0,0,0,1,0,0,0 1033,34,Supplier risk assessments and audits,0,0,0,0,0,0,0,1,0,0,0 1033,35,"NetApp uses the RBA assessment process to identify the risks of noncompliance by RBA member suppliers with NetApps Supplier Code of Conduct and RBA Code, including the actual or potential risks of slavery and human trafficking occurrences",0,0,0,0,0,0,0,1,0,0,0 1033,36,"As a part of NetApps overall participation in the RBA's collaborative audit effort, we expect RBA member suppliers to annually assess their conformance with the tenets of the Supplier Code of Conduct and RBA Code",0,0,0,0,0,0,0,1,0,0,0 1033,37,Completion of the RBA SAQ includes an assessment of the suppliers policies and practices that may give rise to human trafficking risks,0,0,0,0,0,0,0,1,0,0,0 1033,38,"NetApp may also require audits of RBA member suppliers, via a third party, if deemed necessary to verify their conformance to the RBA Code and related standards and policies",0,0,0,0,0,0,0,0,0,1,0 1033,39,"Third-party audits follow the RBA Validated Audit Process (VAP), which includes an assessment of the suppliers risks and controls regarding human trafficking",0,0,0,0,0,0,0,0,0,1,0 1033,40,"If nonconformance is identified, we monitor the suppliers activities to develop corrective action plans and close audit findings",0,0,0,0,0,0,0,0,1,0,0 1033,41,"For the purposes of the Australian Modern Slavery Act 2018 (Cth), NetApp Australia has carried out a modern slavery risk assessment and has assessed that there is a low risk of modern slavery practices in its operations and supply chains",0,0,0,0,0,0,1,0,0,0,0 3847,47,"Corporate services such as legal advisers, accountants, auditors, office accommodation, stationery, telecommunications, IT services, and specialist consultants",0,0,0,0,0,1,0,0,0,0,0 3847,48,"Travel air travel, hotel accommodation, taxis, and car hire services",0,0,0,0,0,1,0,0,0,0,0 3847,49,"Suppliers to Rail 2 Project (R2P) The supply chain for the R2P consists of a project management function (known as the owners team) that oversees a number of sub-projects, or packages",0,0,0,0,0,1,0,0,0,0,0 3847,50,The owners team is made up of a third party project management contractor that oversees a team of personnel that are either MACH Energy employees or contractors,0,0,0,0,0,1,0,0,0,0,0 3847,51,This model of construction contract is not uncommon and allows the owners team greater control over budget and schedule by individually managing the multiple contractors delivering each package,0,0,0,0,0,1,0,0,0,0,0 3847,52,The R2P packages are as follows,0,0,0,0,0,1,0,0,0,0,0 3847,53,"Materials handling consisting of the fabrication and supply of an overland conveyor and train load out facility together with associated civil works, electrical and commissioning services",0,0,0,0,0,1,0,0,0,0,0 3847,54,Rail loop this is the principal element of R2P consisting of civil works and track building of the approximately 5km long private siding,0,0,0,0,0,1,0,0,0,0,0 7476,32,Internal policies and procedures in relation to the selection of service providers are followed and service providers are typically selected after a due diligence (financial & operational) process which includes risk assessments and thorough reviews with internal subject matter experts,0,0,0,0,0,0,0,0,0,0,0 7476,33,"ETL, as Responsible Entity of the Fund, has entered into agreements with each of the service providers which govern the nature and scope of the services to the Fund",0,0,0,0,0,1,0,0,0,0,0 7476,34,"Administration and Custody of the Funds assets are held via Mainstream Fund Services Pty Ltd which has operations in Australia and a number of international jurisdictions including North America, Europe and Asia",0,0,0,0,0,1,0,0,0,0,0 7476,35,"Risks of modern slavery practices in operations and supply chains of the Reporting Entity Modern slavery has been defined by the Act to includes eight types of serious exploitation, including",0,0,0,0,0,0,0,0,0,0,0 7476,36,Trafficking in persons,0,0,0,0,0,0,0,0,0,0,0 7476,37,Slavery,0,0,0,0,0,0,0,0,0,0,0 7476,38,Servitude,0,0,0,0,0,0,0,0,0,0,0 7476,39,Forced labour,0,0,0,0,0,0,0,0,0,0,0 11820,42,"Revise and develop our compliance to modern slavery to build capacity within the organisation to monitor, and act on modern slavery risk",0,0,0,0,0,0,0,0,0,1,0 11820,43,"Develop a set of key performance indicators and controls to measure our performance in combatting modern slavery, inclusive of reporting frequency and audiences",0,0,0,0,0,0,0,0,0,1,0 11820,44,"Feros Care and Aspire4Life will manage modern day slavery through their risk management framework, policy and procedures and will consult with and report modern slavery to their respective governing bodies",0,0,0,0,0,0,0,0,0,1,0 11820,45,Process of Consultations,0,0,0,0,0,0,0,0,0,0,0 11820,46,The Board of Feros Care has consulted with the Executive Leadership and endorses the approach and activities taken by the organisation in order to mitigate against any risks of modern day slavery,0,0,0,0,0,0,0,0,0,0,0 11820,47,This statement has been prepared by the Executive and the Board have consulted with the Executive and will continue to consult with the Executive in relation to the organisations activities to identify modern day slavery risks and eliminate modern day slavery practices,0,0,0,0,0,0,0,0,0,0,0 11820,48,Signed on behalf of the Executive of Feros Care,0,1,0,0,0,0,0,0,0,0,0 11820,49,"Karen Crouch, CEO",0,0,0,0,0,0,0,0,0,0,0 1033,42,"Due to the nature and structure of its operations and supply chains, NetApp Australia relies on the actions taken at a global level to assess and address any risks identified",0,0,0,0,0,0,0,0,0,0,0 1033,43,"The specific steps that NetApp Australia has determined to take to respond to its low level of risk are outlined in Training and Awareness, below",0,0,0,0,0,0,1,0,0,0,0 1033,44,"Given that this is the first year that NetApp Australia has reported under the modern slavery legislation, they will assess the effectiveness of these steps before the next reporting period",0,0,0,0,0,0,0,0,0,0,0 1033,45,Assessment of effectiveness,0,0,0,0,0,0,0,0,0,0,0 1033,46,NetApp reviews the scores of the SAQ completed by its suppliers who are members of the RBA to confirm that they are not deemed to be a high risk,0,0,0,0,0,0,0,0,0,1,0 1033,47,NetApp Australia relies on the assessment of NetApp and does not carry out additional assessments,0,0,0,0,0,0,0,0,0,1,0 1033,48,"Internal Accountability NetApps Code of Conduct, which contains specific provisions on procurement from suppliers, vendors, contractors, and supply chain relationships, provides guidance to enable employees to put our companys values into practice",0,0,0,0,0,0,0,1,0,0,0 1033,49,It is available in seven languages on NetApps intranet and in English on our companys external website,0,0,0,0,0,0,0,1,0,0,0 3847,55,"Signalling owing to its complexity and safety critical nature, signalling design and construction for the private siding and turnout from the mainline is a standalone package",0,0,0,0,0,1,0,0,0,0,0 3847,56,Design a third party design house was retained to provide detailed design services,0,0,0,0,0,1,0,0,0,0,0 3847,57,"Overlap MACH Energy notes that there are several common suppliers within the latter two categories of the supply chain above, most notably demolition, electrical, labour hire, pumps and pipes, and some civil works services",0,0,0,0,0,1,0,0,0,0,0 3847,58,"Modern slavery risk assessment MACH Energy recognises that risks of modern slavery in the mining sector relate to the location and types of operations that are being undertaken, the make-up of the workforce, and the nature and source of equipment and materials used in the operations",0,0,0,0,0,0,1,0,0,0,0 3847,59,"It has assessed the risks of modern slavery in the first tier of its supply chain over the course of 2020, other than for the Main Contractors, and generally considers that risk to be low in the case of its direct suppliers as all of its direct suppliers are Australian registered companies or resident individuals",0,0,0,0,0,0,1,0,0,0,0 3847,60,"Within the supplier categories, however, we recognise that there are areas of higher risk such as, in site maintenance and security, the supply of personal protective equipment and cleaning",0,0,0,0,0,0,1,0,0,0,0 3847,61,"In addition, several suppliers to MACH Energy source their goods from overseas, for example",0,0,0,0,0,1,0,0,0,0,0 3847,62,"Suppliers of plant and spare parts for use in the coal handling and preparation plant typically assemble goods locally using components sourced from multiple countries including China, France, the United Kingdom, America, and the United Kingdom",0,0,0,0,0,1,0,0,0,0,0 7476,40,Forced marriage,0,0,0,0,0,0,0,0,0,0,0 7476,41,Debt bondage,0,0,0,0,0,0,0,0,0,0,0 7476,42,The worst forms of child labour,0,0,0,0,0,0,0,0,0,0,0 7476,43,Deceptive recruiting for labour services,0,0,0,0,0,0,0,0,0,0,0 7476,44,"It is acknowledged that the following types of modern slavery risks and their indicators that can exist in the Funds operations and supply chains as well as in the equity holdings of the Fund: Sector and industry risk: Certain sectors and industries may have high modern slavery risks because of their characteristics, products and processes",0,0,0,0,0,0,1,0,0,0,0 7476,45,"Indicators of this type of risk include the use of unskilled, temporary or seasonal labour, use of short-term contracts and outsourcing, use of foreign workers or temporary or unskilled labour to carry out functions which are not immediately visible (ie at nighttime) for example, security and cleaning",0,0,0,0,0,0,1,0,0,0,0 7476,46,"In respect of the Fund based on the sectors identified using the Responsible Investment Association, Australasia (RIAA) investor toolkit and the Australian Council of Superannuation Investors (ACSI) Modern Slavery Risks, Rights and Responsibilities: A Guide for Companies and Investors and the Responsible Sourcing Tool, we have identified that the Fund's investments are exposed to the following categories that exhibit sector and industry risk: o Electronics manufacturing and electronics recycling; o Healthcare; and o Financial services",0,0,0,0,0,0,1,0,0,0,0 7476,47,"Product and services risk: where certain products and services have high modern slavery risks because of the way they are produced, provided or used",0,0,0,0,0,0,1,0,0,0,0 11820,50,May 2023,0,0,0,0,0,0,0,0,0,0,0 11820,51,Signed on behalf of the Board of Feros Care,0,1,0,0,0,0,0,0,0,0,0 11820,52,"Jason Bingham, Chair of Feros Care Board",0,0,0,0,0,0,0,0,0,0,0 11820,53,May 2023,0,0,0,0,0,0,0,0,0,0,0 11820,54,The Board of Aspire4Life has consulted with its General Manager and the Executive leadership of Feros Care and endorses the approach and activities taken by the organisation in order to mitigate against risk of modern-day slavery and eliminate moder day slavery practices,0,0,0,0,0,0,0,0,0,0,0 11820,55,This statement has been prepared by the Executive of Feros Care who has consulted with the General Manager of Aspire4Life and the Board of Aspire4Life,0,1,0,0,0,0,0,0,0,0,0 11820,56,The Board of Aspire 4 Life acknowledges that it will continue to consult with its General Manager and the Executive of Feros Care in relation to the organisations activities it is taking to identify modern day slavery risks and eliminate modern day slavery practices,0,0,0,0,0,0,0,0,0,0,0 11820,57,Signed on behalf of Aspire4Life,0,0,0,0,0,0,0,0,0,0,0 1033,50,"The principles embodied in our Code of Conduct reflect NetApps policies on, among other topics, compliance hotline, speaking up, investigations, antiretaliation, diversity and discrimination, conflict minerals, antitrust, antibribery and anticorruption, and protecting our companys assets and reputation",0,0,0,0,0,0,0,0,0,0,0 1033,51,"To ensure compliance with our Code of Conduct and policies, NetApp conducts annual Code of Conduct training for all employees",0,0,0,0,0,0,0,1,0,0,0 1033,52,"Courses are administered and tracked through NetApp Learning Services, an internal organization that serves the technical and sales learning needs of NetApp employees, partners, and customers",0,0,0,0,0,0,0,1,0,0,0 1033,53,Employees who are new to NetApp are also required to take an interactive Code of Conduct course,0,0,0,0,0,0,0,1,0,0,0 1033,54,"Additionally, every employee is required to read the Code of Conduct and certify that he or she has done so prior to joining NetApp",0,0,0,0,0,0,0,1,0,0,0 1033,55,NetApps Ethics and Compliance Program includes an Integrity and Compliance Office (ICO) and Global and Regional Business Conduct Councils,0,0,0,0,0,0,0,1,0,0,0 1033,56,ICO oversees and administers NetApps Code of Conduct and is our primary resource for developing and implementing programs and tools to ensure compliance with global laws and NetApps policies,0,0,0,0,0,0,0,1,0,0,0 1033,57,"Our Business Conduct Councils are cross-functional governance bodies composed of senior leaders from Business, Human Resources, Finance, Internal Audit, Legal, and Integrity and Compliance Office that identify and address compliance issues",0,0,0,0,0,0,0,0,0,1,0 3847,63,"Examples of this supply include a tertiary sizer, water pumps, electrical substations, electrical wire, and a scalping roller screen",0,0,0,0,0,1,0,0,0,0,0 3847,64,Diesel fuel is supplied from south-east Asia through refineries in that region,0,0,0,0,0,1,0,0,0,0,0 3847,65,Various service providers use equipment that was manufactured overseas in various countries,0,0,0,0,0,1,0,0,0,0,0 3847,66,"For example, Thiess and the R2P track build contractor Daracon use Caterpillar products built in North America",0,0,0,0,0,1,0,0,0,0,0 3847,67,As at 31 December 2020 MACH was still in the process of obtaining a better understanding of the indirect suppliers to MACHs own suppliers so as to better asses the risks of modern slavery in the indirect supply chain and this work will continue into the next reporting period,0,0,0,0,0,0,0,0,0,0,0 3847,68,Actions MACH Energy has initiated work to build greater understanding of the supply chain and the risks of modern slavery that lie within it,0,0,0,0,0,0,0,0,0,0,0 3847,69,"In this reporting period we have mapped our main contractors, other suppliers, and suppliers to the R2P project that we are undertaking and have undertaken a high level risk assessment",0,0,0,0,0,0,0,1,0,0,0 3847,70,We have identified the Company Secretary to be responsible for identifying and managing modern slavery risk and we are planning a review of our policies and contracts to ensure we have appropriate governance and management processes in place to mitigate risks of modern slavery,0,0,0,0,0,0,0,1,0,0,0 7476,48,We have not identified any significant areas of product services risk in the Funds operations or supply chains,0,0,0,0,0,0,1,0,0,0,0 7476,49,"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",0,0,0,0,0,0,1,0,0,0,0 7476,50,We have analysed the Funds investments in respect of geographic risk and have not identified any areas of significant geographic risk in its investments,0,0,0,0,0,0,1,0,0,0,0 7476,51,"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",0,0,0,0,0,0,1,0,0,0,0 7476,52,We have not identified any instances of entity risk in the Funds investments and suppliers,0,0,0,0,0,0,1,0,0,0,0 7476,53,"Actions taken by the Reporting Entity and ETL to assess and address risks, including due diligence and remediation processes",0,0,0,0,0,0,0,0,0,0,0 7476,54,ETL and the Reporting Entity are committed to continuously improving awareness and response to the risk of modern slavery in the Funds operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 7476,55,"As this is the Funds first Modern Slavery Statement, we have not systematically identified the actions and procedures necessary to assess and address risks",0,0,0,0,0,0,0,0,0,0,0 11820,58,"Michael Scurrah, General Manager",0,0,0,0,0,0,0,0,0,0,0 11820,59,[28/04/2023],0,0,0,0,0,0,0,0,0,0,0 11820,60,Signed on behalf of the Board of Aspire4Life,0,0,0,0,0,0,0,0,0,0,0 11820,61,"Peter Smales, Chair of Board of Aspire4Life",0,0,0,0,0,0,0,0,0,0,0 11820,62,/04/2023],0,0,0,0,0,0,0,0,0,0,0 12153,0,Cranky Health Modern Slavery Statement F22,0,0,0,0,0,0,0,0,0,0,0 12153,1,Introduction This is the Cranky Health Modern Slavery Statement for the 2022 financial year,0,0,1,0,0,0,0,0,0,0,0 12153,2,"Cranky Health is committed to acting ethically and with integrity, in all its business activities and in every relationship",0,0,0,0,0,0,0,0,0,0,0 1033,58,"They review company investigations, drive control improvements, and identify and prioritize areas for global compliance focus",0,0,0,0,0,0,0,0,0,1,0 1033,59,"NetApp maintains a robust process for reporting slavery and human trafficking, including online channels, and our Code of Conduct contains a nonretaliation policy",0,0,0,0,0,0,0,1,0,0,0 1033,60,"Processes exist for informing senior management about allegations of slavery and human trafficking, including periodic internal reporting on allegations that arise in the supply chain and details about key investigations that are in progress or completed",0,0,0,0,0,0,0,0,0,1,0 1033,61,Training and awareness All of our employees take NetApps Code of Conduct training upon hire and participate in initial and annual mandatory training on the contents of the Code of Conduct,0,0,0,0,0,0,0,1,0,0,0 1033,62,"The Code covers topics such as Corporate Social Responsibility, Human Rights, Respecting the Environment, Supply Chain Relationships, Harassment-Free Workplace, Diversity, and Antidiscrimination",0,0,0,0,0,0,0,0,0,0,0 1033,63,"Through our RBA membership, we also encourage and support the participation of our employees who are responsible for supply chain management",0,0,0,0,0,0,0,1,0,0,0 1033,64,"These employees attend conferences, training, and workshops focused on understanding the RBA policies and best practices, including fighting human trafficking and forced labor",0,0,0,0,0,0,0,1,0,0,0 1033,65,These resources are made available to NetApp suppliers who are RBA members,0,0,0,0,0,0,0,1,0,0,0 3847,71,In the next reporting period we will implement a new Anti-Modern Slavery Policy and Guidelines to accompany the policy,0,0,0,0,0,0,0,1,0,0,0 3847,72,This Policy and Guidelines will establish responsibility and a plan of action in regard to MACH Energy future work including,0,0,0,0,0,0,0,1,0,0,0 3847,73,establishing anti-modern slavery standards,0,0,0,0,0,0,0,1,0,0,0 3847,74,"developing and deploying standards, procedures and processes to monitor our anti-modern slavery actions",0,0,0,0,0,0,0,1,0,0,0 3847,75,defining accountability across all entities in respect of modern slavery risk identification and mitigation,0,0,0,0,0,0,0,1,0,0,0 3847,76,"engagement with external stakeholders, in particular our suppliers",0,0,0,0,0,0,0,0,0,0,0 3847,77,establishing a process for remediation should modern slavery be identified,0,0,0,0,0,0,0,0,0,0,0 3847,78,expanding our current complaints mechanism to ensure access for those wishing to express concerns in respect of modern slavery,0,0,0,0,0,0,0,1,0,0,0 7476,56,"However, we intend to undertake the following actions by 30 June 2022: develop and implement modern slavery training to provide employees with awareness of relevant regulatory requirements and understanding of modern slavery risks as well as incident reporting; ensure that within its own direct supply chain, Lakehouse staff and employees are trained on the relevant provisions within the Act and are made aware of the existence and purpose of this Statement; screen new suppliers for modern slavery risks; and assess the risks of modern slavery in investment portfolios",0,0,0,0,0,0,0,1,0,0,0 7476,57,"During the Reporting Period ETL undertook the following actions: updated the annual due diligence questionnaire to include modern slavery questions designed to identify any potential risks in the supply chains of the Fund, 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 this Statement; actively engaged with investment managers when any suspected modern slavery activity was detected",0,0,0,0,0,0,0,1,0,0,0 7476,58,"How the Reporting Entity and ETL assesses the effectiveness of actions to assess and address risks As this is the first year of modern slavery reporting, ETL as the Responsible Entity of the Fund is in the early stages of assessing the effectiveness of the risk-based approach which includes the review of geographical jurisdictions the Reporting Entities are exposed to and the likely exposure within any investable assets that may align to areas of known modern slavery risks",0,0,0,0,0,0,0,0,0,1,0 7476,59,ETL intends to 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,0,0,0,0,0,0,0,0,0,1,0 7476,60,The ETL 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,0,0,0,0,0,0,0,0,0,1,0 7476,61,"Consultation process There are no subsidiaries or entities owned or controlled by the Reporting Entity, which is a Trust",0,0,0,0,0,0,0,0,0,0,1 7476,62,"However, the trustee of the Trust and the investment manager of the trust consult on the preparation of this MSS",0,0,0,0,0,0,0,0,0,0,1 7476,63,The trustee of the Reporting Entity is ETL (the issuer of this statement),0,0,0,1,0,0,0,0,0,0,0 12153,3,This statement represents the first for Cranky Health and presents an opportunity for us to demonstrate our commitment to eliminating modern slavery,0,0,0,0,0,0,0,0,0,0,0 12153,4,"The focus has been to assess and document the processes in place, with the determination and expectation to identify improvement initiatives for the future",0,0,0,0,0,0,0,0,0,0,0 12153,5,"The latest reporting period has been a time of significant change for Cranky Health, with a change in ownership structure and subsequent organizational changes",0,0,0,0,0,0,0,0,0,0,0 12153,6,"Within this time Cranky Health has also experienced high revenue growth and has reached the revenue threshold deemed necessary to report, set out by the Modern Slavery Act 2018 (Cth)",0,0,0,0,0,0,0,0,0,0,0 12153,7,"Modern Slavery is a term to describe serious exploitation where coercion, threats and deception are used to exploit victims and undermine their freedom",0,0,0,0,0,0,0,0,0,0,0 12153,8,"Practices that may be relevant to our industry include human trafficking, forced labor, child labor and debt bondage",0,0,0,0,0,0,0,0,0,0,0 12153,9,"This statement is made on behalf of the Cranky Health entity, the brand owners of The Man Shake and The Lady Shake, and Custom Foods, Custom Manufacturing and Custom Supplements entities, our manufacturing operations",0,0,0,1,0,0,0,0,0,0,0 12153,10,It has been prepared and reviewed in consultation with relevant stakeholders within the organization and approved by the Board of Directors,0,0,0,0,0,0,0,0,0,0,1 1033,66,"As a result of carrying out its first modern slavery risk assessment for its Australia operations, NetApp will provide dedicated training to certain employees who are likely to be exposed to higher levels of modern slavery risk",0,0,0,0,0,0,0,1,0,0,0 1033,67,"The purpose of the training is to ensure that they understand what modern slavery is, the steps that NetApp takes to minimize the risk of modern slavery occurring, and how employees can raise any concerns",0,0,0,0,0,0,0,0,0,0,0 1033,68,NetApp will also communicate expectations with respect to modern slavery to certain categories of suppliers and service providers,0,0,0,0,0,0,0,0,0,0,0 1033,69,Stephen Peter Faulkner Director of NetApp UK Ltd and NetApp B.V,0,1,0,0,0,0,0,0,0,0,0 1033,70,Matthew Knowlton Fawcett Director of NetApp Australia PTY LTD,0,1,0,0,0,0,0,0,0,0,0 1797,0,2019-20 Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 1797,1,"PAGE 2 MODERN SLAVERY STATEMENT 2019-20 ACKNOWLEDGEMENT OF COUNTRY We acknowledge the Traditional Custodians of the land on which we operate, the Birpai, Awabakal, Darkinjung, Wonoruah and Worimi peoples and recognise their continuing connection to land, waters and culture",0,0,0,0,0,0,0,0,0,0,0 1797,2,"We pay our respects to their Elders past, present and emerging",0,0,0,0,0,0,0,0,0,0,0 3847,79,Measuring effectiveness,0,0,0,0,0,0,0,0,0,0,0 3847,80,Over the next reporting period MACH energy will seek to measure the effectiveness of its actions by,0,0,0,0,0,0,0,0,0,1,0 3847,81,Establishing a cross functional working group to monitor progress and report on a 6-monthly basis to the Company Secretary,0,0,0,0,0,0,0,0,0,1,0 3847,82,Engaging with MACHs suppliers so as to better understand the indirect supply chain,0,0,0,0,0,0,0,0,0,1,0 3847,83,Training MACH personnel in modern slavery risk identification,0,0,0,0,0,0,0,1,0,0,0 3847,84,Engaging directly with our main contractors to build understanding of risks in their supply chains,0,0,0,0,0,0,0,0,0,1,0 3847,85,Consulting with certain suppliers and asking them for information that may assist in gauging how their policies have impacted the behaviour of their suppliers,0,0,0,0,0,0,0,0,0,1,0 3847,86,Consultation MAH and MEA have common policies and procedures relating to procurement and a common Company Secretary who has worked across the businesses in preparing this statement,0,0,0,0,0,0,0,0,0,0,1 7476,64,"The trustee is responsible for holding the assets of the trust, issuing interests in the trust to investors and entering into agreements on behalf of the trust",0,0,0,0,1,0,0,0,0,0,0 7476,65,The investment manager of the trust is Lakehouse,0,0,0,1,0,0,0,0,0,0,0 7476,66,The investment manager is appointed by the trustee under an Investment Management Agreement,0,0,0,0,1,0,0,0,0,0,0 7476,67,The role of the investment manager is to make investment decisions regarding the assets of the trust,0,0,0,0,1,0,0,0,0,0,0 7476,68,"For clarity, Lakehouse is not owned or controlled by the issuer of this MSS",0,0,0,1,0,0,0,0,0,0,0 7476,69,"Senior management of the investment manager and the trustee consult on all content included in the MSS and jointly identify, consider and address modern slavery risks set out in the MSS",0,0,0,0,0,0,0,0,0,0,0 7476,70,The MSS is then reviewed and approved by the board of the trustee,0,0,0,0,0,0,0,0,0,0,0 7476,71,Other relevant information No other relevant information for this reporting period,0,0,0,0,0,0,0,0,0,0,0 12153,11,"Structure, Operations and Supply Chains",0,0,0,0,0,0,0,0,0,0,0 12153,12,Company Structure,0,0,0,0,0,0,0,0,0,0,0 12153,13,"Cranky Health Pty LTD (Cranky Health) was founded by Adam and Belinda MacDougall in Newcastle, New South Wales",0,0,0,0,0,0,0,0,0,0,0 12153,14,"Both Adam and Belinda were inspired to start the business when one of their close friends, a time-poor father of three who struggled to get fit and lose weight, tragically died of a heart attack",0,0,0,0,0,0,0,0,0,0,0 12153,15,"The mission to create positive social change and help others improve their health and lifestyle, created the brands The Man Shake, The Lady Shake and The Kids Shake",0,0,0,0,0,0,0,0,0,0,0 12153,16,"Custom Blending Pty Ltd, Custom Foods Pty Ltd, Custom Supplements Pty Ltd (Custom Foods) was founded by Phil Eddy and Aiden Pennell and acquired by Cranky Health in 2022",0,0,0,1,0,0,0,0,0,0,0 12153,17,This new structure is shown below and the F22 consolidated revenue was $122.45 million AUD,0,0,0,0,1,0,0,0,0,0,0 12153,18,"Product Portfolio Cranky Health are the brand owners of The Man Shake, The Lady Shake and The Kids Shake",0,0,0,1,0,0,0,0,0,0,0 1797,3,HUNTER WATER 3 ABOUT THIS STATEMENT Our first Modern Slavery Statement provides an overview of the ways in which we are identifying and managing modern slavery risks in our supply chains and operations,0,0,0,0,0,0,0,0,0,0,0 1797,4,It details the actions we have undertaken in the 2019-20 reporting period; the actions we are currently progressing; our road map over the next reporting periods for combating modern slavery; and the ways that we will ensure that our efforts are effective,0,0,0,0,0,0,0,0,0,0,0 1797,5,"PAGE 4 MODERN SLAVERY STATEMENT 2019-20 6 Our commitment 7 About us 9 Our values 10 Modern slavery risks in our supply chain 13 Our Modern Slavery Action Plan 16 Our effectiveness 17 Concluding comments CONTENTS Photography by Dylan St John, Hunter Water Apprentice Electrician",0,0,0,0,0,0,0,0,0,0,0 1797,6,HUNTER WATER 5,0,0,0,0,0,0,0,0,0,0,0 1797,7,"PAGE 6 MODERN SLAVERY STATEMENT 2019-20 OUR COMMITMENT Hunter Water operates to deliver reliable, safe, high quality water and wastewater services to our community in partnership with our suppliers and stakeholders",0,0,0,0,1,0,0,0,0,0,0 1797,8,"Within this first Modern Slavery Statement, Hunter Water will demonstrate our commitment to eradicating modern slavery throughout our operations and supply chain",0,0,1,0,0,0,0,0,0,0,0 1797,9,"Our approach to understanding and combating modern slavery requires commitment within the highest levels of our organisation, and will be given a priority focus from our Board of Directors and Executive Management Team",0,0,0,0,0,0,0,0,0,0,0 1797,10,"We have developed an action plan and road map which includes the education of our employees, through to partnering with suppliers to ensure this is not just a priority for Hunter Water, but addressed and measurably delivered by our supply chain as well",0,0,0,0,0,0,0,1,0,0,0 3847,87,Approval The MACH Energy 2020 Modern Slavery Report was approved by the board of directors of MACH Australia Holdings Pty Ltd on 31 May 2021,1,0,0,0,0,0,0,0,0,0,0 3847,88,"Ferdian Purnamasidi, Director",0,1,0,0,0,0,0,0,0,0,0 3847,89,Date: 3 June 2021,0,0,0,0,0,0,0,0,0,0,0 3847,90,Annexure A Corporate Chart,0,0,0,0,0,0,0,0,0,0,0 3847,91,Annexure B Overview of main contractors,0,0,0,0,0,0,0,0,0,0,0 3847,92,Thiess Pty Ltd Sedgman Pty Ltd Aurizon & ARTC,0,0,0,0,0,1,0,0,0,0,0 3961,0,MODERN SLAVERY STATEMENT QUANTA SERVICES AUSTRALIA MEARS GROUP PTY LTD (ABN 92 149 486 500) AND OPERATING COMPANIES WITHIN THE QUANTA SERVICES AUSTRALIA GROUP,0,0,0,0,0,0,0,0,0,0,0 3961,1,3 QUANTA SERVICES AUSTRALIA MODERN SLAVERY STATEMENT INTRODUCTION,0,0,0,0,0,0,0,0,0,0,0 7476,72,"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 Entities, on 23 December 2021",0,1,0,0,0,0,0,0,0,0,0 7476,73,Philip Gentry Chair Date: 23 December 2021,0,1,0,0,0,0,0,0,0,0,0 7476,74,"For clients wishing to discuss this statement, please contact your client service representative",0,0,0,0,0,0,0,0,0,0,0 7476,75,"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",0,0,0,0,0,0,0,0,0,0,0 7476,76,"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",0,0,0,0,0,0,0,0,0,0,0 7476,77,"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",0,0,0,0,0,0,0,0,0,0,0 7738,0,HT&E Limited ACN 008 637 643,0,0,0,0,0,0,0,0,0,0,0 7738,1,Modern Slavery Statement 2020,0,0,0,0,0,0,0,0,0,0,0 12153,19,The products sold are shown in the illustration below,0,0,0,0,0,0,0,0,0,0,0 12153,20,"Alongside the products Cranky Health have developed recipes and fitness plans to build an inclusive, supportive community",0,0,0,0,1,0,0,0,0,0,0 12153,21,"Since launching, The Man Shake, The Lady Shake and The Kids Shake range has helped hundreds of thousands of Australians improve their health and change their lives",0,0,0,0,0,0,0,0,0,0,0 12153,22,We are proud to acknowledge that these brands have a positive impact in peoples lives and a positive impact on Australian society,0,0,0,0,0,0,0,0,0,0,0 12153,23,All of our products are proudly Made In Australia,0,0,0,0,1,0,0,0,0,0,0 12153,24,Operations,0,0,0,0,0,0,0,0,0,0,0 12153,25,Within Cranky Health there are three areas of operations,0,0,0,0,0,0,0,0,0,0,0 12153,26,"Custom Foods, Brisbane",0,0,0,0,0,0,0,0,0,0,0 1797,11,This statement has been approved by our Executive Management Team and Board of Directors,1,0,0,0,0,0,0,0,0,0,0 1797,12,Terry Lawler AO,0,0,0,0,0,0,0,0,0,0,0 1797,13,Darren Cleary Chairman,0,1,0,0,0,0,0,0,0,0,0 1797,14,Managing Director,0,0,0,0,0,0,0,0,0,0,0 1797,15,"HUNTER WATER Who we are Hunter Water serves a population of more than 600,000 people in homes and businesses across the Lower Hunter region",0,0,0,0,1,0,0,0,0,0,0 1797,16,"We are a vertically integrated water utility an operator and retailer from catchment to tap, sink to waterway",0,0,0,0,1,0,0,0,0,0,0 1797,17,Hunter Water is owned by the NSW Government,0,0,0,1,0,0,0,0,0,0,0 1797,18,The Hunter Water Act 1991 and State Owned Corporations Act 1989 established Hunter Water and set out our principal functions,0,0,0,0,0,0,0,0,0,0,0 3961,2,STRUCTURE AND OPERATIONS .............................................................................................5 SUPPLY CHAINS .........................................................................................................................8 RISKS OF MODERN SLAVERY IN OPERATIONS AND SUPPLY CHAINS ........................11,0,0,0,0,0,0,0,0,0,0,0 3961,3,Case Study - Procurement Of Labour In PNG,0,0,0,0,0,0,0,0,0,0,0 3961,4,ACTIONS TAKEN TO ASSESS AND ADDRESS RISKS,0,0,0,0,0,0,0,0,0,0,0 3961,5,ASSESSMENT OF THE EFFECTIVENESS OF THE GROUPS ACTIONS,0,0,0,0,0,0,0,0,0,0,0 3961,6,FUTURE COMMITMENTS,0,0,0,0,0,0,0,0,0,0,0 3961,7,CONTENTS,0,0,0,0,0,0,0,0,0,0,0 3961,8,5 QUANTA SERVICES AUSTRALIA MODERN SLAVERY STATEMENT This Modern Slavery Statement (Statement) is for Mears Group Pty Ltd (ACN 149486500) and its wholly owned and controlled entities which together form the Quanta Services Australia Group,0,0,1,0,0,0,0,0,0,0,0 3961,9,"In this Statement, the Quanta Services Australia Group is referred to as QSA or the Group",0,0,0,0,0,0,0,0,0,0,0 7738,2,Introduction This statement is for HT&E Limited (HT&E) (ABN 95 008 637 643) and its related entities (together HT&E or the Group) under the Modern Slavery Act 2018 (Cth) for the year ended 31 December 2020,0,0,1,0,0,0,0,0,0,0,0 7738,3,"HT&E is a public company listed on the ASX, and a leading media and entertainment business operating radio, audio and digital businesses in Australia as well as outdoor assets in Hong Kong",0,0,0,1,1,0,0,0,0,0,0 7738,4,"Business structure and operations HT&Es portfolio of media assets includes the Australian Radio Network (ARN), Emotive, iHeartRadio Australia and Cody Out-of-Home",0,0,0,0,1,0,0,0,0,0,0 7738,5,"ARN is Australias leading metropolitan broadcaster, home to the national KIIS and Pure Gold networks and youth radio station The Edge",0,0,0,0,1,0,0,0,0,0,0 7738,6,"ARN also operates music streaming, digital entertainment and live events brand iHeartRadio in Australia",0,0,0,0,1,0,0,0,0,0,0 7738,7,"ARN operates across Australia with primary operations in Sydney, Melbourne, Brisbane, Perth, and Adelaide, with headquarters located in Sydney",0,0,0,1,1,0,0,0,0,0,0 7738,8,The Groups total work force is approximately 500 employees as at the time of publication of this statement,0,0,0,1,0,0,0,0,0,0,0 7738,9,"HT&E also owns and operates Cody Out-of-Home in Hong Kong, which manages a network of outdoor advertising assets across Hong Kong",0,0,0,1,1,0,0,0,0,0,0 12153,27,"The sites primary activity is powder manufacturing and blending, which is stored and distributed through warehouse operations",0,0,0,0,1,0,0,0,0,0,0 12153,28,"Our industry recognized research and development team is based at the Brisbane site, and the site is supported by support functions",0,0,0,0,1,0,0,0,0,0,0 12153,29,There are currently five separate operating sites which are being consolidated into one site from April 2023,0,0,0,0,1,0,0,0,0,0,0 12153,30,"Cranky Health, Newcastle",0,0,0,0,0,0,0,0,0,0,0 12153,31,The sites primary activity is fulfillment for the e-commerce direct to consumer business,0,0,0,0,1,0,0,0,0,0,0 12153,32,"The site receives and stores goods primarily from the Custom Foods manufacturing facility, to then pick and pack into consumer parcels",0,0,0,0,1,0,0,0,0,0,0 12153,33,"Cranky Health, Sydney",0,0,0,0,0,0,0,0,0,0,0 12153,34,The sites primary activities are sales support and head office functions within an office environment,0,0,0,0,1,0,0,0,0,0,0 1797,19,Our vision is to be a valued partner in delivering the aspirations of our region,0,0,0,0,0,0,0,0,0,0,0 1797,20,"Our purpose is to enable the sustainable growth of the region, and the life our communities desire, with high quality, affordable services",0,0,0,0,0,0,0,0,0,0,0 1797,21,Our values define who we are as an organisation and how we behave,0,0,0,0,0,0,0,0,0,0,0 1797,22,"The five values of leading, learning, trust, wellbeing and inclusion help guide our decisions and balance our priorities, connecting us to achieve our vision",0,0,0,0,0,0,0,0,0,0,0 1797,23,They are part of everything we do,0,0,0,0,0,0,0,0,0,0,0 1797,24,HUNTER WATER we care for each others wellbeing and that of our communities and our environment,0,0,0,0,0,0,0,0,0,0,0 1797,25,we are honest open and ethical,0,0,0,0,0,0,0,0,0,0,0 1797,26,we step up,0,0,0,0,0,0,0,0,0,0,0 3961,10,QSA is subject to the Modern Slavery Act 2018 (Cth) (the Act),0,0,0,0,0,0,0,0,0,0,0 3961,11,"This is QSAs first annual Statement under the Act, which requires it to outline its structure, operations and supply chains and what is being done to identify, assess and address modern slavery risks within them",0,0,0,0,0,0,0,0,0,0,0 3961,12,This Statement covers the reporting year 1 January to 31 December 2020,0,0,0,0,0,0,0,0,0,0,0 3961,13,Modern slavery involves serious abuses of human rights and serious crimes,0,0,0,0,0,0,0,0,0,0,0 3961,14,"It includes human trafficking, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruiting for labour or services and the worst forms of child labour",0,0,0,0,0,0,0,0,0,0,0 3961,15,"It represents one of the worlds most complex human rights issues that we face, and the construction industry is a high-risk sector due to large, diverse and complex supply chains",0,0,0,0,0,0,1,0,0,0,0 3961,16,QSA is committed to protecting human rights within areas it has control and adhering to the Acts principles and requirements,0,0,0,0,0,0,0,0,0,0,0 3961,17,"QSA performs mining, gas, energy and water infrastructure design, construction and commissioning throughout Australia with its operating entities Coe Drilling, Consolidated Power Projects, Enscope, Nacap, Quanta Power, Quanta Lines and Valard Australia",0,0,0,1,1,0,0,0,0,0,0 7738,10,Other HT&E investments include a 50% interest in content creation business Emotive and a 25% interest in global provider of mobile messaging technology Soprano Design.1 The Group operates under the same company policies and operational protocols having its key activities within the media sector and reporting to an integrated leadership team and the HT&E Board,0,0,0,0,1,0,0,0,0,0,0 7738,11,As such it is appropriate for HT&E to make this statement on behalf of the Group,0,0,0,0,0,0,0,0,0,0,0 7738,12,"To learn more about HT&Es operations and strategy, refer to http://www.htande.com.au/ and for more information about HT&Es corporate governance, refer to http://htande.com.au/corporate- governance/",0,0,0,0,0,0,0,0,0,0,0 7738,13,Supply chains HT&Es business is primarily in the delivery of audio and digital services,0,0,0,0,1,0,0,0,0,0,0 7738,14,The supply chain is generally limited to the procurement of products and services required for general day to day business operations and the delivery of content services to its audiences,0,0,0,0,0,1,0,0,0,0,0 7738,15,These include,0,0,0,0,0,1,0,0,0,0,0 7738,16,Soprano Design has a separate modern slavery statement addressing its own operations within the company,0,0,0,0,0,0,0,0,0,0,0 7738,17,https://www.globalslaveryindex.org/,0,0,0,0,0,0,0,0,0,0,0 12153,35,"Safety Culture Cranky Health is committed to providing a safe workplace for our employees, contractors, visitors, and customers, while driving a positive safety culture and actively reducing and mitigating risk",0,0,0,0,0,0,0,0,0,0,0 12153,36,Cranky Health measures a range of balanced safety performance indicators,0,0,0,0,0,0,0,0,0,0,0 12153,37,"We continuously identify, implement, and monitor our activities to ensure we eliminate unsafe acts and practices",0,0,0,0,0,0,0,0,0,0,0 12153,38,"These activities, identified as proactive LEAD indicators, include the number of Safety Interactions conducted, hazards reported, site inspections and actions closed",0,0,0,0,0,0,0,0,0,0,0 12153,39,"Cranky Health also measures key LAG indicators that measure lost time and medically treated injuries, hours lost due to injury and total injuries which represent a combination of lost time and medically treated injuries",0,0,0,0,0,0,0,0,0,0,0 12153,40,"Modern Slavery Practices, Controls and Processes During the reporting period, and in the preparation of this report, Cranky Health have assessed categories of business activities",0,0,0,0,0,0,0,1,0,0,0 12153,41,"We have used numerous factors to assess the potential risk of modern slavery, such as geographic and industry-based risks based on reports set out in the Global Slavery Index",0,0,0,0,0,0,0,1,0,0,0 12153,42,The summary of our findings is set out below,0,0,0,0,0,0,0,0,0,0,0 1797,27,we value and respect diversity,0,0,0,0,0,0,0,0,0,0,0 1797,28,we have a thirst for learning,0,0,0,0,0,0,0,0,0,0,0 1797,29,"Photo Credit: Dylan St John, Hunter Water Apprentice Electrician 7",0,0,0,0,0,0,0,0,0,0,0 1797,30,"PAGE 8 MODERN SLAVERY STATEMENT 2019-20 What we do Our core responsibility is to supply reliable, high quality water and wastewater services to the people of the Lower Hunter region",0,0,0,0,1,0,0,0,0,0,0 1797,31,"We provide services to our customers by building, operating and maintaining a portfolio of water, wastewater, recycled water and storm water assets with a value of more than $2.5 billion",0,0,0,0,1,0,0,0,0,0,0 1797,32,"Our area of operations Maitland Cessnock Lake Macquarie Dungog Newcastle Port Stephens is 5,366 square kilometres and includes the local government areas of Cessnock, Dungog, Lake Macquarie, Maitland, Newcastle, Port Stephens and a small part of Singleton",0,0,0,0,1,0,0,0,0,0,0 1797,33,"Our Modern Slavery Statement sets out our commitment to identify and mitigate modern slavery risks in our supply chain and operations, as well as the measures we have undertaken and will undertake in delivering on our commitment",0,0,0,0,0,0,0,0,0,0,0 1797,34,"To guide us and ensure we are held accountable to our stakeholders, we have developed a Modern Slavery Action Plan which includes the actions that we have achieved in the 2019-20 reporting period, the ones we are currently progressing, as well as our road map looking ahead for action in the following years",0,0,0,0,0,0,0,0,0,0,0 3961,18,"QSA also has an associate company, Mitchell Water",0,0,0,1,1,0,0,0,0,0,0 3961,19,"In YE 2020, QSA employed over 600 people across Australia and had a smaller workforce in Papua New Guinea (PNG) via its operations with Nacap",0,0,0,1,1,0,0,0,0,0,0 3961,20,"QSA is part of a larger global family of entities which are ultimately owned by Quanta Services Inc (Quanta Services), a publicly listed company (NYSE: PWR) incorporated in Delaware, United States of America",0,0,0,1,0,0,0,0,0,0,0 3961,21,"Quanta Services employs 40,000 employees globally and has one of the largest skilled labour workforces in North America",0,0,0,1,0,0,0,0,0,0,0 3961,22,"Quanta Services provides fully integrated infrastructure solutions in the utility, energy and communications industries",0,0,0,0,1,0,0,0,0,0,0 3961,23,"In YE 2020, the Quanta Services Group had revenues of over $US11B",0,0,0,0,1,0,0,0,0,0,0 3961,24,"In 2020, the Groups project services were provided exclusively in Australia except for a liquefied natural gas pipeline project being undertaken by Nacap in PNG",0,0,0,0,1,0,0,0,0,0,0 3961,25,"QSAS OPERATING ENTITIES SERVICE THE FOLLOWING SECTORS: y electric power (renewable energy generation, electrical transmission and distribution lines); y oil, gas & petrochemical (transmission pipelines and their related facilities such as metering stations, compressor stations, pump stations and processing facilities); y mining (slurry and concentrate transmission pipelines and their related facilities such as metering stations, pump stations and processing facilities); y water (transmission pipelines and distribution networks and their related facilities such as pump stations, metering stations, filtration, and treatment plants); and y civil infrastructure for US Defence force airfield bases in Australia",0,0,0,0,1,0,0,0,0,0,0 7738,18,HT&E Limited ACN 008 637 643,0,0,0,0,0,0,0,0,0,0,0 7738,19,"Service suppliers and equipment vendors: including for example office equipment, communication and broadcast services and equipment, IT infrastructure and support services, travel & accommodation providers and vehicle leasing & hire companies, merchandise & event supplies, printing services, and contract cleaning suppliers",0,0,0,0,0,1,0,0,0,0,0 7738,20,"Content suppliers, licensing agencies and other media companies from whom the Group acquires content rights and advertising services: including licensing content for audio and audio- visual materials such as record labels, collecting societies, newswire services, image libraries and freelance contributors",0,0,0,0,0,0,0,0,0,0,0 7738,21,"Corporate and Professional services: such as legal, accounting and advisory services",0,0,0,0,0,0,0,0,0,0,0 7738,22,"The direct supply chain is predominantly located in Australia, with only a portion sourced from overseas suppliers",0,0,0,0,0,1,0,0,0,0,0 7738,23,"The overseas suppliers are located in developed countries such as the USA, the UK, New Zealand and Ireland",0,0,0,0,0,1,1,0,0,0,0 7738,24,These countries when assessed against the Global Slavery Index are rated low for prevalence of modern slavery.2,0,0,0,0,0,0,1,0,0,0,0 7738,25,Potential risks of modern slavery HT&E has reviewed the risk of modern slavery practices in our supply chain and operations,0,0,0,0,0,0,1,0,0,0,0 12153,43,Our People,0,0,0,0,0,0,0,0,0,0,0 12153,44,There is a zero-tolerance approach towards Modern Slavery in our recruitment and human resources management (HR),0,0,0,0,0,0,0,0,0,0,0 12153,45,All workers are employed within Australia and are represented by the Australian Fair Work Act and the National Employment standards,0,0,0,0,0,0,0,1,0,0,0 12153,46,"As of 30th June 2022, there were 133 people employed at Cranky Health and Custom Foods",0,0,0,1,0,0,0,0,0,0,0 12153,47,Sixty percent of our workforce are salaried employees,0,0,0,0,1,0,0,0,0,0,0 12153,48,Full-time employees are paid according to market rate which is managed by the Human Resources and Executive team,0,0,0,0,0,0,0,0,0,0,0 12153,49,Forty percent were casual employees which fluctuates throughout the year depending on peak seasons and workflow,0,0,0,0,1,0,0,0,0,0,0 12153,50,Casual employees are either employed directly or through well-known industry agencies,0,0,0,0,1,0,0,0,0,0,0 1797,35,How we are addressing modern slavery risk,0,0,0,0,0,0,0,0,0,0,0 1797,36,"HUNTER WATER 9 OUR VALUES At Hunter Water we contribute to sustainability through our adoption and progression of the 17 United Nations Sustainable Development Goals (SDGs), which include specific targets directly linked to combating modern slavery",0,0,0,0,0,0,0,1,0,0,0 1797,37,"To progress our actions in addressing modern slavery risks in our operations and supply chains, we have selected eight SDGs that most directly align with and support our approach to modern slavery risk management",0,0,0,0,0,0,0,1,0,0,0 1797,38,The table below shows how our values and the selected SDGs interact to guide our approach to assessing and addressing modern slavery risks: Value Modern Slavery Risk Management Program Alignment United Nations SDGs Care/Community/Environment Caring about the wellbeing of our community includes caring about people working within our extended supply chain both nationally and internationally,0,0,0,0,0,0,0,0,0,0,0 1797,39,Honesty/Open/Ethical Honest and ethical relationships with our suppliers and the extended supply chain ensures transparency and enables the building of positive relationships within the supply chain,0,0,0,0,0,0,0,0,0,0,0 1797,40,Innovative/Action/Capable Innovation and leadership is essential to assess and address modern slavery risks across our organisation and supply chain,0,0,0,0,0,0,0,0,0,0,0 1797,41,"Diversity/Respect Diversity and respect for the human rights of all individuals across Hunter Water operations, the supply chain and the community promotes an inclusive organisation",0,0,0,0,0,0,0,0,0,0,0 1797,42,"Listening/Collaborating/Sharing Collaboration and sharing of information internally and externally with suppliers, industry bodies, government and the community will enhance the learnings for all",0,0,0,0,0,0,0,1,0,0,0 3961,26,"PROJECT SERVICES PROVIDED BY QSAS OPERATING ENTITIES INCLUDE: y project development, project management, design, engineering, procurement, construction, horizontal directional drilling, and commissioning of new infrastructure including civil, mechanical, structural, electrical and process engineering; and y maintenance, refurbishment, asset management and asset condition assessment of existing infrastructure",0,0,0,0,1,0,0,0,0,0,0 3961,27,INTRODUCTION,0,0,0,0,0,0,0,0,0,0,0 3961,28,STRUCTURE AND OPERATIONS,0,0,0,0,0,0,0,0,0,0,0 3961,29,This is QSAs first annual statement under the Act and we wholly support the Governments process to identify and address modern slavery risks to maintain responsible and transparent supply chains,0,0,0,0,0,0,0,0,0,0,0 3961,30,"Mark Bumpstead, President QSA",0,0,0,0,0,0,0,0,0,0,0 3961,31,7 QUANTA SERVICES AUSTRALIA MODERN SLAVERY STATEMENT THE GROUP STRUCTURE AS AT 31 DECEMBER 2020 NOTES,0,0,0,0,0,0,0,0,0,0,0 3961,32,"All subsidiaries are 100% owned by their Group parent, unless otherwise stated",0,0,0,0,0,0,0,0,0,0,0 3961,33,"As QSA has a non-controlling interest in Mitchell Water Australia Pty Ltd (Mitchell), this Statement does not consider the operations of that company",0,0,0,0,1,0,0,0,0,0,0 7738,26,"Given the nature of our supply chains coupled with the majority of suppliers being located in Australia, the risk of modern slavery in any of our suppliers is considered low",0,0,0,0,0,0,1,0,0,0,0 7738,27,"HT&E generally deals with the Australian based subsidiaries of major international suppliers, but acknowledge they may have a wider supply chain originating from overseas over which HT&E does not have oversight",0,0,0,0,0,0,1,0,0,0,0 7738,28,"In these instances, HT&E acknowledges suppliers engaged in Australia could purchase equipment manufactured overseas in areas that might be of risk of modern slavery practices",0,0,0,0,0,0,1,0,0,0,0 7738,29,"However, this is mitigated by HT&Es major suppliers complying with the relevant modern slavery laws in those jurisdictions and HT&E acquiring goods and services from reputable producers in countries with high standards of protection for the rights of individuals",0,0,0,0,0,0,0,1,0,0,0 7738,30,HT&E recognises that engagement of employees and contractors may present modern slavery risks but considers this low risk due to its implementation of sound HR practices in compliance with the regulatory framework,0,0,0,0,0,0,1,0,0,0,0 7738,31,HT&E is committed to complying with the high employment standards regulated within Australia,0,0,0,0,0,0,0,0,0,0,0 7738,32,Our policies Addressing the risks The Board of HT&E endorses good corporate governance practices and oversees a holistic commitment to high standards of legislative compliance and ethical behaviour across the Group,0,0,0,0,0,0,0,0,0,0,0 7738,33,"HT&E has a number of procedures and policies which minimise the risk of modern slavery practices, including",0,0,0,0,0,0,0,0,0,0,0 12153,51,"In Brisbane casual employees are governed under the Food, Beverage & Tobacco Manufacturing award, and In Newcastle casual employees are governed under the Storage, Services and Wholesale award",0,0,0,0,0,0,0,0,0,0,0 12153,52,Direct Suppliers,0,0,0,0,0,0,0,0,0,0,0 12153,53,During the reporting period there has continued to be volatility and uncertainty within global supply chains,0,0,0,0,0,1,0,0,0,0,0 12153,54,"As a result, the number of suppliers has increased 10% and the procurement strategy has significantly changed",0,0,0,0,0,1,0,0,0,0,0 12153,55,All suppliers are instructed to complete a supplier questionnaire and are added to the Supplier Certificate Register before they are onboarded,0,0,0,0,0,0,0,1,0,0,0 12153,56,The supplier questionnaire includes direct questions regarding labor and compliance with employment laws,0,0,0,0,0,0,0,1,0,0,0 12153,57,"We recognize that honest completion of the supplier questionnaire is relied upon, and we have independently assessed the risk of our direct raw material suppliers",0,0,0,0,0,0,0,1,0,0,0 12153,58,As travel becomes more readily available we will assess the value of on the ground external audits,0,0,0,0,0,0,0,1,0,0,0 1797,43,Wellbeing Trust Leading Inclusion Learning,0,0,0,0,0,0,0,0,0,0,0 1797,44,"PAGE 10 MODERN SLAVERY STATEMENT 2019-20 MODERN SLAVERY RISKS IN OUR SUPPLY CHAINS What we buy During 2019-20, our payments to suppliers totalled $293 Million",0,0,0,0,0,1,0,0,0,0,0 1797,45,The following graph shows our spend by Australia and New Zealand Standard Industry Classifications (ANZSIC) categories as a percentage of total supplier spend in the period,0,0,0,0,0,1,0,0,0,0,0 1797,46,Each ANZSIC category provided in the graph is a grouping of discrete categories that are used to manage Hunter Waters spend profile,0,0,0,0,0,1,0,0,0,0,0 1797,47,"ANZSIC Category Spend FY 2019-20 Postal, Courier Pick-up & Delivery Services Telecommunications Services Construction Services Non-Metallic Mineral Product Manufacturing Other Store-Based Retailing Machinery & Equipment Wholesaling Waste Collection, Treatment & Disposal Services Building Cleaning, Pest Control & Other Support Services Rental & Hiring Services (except Real Estate) Internet Service Providers, Web Search Portals & Data Processing Services Electricity Supply Administrative Services Repair & Maintenance Water Supply, Sewerage & Drainage Services Professional, Scientific & Technical Services (except Computer System Design & Related Heavy & Civil Engineering Construction Sum of Invoice Item Total ORIG $0 $20,000,000 $40,000,000 $60,000,000 $80,000,000 $100,000,000",0,0,0,0,0,1,0,0,0,0,0 1797,48,"HUNTER WATER 11 Risk assessment actions During the 2019-20 reporting period the following actions were taken to understand the extent of exposure in our supply chains to modern slavery: Hunter Water engaged an external consultant to facilitate an internal stakeholder review of spend categories to determine high, medium and low risk spend categories, considering industry sector, geographic location and individual supplier management practices relating to modern slavery and labour and human rights threats",0,0,0,0,0,0,0,1,0,0,0 1797,49,"An independent consultant was engaged to undertake a detailed review of 3 years of spend data totaling $614M across 30 spend categories focusing on industry sector, commodity, geographic location and workforce profile",0,0,0,0,0,0,0,1,0,0,0 1797,50,"Using the above mapping and analysis work, a review of 2019-20 spend category prioritisation has been completed which will direct the procurement activity requirements such as market approach, assessment and evaluation considerations, contract clauses and contractor performance management requirements considering modern slavery risk",0,0,0,0,0,0,0,1,0,0,0 3961,34,"Other than Mitchell, each of the operating entities are wholly owned by Mears Group Pty Ltd and are governed by the same board of directors and are subject to the same corporate governance policies and procedures",0,0,0,1,0,0,0,0,0,0,0 3961,35,"In YE 2020, some operating entities also formed or participated in integrated joint ventures with members outside the Group",0,0,0,0,1,0,0,0,0,0,0 3961,36,This Statement covers operations and supply chains relating to joint venture operations and procurement activities only,0,0,0,0,0,0,0,0,0,0,0 3961,37,"QSI Finance (Australia) Pty Ltd ABN: 40164312047 Inc 9 July 2013 Enscope Pty Ltd ABN: 38136478030 Inc 6 April 2009 Coe Drilling Pty Ltd ABN: 96007015563 Inc 27 June 1988 Consolidated Power Projects Australia Pty Ltd ABN: 18075411219 Inc 28 August 1996 Mears Pipelines Pty Ltd ACN: 164725124 Inc 9 July 2013 Quanta Lines Pty Ltd ABN: 11066157391 Inc 23 August 1994 Quanta Power Australia Pty Ltd ABN: 79617859 739 Inc 9 March 2017 Quanta Services Australia Pty Ltd ABN: 11164311997 Inc 10 July 2013 Mitchell Water Australia Pty Ltd ABN: 16097612149 Inc 25 July 2001 Nacap Pty Ltd ABN: 33006306994 Inc 25 July 1984 Mears Integrity Pty Ltd ABN: 28168349951 Inc 3 March 2014 Valard Construction Australia Pty Ltd ACN: 638 953 572 Inc 7 February 2020 Other Subsidiaries Nacap PNG Limited (Papua New Guinea) 30% AUSTRALIA OVERSEAS OVERSEAS AUSTRALIA Quanta Services, Inc (U.S.) NYSE: PWR QSI Finance II (Australia) Pty Ltd ACN: 168 351 022 Inc 3 March 2014 Mears Group Pty Ltd ABN: 92149486500 Inc 23 February 2011",0,0,0,1,0,0,0,0,0,0,0 3961,38,"9 QUANTA SERVICES AUSTRALIA MODERN SLAVERY STATEMENT Supporting the Groups operations are the following key supply chains: (a) Subcontracted on-site and off-site services, including trades, skilled, semi-skilled and unskilled labour; (b) Purchase of major process equipment designed and built to specified project requirements; (c) Purchase of steel pipe, extruded and machined steel fittings and process control equipment for incorporation into gas and water extraction, transportation and processing infrastructure; (d) Plant and equipment hire and maintenance; (e) Transport, travel and accommodation, including portable camps; (f) Export logistics to support PNG-based operations; and (g) Purchase and hire of vehicles, construction equipment and tools, construction materials and consumables, clothing, footwear, branded products, IT and electronic equipment, offices and furniture",0,0,0,0,0,1,0,0,0,0,0 3961,39,"LABOUR Most of the Groups employees are employed under Fair Work Australia-approved enterprise bargaining agreements or individual workplace agreements (permanent, fixed term, part-time or casual contracts) that meet or exceed the minimum requirements of an applicable award",0,0,0,0,1,0,0,0,0,0,0 3961,40,Labour is also provided to projects by subcontractors as part of the services performed,0,0,0,0,0,1,0,0,0,0,0 3961,41,"The Group uses standard conditions of subcontract to hold subcontractors accountable for meeting legislative requirements, including the Fair Work Act 2009 (Cth)",0,0,0,0,0,0,0,1,0,0,0 7738,34,This statement - confirming HT&Es commitment to minimising modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 7738,35,Ensuring that the Group acquires goods and services from reputable suppliers who primarily operate in countries with equivalent protections for employees and individuals,0,0,0,0,0,0,0,1,0,0,0 7738,36,https://www.globalslaveryindex.org/,0,0,0,0,0,0,0,0,0,0,0 7738,37,HT&E Limited ACN 008 637 643,0,0,0,0,0,0,0,0,0,0,0 7738,38,"Standard contractual terms to engage major suppliers and for the procurement of goods or services deemed of potential risk, including requiring the supplier to comply with relevant modern slavery laws",0,0,0,0,0,0,0,1,0,0,0 7738,39,"Code of Conduct - setting out the values, ethical behaviour and commitment to legislative compliance which is expected of the Group and its employees",0,0,0,0,0,0,0,1,0,0,0 7738,40,"Whistle blower policy - providing an independent avenue for employees, contractors and suppliers to raise concerns regarding actual or suspected contravention of HT&Es ethical and legal standards",0,0,0,0,0,0,0,1,0,0,0 7738,41,Internal audit and risk functions to monitor compliance,0,0,0,0,0,0,0,0,0,1,0 12153,59,The following assessment of key categories incorporates factors such as: size and scale; accreditation shown; complexity of the route to market; and nature and length of the relationship,0,0,0,0,0,0,0,1,0,0,0 12153,60,Description Country of Origin Modern Slavery Risk Assessment Milk Powder Concentrate Australia and New Zealand Low,0,0,0,0,0,1,1,0,0,0,0 12153,61,"The most significant ingredient of The Man Shake, The Lady Shake and The Kids Shake",0,0,0,0,0,0,1,0,0,0,0 12153,62,"MPC is a derivative of milk and is supplied by reputable, well-known partners in the Australia and New Zealand dairy industry",0,0,0,0,0,0,1,0,0,0,0 12153,63,A number of those partners are listed and publish Modern Slavery statements,0,0,0,0,0,0,1,0,0,0,0 12153,64,Whey Protein USA Low,0,0,0,0,0,0,0,0,0,0,0 12153,65,Suppliers in this category are large-scale operations within an established industry,0,0,0,0,0,0,1,0,0,0,0 12153,66,Amino Acids China Low-medium,0,0,0,0,0,0,1,0,0,0,0 1797,51,"Consultant Facilitated Spend Category Heat Mapping Consultant Spend Analysis - Modern Slavery Procurement Spend Category Prioritisation Modern Slavery supply chain risk review actions Photograph by Dylan St John, Hunter Water Apprentice Electrician",0,0,0,0,0,0,0,0,0,0,0 1797,52,"PAGE 12 MODERN SLAVERY STATEMENT 2019-20 Our risk profile According to the Global Slavery Index, the risk of modern slavery in Australia is lower than many other jurisdictions",0,0,0,0,0,0,1,0,0,0,0 1797,53,"There are however, goods and services that Hunter Water procures that are at a higher risk of modern slavery based on the geographic origin and/or industry sector as identified and categorised under the globally recognised modern slavery risk assessment approach",0,0,0,0,0,0,1,0,0,0,0 1797,54,"Although Australian-based suppliers provide us with the goods and services we need across these known high-risk categories, these suppliers and their supply chains will require further engagement to ensure that modern slavery risks are identified, assessed and addressed",0,0,0,0,0,0,1,0,0,0,0 1797,55,An external consultant was engaged to undertake a detailed review of the last three years of supplier spend data,0,0,0,0,0,0,0,1,0,0,0 1797,56,The methodology used considered the modern slavery risks associated with,0,0,0,0,0,0,0,1,0,0,0 1797,57,the industry sector of the spend,0,0,0,0,0,0,0,0,0,0,0 1797,58,the commodity or service purchased,0,0,0,0,0,0,0,0,0,0,0 3961,42,The Groups operating entities also use third-party labour providers to provide temporary labour to assist with project delivery,0,0,0,0,0,1,0,0,0,0,0 3961,43,"MATERIALS / EQUIPMENT In 2020, the vast majority (approximately 97%) of QSAs annual procurement spend was with suppliers and subcontractors located in Australia",0,0,0,0,0,1,0,0,0,0,0 3961,44,"While this was the case, much of the procurement spend was on products and materials sourced overseas",0,0,0,0,0,1,0,0,0,0,0 3961,45,"For example, unique to the Groups supply chain is the procurement of major equipment including high voltage equipment such as synchronous condensers, voltage transformers, current transformers, power transformers, capacitors, reactors, circuit-breakers, disconnectors, cabling and other high voltage materials",0,0,0,0,0,1,0,0,0,0,0 3961,46,"This equipment is generally procured from Australian based companies, but many of those companies source the assembled equipment from Europe (in particular, Austria, Germany, Sweden, France and Italy), China, India, Canada, USA and South Korea, with a complex associated supply chain for the componentry and associated raw materials",0,0,0,0,0,1,0,0,0,0,0 3961,47,SUPPLY CHAINS,0,0,0,0,0,0,0,0,0,0,0 3961,48,"11 QUANTA SERVICES AUSTRALIA MODERN SLAVERY STATEMENT 1 Walk Free Foundation Global Slavery Index, 2018, pages 87-88",0,0,0,0,0,0,0,0,0,0,0 3961,49,Minderoo Foundation,0,0,0,0,0,0,0,0,0,0,0 7738,42,"Given the low risk of modern slavery among HT&Es operations and supply chain, these policies are considered appropriate and primary audits of the supply chain are not warranted nor feasible",0,0,0,0,0,0,1,0,0,0,0 7738,43,Due diligence and further steps HT&E obtains goods and services predominantly from domestic suppliers who are reputable and ethical entities,0,0,0,0,0,1,0,0,0,0,0 7738,44,HT&E also monitors the location of each of its suppliers so that even the small number of international suppliers are identified and any entities that supply from potentially higher risk areas more susceptible to modern slavery practices are managed,0,0,0,0,0,0,0,1,0,0,0 7738,45,"To support and ensure the engagement of reputable entities HT&E has HR, audit and risk, finance and legal functions whose roles include assessing and ensuring such entities comply with both the relevant laws and HT&E policies across the business",0,0,0,0,0,0,0,1,0,0,0 7738,46,"This process is accompanied by internal checks and balances, as all material contracts need sign off from senior management, including consideration of risks relating to the supply",0,0,0,0,0,0,0,1,0,0,0 7738,47,HT&E reviews and tracks contract procurement processes in order to check internal practices are complied with,0,0,0,0,0,0,0,0,0,1,0 7738,48,This compliance is also supported by our key corporate governance policies,0,0,0,0,0,0,0,0,0,0,0 7738,49,"Whilst it is not feasible for HT&E to comprehensively investigate all activities of its suppliers, HT&E will continue to review its operations and its procurement of goods and services to monitor and identify whether there are risks relating to modern slavery which HT&E may then be able to mitigate",0,0,0,0,0,0,0,0,0,1,0 12153,67,Suppliers in this category are large-scale operations and have long standing agreements with multi-national corporate manufacturers,0,0,0,0,0,0,1,0,0,0,0 12153,68,Vitamins China Low-medium,0,0,0,0,0,0,0,0,0,0,0 12153,69,There are multiple suppliers used within this category,0,0,0,0,0,0,1,0,0,0,0 12153,70,Preference is given to those with international accreditation and professional operational standards,0,0,0,0,0,0,1,0,0,0,0 12153,71,"It is not unusual to work with agencies and/or wholesalers to procure specialized ingredients, which may increase risk",0,0,0,0,0,0,1,0,0,0,0 12153,72,Flavors Various Medium,0,0,0,0,0,0,1,0,0,0,0 12153,73,"Whilst flavorings are often processed in Australia, the ingredients are sourced from international markets",0,0,0,0,0,0,1,0,0,0,0 12153,74,The complexity of the indirect supply chain and small scale creates a less certain view of Modern Slavery compliance,0,0,0,0,0,0,1,0,0,0,0 1797,59,"the supplier geographic location and / or the product country of origin, where known; and",0,0,0,0,0,0,0,1,0,0,0 1797,60,the workforce profile of the service or commodity,0,0,0,0,0,0,0,0,0,0,0 1797,61,Approximately 40% of the 824 suppliers included in the high-level analysis were identified as potentially high risk in accordance with the methodology,0,0,0,0,0,1,1,0,0,0,0 1797,62,"It is important to clarify that the review did not asses supplier risk levels based on individual supplier practices or behaviour, and it is not an indication that these suppliers are knowingly causing or contributing to modern slavery",0,0,0,0,0,0,0,0,0,0,0 1797,63,It serves as an indication that the industry sector or geographic location of the supplier carries a greater risk exposure,0,0,0,0,0,0,0,0,0,0,0 1797,64,"The information helps us prioritise our modern slavery prevention and awareness efforts according to risk potential, as well as providing a baseline for our ongoing supplier due diligence processes",0,0,0,0,0,0,0,0,0,0,0 1797,65,"Our supplier profile is likely to change in future years, given the nature of capital works programs, however the spend categories in which our spend occurs is less likely to change significantly",0,0,0,0,0,0,0,0,0,0,0 1797,66,"For this reason, spend category risk was a key focus of the risk review",0,0,0,0,0,0,1,0,0,0,0 3961,50,"Australian Human Rights Commission; https://humanrights.gov.au/our-work/business-and-human-rights/projects/tackling-modern-slavery-and-labour-exploitation 3 Walk Free Foundation Global Slavery Index, 2018, page iv",0,0,0,0,0,0,0,0,0,0,0 3961,51,Minderoo Foundation,0,0,0,0,0,0,0,0,0,0,0 3961,52,Ibid,0,0,0,0,0,0,0,0,0,0,0 3961,53,"The Group recognises that risk of modern slavery is greater where QSAs operating entities do not have direct knowledge of the terms and conditions between its suppliers and their employees and sub-suppliers, and particularly in geographies and industries with a higher prevalence of modern slavery",0,0,0,0,0,0,1,0,0,0,0 3961,54,"In the 2020 reporting year, the Group identified the following areas of its business that may entail modern slavery risks in its supply chain: (a) Engagement of local labour for PNG operations, given PNG has an estimated 10.3 victims of modern slavery per 1000 population (compared to Australias estimated 0.6 victims of modern slavery per 1000 population).1 (b) Cleaning of its leased offices, as cleaning services have been identified as a key risk area for modern slavery in Australia.2 (c) Procurement of the following products, based on the US Department of Labors 2020 List of Goods Produced by Child Labour or Forced Labour",0,0,0,0,0,0,1,0,0,0,0 3961,55,Steel-containing product,0,0,0,0,0,0,1,0,0,0,0 3961,56,"may be procured as formed product (eg pipe, structural steel, reinforcing steel) or be incorporated in plant, tools and equipment; and",0,0,0,0,0,0,1,0,0,0,0 3961,57,steel could have been produced using raw materials (eg iron or coal) extracted or refined under modern slavery conditions,0,0,0,0,0,0,1,0,0,0,0 7738,50,Effectiveness in addressing modern slavery The processes HT&E currently undertakes provide a framework for managing the risks relating to modern slavery,0,0,0,0,0,0,0,0,0,0,0 7738,51,HT&E will continue to review the risks and effectiveness of actions to mitigate risks relating to modern slavery,0,0,0,0,0,0,0,0,0,0,0 7738,52,Approval This statement has been approved by the Board of Directors of HT&E on 31 March 2021,1,0,0,0,0,0,0,0,0,0,0 7738,53,"Hamish McLennan, Chairman, HT&E Limited",0,1,0,0,0,0,0,0,0,0,0 7771,0,Beyond Blue Limited Modern Slavery Statement 2021,0,0,0,0,0,0,0,0,0,0,0 7771,1,This statement covers the activities of Beyond Blue Limited (ABN 87 093 865 840) (Beyond Blue) (and its controlled entity the Beyond Blue Depression Research Ancillary Fund Trust (ABN 41 688 712 705)) to understand and implement actions to minimise the risk of modern slavery and human trafficking in our operations and supply chain,0,0,1,1,0,0,0,0,0,0,0 7771,2,Introduction,0,0,0,0,0,0,0,0,0,0,0 7771,3,"This is the first mandatory Modern Slavery Statement (Statement) for Beyond Blue, having met the income threshold contained within the Modern Slavery Act 2018 (Cth) (Act) for the first time in 2021",0,0,0,0,0,0,0,0,0,0,0 12153,75,Corn-based derivatives USA,0,0,0,0,0,0,0,0,0,0,0 12153,76,Low risk,0,0,0,0,0,0,1,0,0,0,0 12153,77,Suppliers in this category are large-scale operations within an established industry,0,0,0,0,0,0,0,0,0,0,0 12153,78,Packaging China and AU Low risk,0,0,0,0,0,0,0,0,0,0,0 12153,79,There are long standing collaborative relationships with large-scale packaging suppliers,0,0,0,0,0,0,1,0,0,0,0 12153,80,Indirect Suppliers Within our operational sites there are several areas of indirect suppliers,0,0,0,0,0,1,0,0,0,0,0 12153,81,Transport and logistics suppliers,0,0,0,0,0,1,0,0,0,0,0 12153,82,Site support including equipment hire,0,0,0,0,0,1,0,0,0,0,0 1797,67,"Building & engineering materials Property/ facilities maintenance Waste management Labour hire Building, construction, fabrication Clothing, PPE Spend statistics The below diagram shows the percentage of our 2019-20 supplier spend assessed under the modern slavery risk assessment methodology as having potentially high, medium and low modern slavery risk",0,0,0,0,0,0,1,0,0,0,0 1797,68,"Supplier Spend Modern Slavery Profile FY 2019-20 47% 35% 18% Low Risk Medium Risk High Risk Based on the analysis, the following subcategories of spend within the ANZSIC groupings were identified as potentially high- risk",0,0,0,0,0,0,1,0,0,0,0 1797,69,"HUNTER WATER 13 OUR MODERN SLAVERY ACTION PLAN What we have done In the 2019-20 reporting period, we undertook a detailed organisational gap analysis and a supplier data analysis to identify potential modern slavery risks and opportunities within our operations and supply chains",0,0,0,0,0,0,0,1,0,0,0 1797,70,"We engaged a consultant specialising in modern slavery capability to assist us in providing awareness training on modern slavery risks, which included members of our Executive Management Team, via action planning workshops",0,0,0,0,0,0,0,1,0,0,0 1797,71,The gap analysis and action planning workshops informed the development of an organisational-wide Modern Slavery Action Plan and Road Map,0,0,0,0,0,0,0,0,0,0,0 1797,72,"The gap analysis process highlighted a high level of commitment and support across our business to address modern slavery, acknowledging the need for further awareness and training on modern slavery risks, and how we can treat these risks within our organisation and supply chain",0,0,0,0,0,0,0,0,0,0,0 1797,73,"We have presented the Action Plan and Road Map to our Executive Management Team on our proposed plans to treat modern slavery risk within the business, as well as what our legislative requirements are as a Reporting Entity",0,0,0,0,0,0,0,1,0,0,0 1797,74,"Building on the level of commitment, and the need to implement the actions from the Modern Slavery Action Plan, during the reporting period we established a Sustainable Procurement Working Group",0,0,0,0,0,0,0,1,0,0,0 3961,58,ii,0,0,0,0,0,0,1,0,0,0,0 3961,59,Copper-containing product,0,0,0,0,0,0,1,0,0,0,0 3961,60,"may be procured as cabling or wire, or incorporated into manufactured goods including electronics, IT equipment, construction equipment, tools; and",0,0,0,0,0,0,1,0,0,0,0 3961,61,copper could have been extracted or refined under modern slavery conditions,0,0,0,0,0,0,1,0,0,0,0 3961,62,iii,0,0,0,0,0,0,1,0,0,0,0 3961,63,"IT equipment, which is procured from local wholesalers / retailers which have been assessed by the Group as having low modern slavery risk but may have been assembled overseas in conditions where modern slavery may be prevalent",0,0,0,0,0,0,1,0,0,0,0 3961,64,"Laptops, computers and mobile phones were also ranked as the top modern slavery at-risk product category in 2018 for imports into the G20.3 iv",0,0,0,0,0,0,1,0,0,0,0 3961,65,"Clothing, footwear and branded products that may have been manufactured, or may include raw materials that have been produced, under modern slavery conditions (eg cotton, fabrics, yarn or rubber)",0,0,0,0,0,0,1,0,0,0,0 7771,4,"Previously, Beyond Blue has voluntarily published a Modern Slavery Statement on the basis that it was felt appropriate for it to be pro-active in the management of its modern slavery risks and obligations",0,0,0,0,0,0,0,0,0,0,0 7771,5,The purpose of this Statement is to outline our approach to ensuring that Beyond Blue has robust frameworks and processes in place to minimise the risk of modern slavery in our business operations and supply chain,0,0,0,0,0,0,0,0,0,0,0 7771,6,Preparation of this statement is also consistent with our organisational values of,0,0,0,0,0,0,0,0,0,0,0 7771,7,"Collaboration - We treat all people, and other organisations, with humility and compassion and value the knowledge they share with us",0,0,0,0,0,0,0,0,0,0,0 7771,8,Integrity - Honesty and transparency are the guiding principles for all our work,0,0,0,0,0,0,0,0,0,0,0 7771,9,"We are authentic and open about why, when and how we engage with the community, and we are transparent about how we use those learnings and what we need to do to improve",0,0,0,0,0,0,0,0,0,0,0 7771,10,Our business,0,0,0,0,0,0,0,0,0,0,0 7771,11,"Beyond Blue is an Australian public company, limited by guarantee, incorporated and domiciled in Australia under the Corporations Act 2001 (Cth)",0,0,0,1,0,0,0,0,0,0,0 12153,83,Hardware and software,0,0,0,0,0,1,0,0,0,0,0 12153,84,Each supplier has completed a tender and selection process before being selected,0,0,0,0,0,0,0,1,0,0,0 12153,85,All services are provided within Australia and present a low risk,0,0,0,0,0,0,1,0,0,0,0 12153,86,Manufacturing Partners,0,0,0,0,0,0,0,0,0,0,0 12153,87,"Cranky Health use manufacturing partners, outside of Custom Foods, to transform the primarily blended powder into secondary products such as bars and ready to drink products",0,0,0,0,0,1,0,0,0,0,0 12153,88,All manufacturing partners are within Australia and are regularly visited and audited by Cranky Health employees,0,0,0,0,0,1,1,1,0,0,0 12153,89,This area presents a low risk,0,0,0,0,0,0,1,0,0,0,0 12153,90,Customers,0,0,0,0,0,0,0,0,0,0,0 1797,75,"This Working Group includes representatives from across several functions within our business, and is accountable to the Group Manager Procurement for the delivery and monitoring of sustainable procurement objectives, including the Modern Slavery Action Plan",0,0,0,0,0,0,0,1,0,0,0 1797,76,PAGE 14 MODERN SLAVERY STATEMENT 2019-20 2019-20 Action Plan Gap Analysis: Operational risks and gaps were assessed during workshops involving a cross-disciplinary team,0,0,0,0,0,0,0,1,0,0,0 1797,77,"Systems and processes were assessed for potential gaps in addressing modern slavery across areas including management systems, risk management, procurement and supply chains, human resources and recruitment and customers and stakeholders",0,0,0,0,0,0,0,1,0,0,0 1797,78,Awareness Training: Hunter Water engaged an external consultant to deliver Modern Slavery Awareness Training to staff across the organisation with responsibility across the procurement / supplier management lifecycle,0,0,0,0,0,0,0,1,0,0,0 1797,79,"The training focused on defining Modern Slavery, the legislative requirements, identifying threats and opportunities for Hunter Water to mitigate the risk",0,0,0,0,0,0,0,1,0,0,0 1797,80,Road Map: The results of the gap analysis informed the development of an organisational wide Modern Slavery Action Plan a three year road map for implementation,0,0,0,0,0,0,0,1,0,0,0 1797,81,"Sustainable Procurement Working Group: Hunter Water has re-established the Sustainable Procurement Working Group to provide a cross- functional forum to review, update and progress the modern slavery road map, as well as identify and flag the resources required to ensure capacity and capability to deliver against the Modern Slavery Action Plan",0,0,0,0,0,0,0,1,0,0,0 1797,82,Board and Executive Engagement: High level of engagement on modern slavery risks with the Board and Executive Management Team,0,0,0,0,0,0,0,1,0,0,0 3961,66,Garments were also the second-ranked modern slavery at-risk product category in 2018 for imports into the G20.4,0,0,0,0,0,0,1,0,0,0,0 3961,67,"Structural timber, which could have originated from a country with modern slavery risk for timber production",0,0,0,0,0,0,1,0,0,0,0 3961,68,RISKS OF MODERN SLAVERY,0,0,0,0,0,0,0,0,0,0,0 3961,69,IN OPERATIONS AND SUPPLY CHAINS,0,0,0,0,0,0,0,0,0,0,0 3961,70,"13 QUANTA SERVICES AUSTRALIA MODERN SLAVERY STATEMENT CASE STUDY PROCUREMENT OF LABOUR IN PNG Local labour is procured by Nacap in two ways: (a) Firstly, through referrals by Nacaps client (a leading consulting and engineering company), where the client negotiates directly with local communities to identify potential work candidates from within each community",0,0,0,0,0,1,0,0,0,0,0 3961,71,"Nacap and its client jointly agree which of the identified workers will be seconded to Nacap and, from that point, the workers are directly engaged under Nacaps supervision",0,0,0,0,0,1,0,0,0,0,0 3961,72,"(b) Secondly, labour is sourced through an Australian-based labour- hire company that specialises in recruitment and staffing solutions for PNG projects",0,0,0,0,0,1,0,0,0,0,0 3961,73,"Nacap has a long-standing relationship with this company and they have operated in PNG for over 30 years, and service many of the resource majors operating in the country",0,0,0,0,0,1,0,0,0,0,0 7771,12,The members of Beyond Blue are the Commonwealth of Australia and each Australian State and Territory,0,0,0,1,0,0,0,0,0,0,0 7771,13,Beyond Blue,0,0,0,1,0,0,0,0,0,0,0 7771,14,is registered as a charity with the Australian Charities and Not-for-profits Commission (ACNC),0,0,0,1,0,0,0,0,0,0,0 7771,15,is classified as a Health Promotion Charity under the Income Tax Assessment Act 1997 (Cth),0,0,0,1,0,0,0,0,0,0,0 7771,16,is endorsed as a Deductible Gift Recipient and is eligible for certain tax concessions,0,0,0,0,0,0,0,0,0,0,0 7771,17,acts as the Trustee of the Beyond Blue Depression Research Ancillary Fund Trust (Trust),0,0,0,1,0,0,0,0,0,0,0 7771,18,"The purpose of the Trust is to commission and undertake research relating to depression, anxiety and related conditions",0,0,0,0,1,0,0,0,0,0,0 7771,19,"Established in 2000, Beyond Blue is a national, independent, not-for-profit organisation working to increase awareness and understanding of depression, anxiety and suicide prevention in Australia and reduce associated stigma",0,0,0,1,1,0,0,0,0,0,0 12153,91,Cranky Health brands are sold within the major retailers within Australia and are typically publicly listed companies with Modern Slavery policies,0,0,0,0,1,0,0,0,0,0,0 12153,92,"Custom Foods manufacture for brands and customers alongside the core Cranky Health brands, and this third-party manufacturing contributed to approximately 10% of the production volume",0,0,0,0,1,0,0,0,0,0,0 12153,93,Our 3rd party partners reside within Australia and typically do not meet the threshold for public Modern Slavery statements,0,0,0,0,0,0,0,0,0,0,0 12153,94,Retail customers and third-party manufacturing customers present a low Modern Slavery risk,0,0,0,0,0,0,0,0,0,0,0 12153,95,Assesses the effectiveness of these actions,0,0,0,0,0,0,0,0,0,0,0 12153,96,This document represents the first Modern Slavery statement for Cranky Health,0,0,0,0,0,0,0,0,0,0,0 12153,97,"During the review, consultation, and preparation of this statement there were several areas for improvement identified",0,0,0,0,0,0,0,0,0,0,0 12153,98,"We anticipate that between the submission of this F22 statement and F23, there will be significant progression",0,0,0,0,0,0,0,0,0,0,0 1797,83,"Hunter Water began its journey to understand, assess and address Modern Slavery through the following actions",0,0,0,0,0,0,0,0,0,0,0 1797,84,HUNTER WATER 15 What we will do Our Road Map includes the actions we are currently progressing as well as the actions we will achieve over the next three reporting periods,0,0,0,0,0,0,0,0,0,0,0 1797,85,These are broadly categorised into five focus areas covering,0,0,0,0,0,0,0,0,0,0,0 1797,86,due diligence,0,0,0,0,0,0,0,0,0,0,0 1797,87,awareness and training,0,0,0,0,0,0,0,0,0,0,0 1797,88,engagement and collaboration,0,0,0,0,0,0,0,0,0,0,0 1797,89,procurement and supply chain; and,0,0,0,0,0,0,0,0,0,0,0 1797,90,governance,0,0,0,0,0,0,0,0,0,0,0 3961,74,Our review found that the employment of local workers is a key component of getting support for large oil and gas projects from their communities,0,0,0,0,0,0,0,0,0,0,0 3961,75,The relationship is largely one of mutual benefit which mitigates the potential for local unrest and human rights abuses,0,0,0,0,0,0,0,0,0,0,0 3961,76,"It was also found that the ultimate client, which is one of the worlds largest oil and gas majors, clearly communicates its expectations on human rights to its suppliers on an annual basis",0,0,0,0,0,0,0,0,0,0,0 3961,77,"These expectations include references to key international human rights frameworks, including the United Nations Guiding Principles on Business and Human Rights and the International Labour Organization Declaration on Fundamental Principles and Rights at Work",0,0,0,0,0,0,0,0,0,0,0 3961,78,The ultimate client has also submitted modern slavery and human trafficking statements under the UK Modern Slavery Act 2015,0,0,0,0,0,0,0,0,0,0,0 3961,79,Nacaps agreement with the Australian- based labour hire company was entered into prior to passage of the Act and will be reviewed as part of the future actions described below,0,0,0,0,0,0,0,1,0,0,0 3961,80,"However, the agreement contains provisions that, in our view, serve to mitigate the risk of modern slavery, such as",0,0,0,0,0,0,0,1,0,0,0 3961,81,Stating the amounts which are to be paid to employees based on job classification (without reduction or offset by the provider),0,0,0,0,0,0,0,1,0,0,0 7771,20,Our vision is that all people in Australia achieve their best possible mental health,0,0,0,0,0,0,0,0,0,0,0 7771,21,"For more information about our business structure, strategy and performance, please refer to our website www.beyondblue.org.au",0,0,0,0,0,0,0,0,0,0,0 7771,22,"Respect for human rights is fundamental to our values and the long-term sustainability of our business, and to the wellbeing of the communities in which we operate",0,0,0,0,0,0,0,0,0,0,0 7771,23,"At Beyond Blue, this means doing business in a",0,0,0,0,0,0,0,0,0,0,0 7771,24,"way that acknowledges and respects the rights of our people, community and service providers to be free from practices of modern slavery, including forced labour, human trafficking and child labour",0,0,0,0,0,0,0,0,0,0,0 7771,25,"Beyond Blue is committed to complying with the labour rights standards, legislation and statutory requirements in Australia",0,0,0,0,0,0,0,0,0,0,0 7771,26,"Further, Beyond Blue is committed to acting ethically and with integrity in all business dealings, and to ensuring its service providers and suppliers comply with the labour rights standards, legislation and statutory requirements in the countries in which they operate",0,0,0,0,0,0,0,0,0,0,0 7771,27,Our operations and supply chain Our key operations and the associated supply chains are as follows: Area Main operations Supply chain Corporate functions,0,0,0,0,0,0,0,0,0,0,0 12153,99,"The areas identified are, but not limited to, the following",0,0,0,0,0,0,0,0,0,0,0 12153,100,Safety systems and culture,0,0,0,0,0,0,0,0,0,0,0 12153,101,Building improved safety systems to drive culture and behavior,0,0,0,0,0,0,0,0,0,0,0 12153,102,"Ethical sourcing policy to supporting Procurement, Human Resources, and indirect supplier compliance",0,0,0,0,0,0,0,0,0,0,0 12153,103,Increase business awareness through inclusion within the new starter induction and regular business training,0,0,0,0,0,0,0,0,0,0,0 12153,104,Management process in place for lack of adherence to Cranky Healths Modern Slavery standards,0,0,0,0,0,0,0,0,0,0,0 12153,105,Process of Consultation This statement has been prepared in consultation with relevant subject-matter experts of Cranky Health and Custom Foods,0,0,0,0,0,0,0,0,0,0,1 12153,106,This statement has been reviewed and approved for publishing by the Cranky Health board,1,0,0,0,0,0,0,0,0,0,0 1797,91,The Road Map Over the next three years Hunter Water has identified actions to further assess and address modern slavery risks: An organisation wide training needs analysis will be conducted to determine training and awareness requirements across roles and responsibilities,0,0,0,0,0,0,0,1,0,0,0 1797,92,Training will be undertaken in accordance with Hunter Waters Learning Management System,0,0,0,0,0,0,0,1,0,0,0 1797,93,"Awareness and Training Actions to integrate modern slavery requirements in to procurement processes, conduct supply chain risk profiling and updating of policies and guidelines is planned along with engagement with identified high risk suppliers",0,0,0,0,0,0,0,1,0,0,0 1797,94,Procurement and Supply Chain Hunter Water will integrate modern slavery risk management as a compliance requirement in to the Enterprise Risk Management framework,0,0,0,0,0,0,0,1,0,0,0 1797,95,External independent review of our modern slavery management processes is planned to assess action effectiveness,0,0,0,0,0,0,0,0,0,1,0 1797,96,"Hunter Water has committed to working with our suppliers, other regional organisations and the broader water industry to drive collaboration, improve sustainability performance and increase modern slavery awareness",0,0,0,0,0,0,0,1,0,0,0 1797,97,These actions will be critical to advancing the Hunter Water Modern Slavery Road Map,0,0,0,0,0,0,0,0,0,0,0 1797,98,"Hunter Water will review all relevant policies, procedures, contracts and customer feedback / grievance mechanisms to ensure modern slavery obligations are captured, and concerns can be raised confidentially and managed appropriately",0,0,0,0,0,0,0,0,0,1,0 3961,82,"The provider is entitled to be reimbursed for costs associated with worker engagement and mobilisation (eg travel, medical); IN 2020, QSA REVIEWED THE PROCESS BY WHICH ITS OPERATING COMPANY, NACAP, ENGAGES LOCAL LABOUR TO SUPPORT ITS PNG OPERATIONS",0,0,0,0,0,0,0,0,0,0,0 3961,83,Prohibition of solicitation of payments from prospective employees to guarantee employment; and,0,0,0,0,0,0,0,1,0,0,0 3961,84,"Provision of accommodation by Nacaps client or the ultimate client, being the same or similar standard provided to Nacap for its project management staff",0,0,0,0,0,0,0,1,0,0,0 3961,85,Nacap also has direct contact with the workers which affords them opportunity to raise concerns of human rights or other violations,0,0,0,0,0,0,0,1,0,0,0 3961,86,"Based on our review and for the reasons described above, the Group considers there to be low risk of modern slavery within its arrangements for sourcing and engaging PNG labour",0,0,0,0,0,0,1,0,0,0,0 3961,87,Nacap also sources labour from countries other than Australia and PNG to support its PNG operations,0,0,0,0,0,1,0,0,0,0,0 3961,88,"This labour consists of mainly skilled, semi-professional and professional workers, and is mostly sourced from Indonesia and Philippines, either directly by Nacap on a referral basis, or seconded via the same Australian-based labour-hire company used to procure local labour",0,0,0,0,0,1,0,0,0,0,0 3961,89,The Group will report further on these arrangements in a future modern slavery statement,0,0,0,0,0,0,0,0,0,0,0 7771,28,Finance,0,0,0,0,0,0,0,0,0,0,0 7771,29,Information Technology,0,0,0,0,0,0,0,0,0,0,0 7771,30,Human Resources,0,0,0,0,0,0,0,0,0,0,0 7771,31,Risk Management,0,0,0,0,0,0,0,0,0,0,0 7771,32,"Commercial Services - Procurement, Legal",0,0,0,0,0,0,0,0,0,0,0 7771,33,Legal and Secretariat - Privacy,0,0,0,0,0,0,0,0,0,0,0 7771,34,Marketing,0,0,0,0,0,0,0,0,0,0,0 7771,35,Digital Product and Experience,0,0,0,0,0,0,0,0,0,0,0 12153,107,Tony Duthie,0,0,0,0,0,0,0,0,0,0,0 12153,108,Anthony Mortimer Chairman,0,0,0,0,0,0,0,0,0,0,0 12153,109,Chief Operating Officer,0,1,0,0,0,0,0,0,0,0,0 14984,0,Risen Energy (Australia) Pty Ltd ACN 168 750 374 ABN 97 168 750 374 Email: info@risenenergy.com.au www.risenenergy.com.au,0,0,0,0,0,0,0,0,0,0,0 14984,1,Modern Slavery Statement 2022,0,0,0,0,0,0,0,0,0,0,0 14984,2,"Purpose The purpose of this statement, made pursuant to section 13 of the Australian Modern Slavery Act 2018 (Cth) (the Act), is to ensure Risen Energy (Australia) Pty Ltds (ABN 97 168 750 372) (Risen Energy, we, our or us) commitment, to utilising ethical suppliers and ensuring that any modern slavery risks in Risen Energys operations and supply chains are identified and that steps are taken to assess and address these risks",0,0,0,0,0,0,0,0,0,0,0 14984,3,This statement covers reporting period of 1 January 2022 31 December 2022,0,0,0,0,0,0,0,0,0,0,0 14984,4,"Modern slavery captures situations where coercion, threats or deception are used to exploit victims and undermine or deprive them of their freedom and includes the following categories of serious exploitation: trafficking in persons, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruiting for labour or services, and the worst forms of child labour",0,0,0,0,0,0,0,0,0,0,0 1797,99,Due Diligence Engagement and Collaboration Governance,0,0,0,0,0,0,0,0,0,0,0 1797,100,"PAGE 16 MODERN SLAVERY STATEMENT 2019-20 OUR EFFECTIVENESS In order to deliver on our commitments for combating modern slavery risks in our supply chains and our operations, we consistently monitor and assess our progress and effectiveness",0,0,0,0,0,0,0,0,0,1,0 1797,101,We do this through,0,0,0,0,0,0,0,0,0,1,0 1797,102,our governance and assurance processes,0,0,0,0,0,0,0,0,0,1,0 1797,103,our internal and external reporting mechanisms,0,0,0,0,0,0,0,0,0,1,0 1797,104,our organisational risk and threat identification processes,0,0,0,0,0,0,0,0,0,1,0 1797,105,our engagement and collaboration with internal and external stakeholders,0,0,0,0,0,0,0,0,0,1,0 1797,106,Governance and reporting Our enterprise level assurance processes capture modern slavery risk and compliance will be visible and accountable up through our Executive Management Team and Board of Directors,0,0,0,0,0,0,0,0,0,1,0 3961,90,"15 QUANTA SERVICES AUSTRALIA MODERN SLAVERY STATEMENT ACTIONS TAKEN TO ASSESS AND ADDRESS THE RISKS During 2020, QSA embarked on a program to review and update the Groups practices and procedures to ensure they reflect the risks posed by modern slavery within the Groups supply chains and in the construction industry more generally",0,0,0,0,0,0,0,0,0,0,0 3961,91,Available at: https://investors.quantaservices.com/governance/governance-documents TRAINING PROGRAM QSAs internal legal team commenced a staff training program that provided a general awareness of global modern slavery practices,0,0,0,0,0,0,0,1,0,0,0 3961,92,"This included providing a link to an ABC Four Corners documentary on modern slavery in the United Kingdom The Hunt for Britains Slave Gangs, which all employees were encouraged to watch",0,0,0,0,0,0,0,1,0,0,0 3961,93,"Furthermore, a training session was made available to all staff on the requirements and intent of the Modern Slavery Act 2018, and the Groups approach to identify and mitigate modern slavery risk and comply with its statutory requirements",0,0,0,0,0,0,0,1,0,0,0 3961,94,PROCUREMENT PROCESS QSA has incorporated modern slavery provisions into standard Group procurement processes and documentation,0,0,0,0,0,0,0,1,0,0,0 3961,95,"This includes updating and standardising the Groups Request for Quotation (RFQ) template across all operating entities, which is used to procure subcontractors and equipment for all projects",0,0,0,0,0,0,0,1,0,0,0 3961,96,"When responding to RFQs, prospective subcontractors and suppliers are required to answer questions regarding steps taken to prevent human rights abuses and initiatives or strategies they have adopted to identify, assess, address or remedy actual or potential modern slavery in their operations or supply chains",0,0,0,0,0,0,0,1,0,0,0 3961,97,MODERN SLAVERY WORKING COMMITTEE Underpinning these actions was the establishment of a Modern Slavery Working Committee which is chaired by a senior lawyer within QSA and includes a committee member from each of the Group operating companies,0,0,0,0,0,0,0,1,0,0,0 7771,36,"Fundraising and philanthropy Community, Corporate Partnerships",0,0,0,0,0,0,0,0,0,0,0 7771,37,"Strategy, Policy and Reform Policy and Advocacy, Evaluation and Research, Strategy and Planning, Strategic Communications",0,0,0,0,1,0,0,0,0,0,0 7771,38,"Technology (hardware, software and cloud services)",0,0,0,0,0,1,0,0,0,0,0 7771,39,Professional services consultants who provide a service directly to Beyond Blue,0,0,0,0,0,1,0,0,0,0,0 7771,40,Contractors and sub- contractors who provide research and evaluation services,0,0,0,0,0,1,0,0,0,0,0 7771,41,Office consumables,0,0,0,0,0,0,0,0,0,0,0 7771,42,Promotional merchandise Programs and Services,0,0,0,0,0,0,0,0,0,0,0 7771,43,Wellness and Prevention/Community Participation: Education Be You Blue Voices Speakers Volunteers Workplace Partnerships and Engagement Heads Up Community engagement activities,0,0,0,0,1,0,0,0,0,0,0 14984,5,"Risen Energy is committed to eradicating Modern Slavery, breaches of human rights, and wage theft",0,0,0,0,0,0,0,0,0,0,0 14984,6,"Mandatory Criteria 1 and 2: Identity, Structure, Operations and Supply Chains This Statement covers the reporting entity Risen Energy which has no subsidiaries",0,0,1,1,0,0,0,0,0,0,0 14984,7,Risen Energy is part of a larger corporate body (The Risen Group) including several entities in Australia (per explained as follows),0,0,0,1,0,0,0,0,0,0,0 14984,8,"Risen Energy Australia Holdings Pty Ltd, which owns",0,0,0,1,0,0,0,0,0,0,0 14984,9,Risen Energy (the reporting entity),0,0,1,1,0,0,0,0,0,0,0 14984,10,Risen Energy Development Pty Ltd,0,0,0,1,0,0,0,0,0,0,0 14984,11,Risen Energy EPC Pty Ltd,0,0,0,1,0,0,0,0,0,0,0 14984,12,Risen Energy Service Pty Ltd,0,0,0,1,0,0,0,0,0,0,0 1797,107,Our Sustainable Procurement Working Group will be responsible for allocation and monitoring of progress on delivering the actions within our Modern Slavery Action Plan,0,0,0,0,0,0,0,0,0,1,0 1797,108,Our policies and contracts will be updated in 2020-21 to enable us to address modern slavery legislative compliance across our operations and into our supply chain,0,0,0,0,0,0,0,1,0,0,0 1797,109,"In addition to internal processes, we are progressing awareness campaigns under the Modern Slavery Action Plan to measure competency and awareness of our employees across all levels of our organisation",0,0,0,0,0,0,0,1,0,1,0 1797,110,"We are also undertaking activities to assess our suppliers capabilities in modern slavery risk identification and mitigation in their supply chains via supplier checklists based on our Minimum, Progressing and Leading requirements",0,0,0,0,0,0,0,1,0,1,0 1797,111,Threats and opportunities We are actively identifying threats and opportunities relating to modern slavery risk management in our internal and external engagements,0,0,0,0,0,0,0,1,0,0,0 1797,112,"We assess and manage risk as a part of our Enterprise Risk Management framework, including reporting on risk appetite through to our Audit and Risk Committee",0,0,0,0,0,0,0,1,0,0,0 1797,113,"We will also undertake an annual review of our supplier spend data to inform priorities for continued identification, assessment and improvements to modern slavery risk mitigation through our internal business processes and the way we engage with our suppliers, our customers and our community",0,0,0,0,0,0,0,0,0,1,0 1797,114,Engagement and collaboration We are undertaking a number of internal and external engagement activities that will support effective collaboration in assessing and mitigating modern slavery risks,0,0,0,0,0,0,0,1,0,0,0 3961,98,"The Committee provides a forum for the operating entities to interface, consult, raise awareness, undertake the tasks required by the Act to ensure the Group complies with its legal obligations, and provide recommendations to management which are consistent with meeting the Acts requirements and philosophies",0,0,0,0,0,0,0,1,0,0,0 3961,99,"Each committee member is required to liaise with relevant stakeholders and staff within their operating unit to identify modern slavery risks within individual supply chains / operations, attend committee meetings and contribute to and/or support the development of the Statement",0,0,0,0,0,0,0,1,0,0,0 3961,100,SUBCONTRACT SUITE QSA has added mandatory clauses to its standard form subcontract terms and conditions to ensure subcontractors and suppliers are contractually obligated to notify any instances of modern slavery detected within their operations and supply chains and take steps to attempt to remedy them,0,0,0,0,0,0,0,1,0,0,0 3961,101,GOVERNANCE The Groups commitment to addressing modern slavery risks in its operations is aligned with its overarching risk management framework,0,0,0,0,0,0,0,0,0,0,0 3961,102,"QSA requires its operating entities, directors, officers and employees to maintain high standards of ethical conduct in all of their business activities",0,0,0,0,0,0,0,1,0,0,0 3961,103,This includes a commitment to business practices being conducted in accordance with the highest possible ethical standards which is reflected though Quanta Services Code of Ethics and Business Conduct,0,0,0,0,0,0,0,1,0,0,0 3961,104,"QSA is also committed to respecting and promoting human rights for all its employees, affiliates and partners, in accordance with the United Nations Guiding Principles on Business and Human Rights, the International Labour Organizations Declaration on Fundamental Principles and Rights at Work, and legislation relating to human rights",0,0,0,0,0,0,0,1,0,0,0 3961,105,"QSA is bound by Quanta Services Code of Ethics and Business Conduct and Anticorruption Compliance Policy, Human Rights Policy and Non-Discrimination, Anti- Harassment and Anti-Retaliation Policy",0,0,0,0,0,0,0,1,0,0,0 7771,44,"Services and Supports: 24/7 Support Service NewAccess Suicide Prevention - The Way Back Support Service, Online Communities Beyond Now Coronavirus Mental Wellbeing Support Service",0,0,0,0,1,0,0,0,0,0,0 7771,45,Contractors and sub- contractors who deliver services to our community,0,0,0,0,0,1,0,0,0,0,0 7771,46,Our approach Beyond Blue has zero tolerance for any form of slavery-like practices,0,0,0,0,0,0,0,0,0,0,0 7771,47,We have established the following governance process to provide the Board oversight of the implementation phase as we embed requirements into Beyond Blues existing corporate governance processes,0,0,0,0,0,0,0,1,0,0,0 7771,48,"The Commercial Services Team has consulted, and will continue to consult, with the operational areas of the business to assist with the assessment of modern slavery risks",0,0,0,0,0,0,0,1,0,0,0 7771,49,"Modern slavery has been identified as specific risk within Beyond Blues Risk Management Framework and incorporated into its new risk management system, and therefore will be assessed regularly as part of the ongoing review of Beyond Blues business risks; and",0,0,0,0,0,0,0,1,0,0,0 7771,50,"Reports will be made annually to Beyond Blues Audit, Finance and Risk Committee on compliance against this Statement",0,0,0,0,0,0,0,1,0,0,0 7771,51,Our policies and procedures We have formal policies already in place that are intended to promote ethical and legally compliant business conduct,0,0,0,0,0,0,0,1,0,0,0 14984,13,Risen Energy Australia Project Holding Nominee Pty Ltd,0,0,0,1,0,0,0,0,0,0,0 14984,14,"Risen Energy Australia Project Holding Nominee Pty Ltd, which is the sole shareholder of each of the following trustee companies",0,0,0,1,0,0,0,0,0,0,0 14984,15,Darlington Point BESS Pty Ltd,0,0,0,1,0,0,0,0,0,0,0 14984,16,Darlington Point Land Pty Ltd,0,0,0,1,0,0,0,0,0,0,0 14984,17,Wagga Wagga Solar Farm Nominee Pty Ltd,0,0,0,1,0,0,0,0,0,0,0 14984,18,Moama Solar Farm Trust Nominee Pty Ltd,0,0,0,1,0,0,0,0,0,0,0 14984,19,Moama Land Trust Nominee Pty Ltd,0,0,0,1,0,0,0,0,0,0,0 14984,20,Bungama Land Trust Nominee Pty Ltd,0,0,0,1,0,0,0,0,0,0,0 1797,115,We will conduct awareness and refresher training across our organisation for all employees,0,0,0,0,0,0,0,1,0,0,0 1797,116,"We have established cross-functional responsibility for implementation of actions under our Modern Slavery Action Plan and Road Map, led by our Sustainable Procurement Working Group",0,0,0,0,0,0,0,1,0,0,0 1797,117,We have engaged externally with other water utilities to collaborate and leverage opportunities and efficiencies for applying modern slavery risk management across the same supply chains where possible,0,0,0,0,0,0,0,1,0,0,0 1797,118,"We are also engaging with industry bodies and regional sustainability groups, such as local government agencies and local businesses to build awareness, share ideas and experiences",0,0,0,0,0,0,0,1,0,1,0 1797,119,"HUNTER WATER 17 At Hunter Water, we are taking positive action through a cross-functional approach in identifying and mitigating modern slavery risks from our supply chains and through our operations to ensure we are compliant with the Modern Slavery Act 2018 (Cth)",0,0,0,0,0,0,0,0,0,0,0 1797,120,"The progress that we have made, and the action that we are committed to in our Modern Slavery Action Plan and Road Map is inextricably linked to the organisational values we model through our behaviours, and which guide our decision-making and the ways that we operate",0,0,0,0,0,0,0,0,0,0,0 1797,121,"OUR CONCLUDING COMMENTS Building on the successful implementation of actions from our Modern Slavery Action Plan for the 2019-20 reporting period, we will progress our Road Map initiatives through the 2020-21 reporting period, actively identifying and addressing modern slavery risks, and ensuring our actions prove effective in combating modern slavery in our operations and the operations of our supply chains",0,0,0,0,0,0,0,0,0,0,0 1797,122,PAGE 18 MODERN SLAVERY STATEMENT 2019-20,0,0,0,0,0,0,0,0,0,0,0 3961,106,"QSAs local operating entities also have their own local policy frameworks that address code of conduct, anti-harassment, equal opportunity, anti-bullying and grievance resolution for the Australian legislative context",0,0,0,0,0,0,0,1,0,0,0 3961,107,"In 2020, QSA also introduced a Whistle-blower Policy providing a reporting framework for personnel to raise any concerns that they may have in relation to misconduct or any other improper acts by Group personnel, without fear of detriment or recrimination",0,0,0,0,0,0,0,1,0,0,0 3961,108,"This includes, but is not limited to, human rights abuses",0,0,0,0,0,0,0,1,0,0,0 3961,109,17 QUANTA SERVICES AUSTRALIA MODERN SLAVERY STATEMENT The Groups focus in its first modern slavery reporting year has been to establish processes to identify and address the risks of modern slavery within its operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 3961,110,The assessment of the effectiveness of this process will be monitored over the course of the next 12 months and reported within future modern slavery statements,0,0,0,0,0,0,0,0,0,0,0 3961,111,Training provided by the Groups legal team has been well-attended by employees,0,0,0,0,0,0,0,0,0,1,0 3961,112,"The Modern Slavery Working Committee has also been effective in keeping an ear close to the ground and raising awareness of potential human rights violations within the Australian construction industry, including a recent example of public allegations made against a company which the Group has engaged on past projects",0,0,0,0,0,0,0,1,0,0,0 3961,113,ASSESSMENT,0,0,0,0,0,0,0,0,0,0,0 7771,52,"Our policies contribute to our commitment to prevent violations of human rights such as modern forms of slavery in our business including our Code of Conduct, Whistleblower Policy, Corporate Partnership Policy and Procurement Policy",0,0,0,0,0,0,0,1,0,0,0 7771,53,We have procurement and legal processes in place to minimise the risk of modern slavery occurring in our operations and supply chain,0,0,0,0,0,0,0,1,0,0,0 7771,54,"Potential risks in our operations and supply chains Since 2020, we have engaged in a review of potential risks of modern slavery practices across our operations and supply chains",0,0,0,0,0,0,0,1,0,0,0 7771,55,"During the assessment process, we have considered/are considering risks that may possibly cause, contribute and/or be directly linked to modern slavery practices",0,0,0,0,0,0,0,1,0,0,0 7771,56,"We are also taking into consideration other risk factors such as the sector, industry, types of products and services, geographic locations and business models",0,0,0,0,0,0,0,1,0,0,0 7771,57,"Beyond Blue has been able to identify areas with no or low risk, for example, in any operational activities that are directly undertaken by Beyond Blue employees and covered by our internal processes",0,0,0,0,0,0,1,0,0,0,0 7771,58,"An initial assessment of Beyond Blues main risks in relation to Modern Slavery relate to the procurement of IT equipment, merchandise and printing",0,0,0,0,0,0,1,0,0,0,0 7771,59,Beyond Blue has consulted the relevant companies we own or control in the development of this statement (the Beyond Blue Depression Research Ancillary Fund Trust),0,0,0,0,0,0,1,0,0,0,1 14984,21,Bungama BESS Trust Nominee Pty Ltd,0,0,0,1,0,0,0,0,0,0,0 14984,22,Campbell Forest Project Pty Ltd; DocuSign Envelope ID: 9714B3FC-DE88-4657-A83C-1C0FD6AF6F64,0,0,0,1,0,0,0,0,0,0,0 14984,23,Page 2,0,0,0,0,0,0,0,0,0,0,0 14984,24,Version: 1,0,0,0,0,0,0,0,0,0,0,0 14984,25,Active Date: 2 November 2023,0,0,0,0,0,0,0,0,0,0,0 14984,26,Page 2 of 7,0,0,0,0,0,0,0,0,0,0,0 14984,27,Campbell Forest Project Holdco Pty Ltd,0,0,0,1,0,0,0,0,0,0,0 14984,28,"Coleambally BESS Pty Ltd Risen Energys registered office is located at Level 11, 307 Queen Street, Brisbane QLD 4000",0,0,0,1,0,0,0,0,0,0,0 1973,0,Flinders Port Holdings Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 1973,1,"page 3 Introduction page 5 Our structure, operations and supply chains page 10 Our actions to assess and address modern slavery risks page 11 Our performance page 13 Continuous improvement page 12 Consultation within the Group page 14 Looking ahead Flinders Port Holdings page 7 Identifying the risks of modern slavery practices page 16 Appendix A",0,0,0,0,0,0,0,0,0,0,0 1973,2,"Introduction Being socially responsible is important to Flinders Port Holdings Pty Ltd (Flinders Port Holdings) and subsidiary companies identified in Appendix A (together, the Group)",0,0,0,0,0,0,0,0,0,0,0 1973,3,The Group recognises its role and responsibility in addressing the risk of modern slavery practices in its operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 1973,4,"The Group is committed to high standards of ethical conduct and strives to uphold human rights, fair working conditions and to engage in sustainable and environmentally sound business practices",0,0,0,0,0,0,0,0,0,0,0 1973,5,The Group endeavours to always operate responsibly and expects the same from its suppliers,0,0,0,0,0,0,0,0,0,0,0 1973,6,"As part of its sustainability commitments, the Group is committed to embedding sustainable practices across its operations, including engaging with its suppliers to improve social practices across its supply chain",0,0,0,0,0,0,0,1,0,0,0 1973,7,"Each of Flinders Port Holdings and Flinders Ports Pty Ltd (FP) are Reporting Entities for the purposes of the Modern Slavery Act 2018 (Cth) (Modern Slavery Act) and this is their first, joint, Modern Slavery Statement (Statement), submitted for the purposes of the reporting requirement in the Modern Slavery Act",0,0,1,1,0,0,0,0,0,0,0 3961,114,OF THE EFFECTIVENESS OF THE GROUPS ACTIONS,0,0,0,0,0,0,0,0,0,0,0 3961,115,19 QUANTA SERVICES AUSTRALIA MODERN SLAVERY STATEMENT FUTURE COMMITMENTS,0,0,0,0,0,0,0,0,0,0,0 3961,116,MODERN SLAVERY WORKING COMMITTEE The Modern Slavery Working Committee will be the representing body across our business to build upon the processes set up in 2020,0,0,0,0,0,0,0,0,0,0,0 3961,117,"The Committee will meet quarterly and report to the Chief Operating Officer, QSA",0,0,0,0,0,0,0,0,0,0,0 3961,118,"For YE 2021, the Committees Charter includes",0,0,0,0,0,0,0,0,0,1,0 3961,119,Benchmarking the Group against industry,0,0,0,0,0,0,0,0,0,1,0 3961,120,Mapping of common suppliers across the business to provide increased opportunity for more detailed risk assessments for the Groups operations,0,0,0,0,0,0,0,1,0,0,0 3961,121,Identifying supply chains by industry or geography that require deeper risk assessment,0,0,0,0,0,0,0,0,0,0,0 7771,60,It is noted that the entity does not form part of a supply chain and does not present a material risk in these terms,0,0,0,0,0,0,1,0,0,0,0 7771,61,"Addressing the risk of modern slavery practices We are incorporating our approach to address the various risks of modern slavery practices in our corporate governance processes eg procurement, legal, contracts and risk management",0,0,0,0,0,0,0,1,0,0,0 7771,62,This will help ensure that our organisation has robust and effective processes that are firmly embedded in how we do business,0,0,0,0,0,0,0,1,0,0,0 7771,63,"Beyond Blues template procurement request for proposal, service agreements and purchase order terms and conditions have already been amended to help ensure that our service providers are meeting their modern slavery obligations",0,0,0,0,0,0,0,1,0,0,0 7771,64,"Future commitments: Over the next year, our key focus areas will be",0,0,0,0,0,0,0,1,0,0,0 7771,65,Continuing the ongoing assessment of our modern slavery supply chain risks,0,0,0,0,0,0,0,1,0,0,0 7771,66,"Considering appropriate stakeholder engagement on this issue, as part of revisions to the organisational policy framework and the learning and development program",0,0,0,0,0,0,0,1,0,0,0 7771,67,This might include delivering appropriate awareness training sessions on modern slavery principles to relevant Beyond Blue staff and key suppliers/service providers; and,0,0,0,0,0,0,0,1,0,0,0 14984,29,"The Risen Group is headquartered in Ningbo, China with key hubs in Hong Kong, Singapore and Australia",0,0,0,1,0,0,0,0,0,0,0 14984,30,"The parent company Risen Energy Co., Ltd is listed on the Shenzhen Stock Exchange (SZSE)",0,0,0,0,0,0,0,0,0,0,0 14984,31,"The Risen Group has over 10,760 employees globally and is present in over 7 countries including China, Germany, Australia, Mexico, India, USA and Japan",0,0,0,1,1,0,0,0,0,0,0 14984,32,"In this reporting period, Risen Energy had a workforce of 22 full-time-equivalents",0,0,0,0,1,0,0,0,0,0,0 14984,33,Risen Energy is not currently engaged with any casual or contracted staff but from time to time engages with temporary workers,0,0,0,0,1,1,0,0,0,0,0 14984,34,Risen Energy has 2 staff members working in an arrangement where their visa ties them to the business,0,0,0,0,1,0,0,0,0,0,0 14984,35,"Operations Risen Energy develops solar farms, constructs solar farms, invests in solar farms, provides solar panels to wholesalers and constructors of utility solar farms, operates and maintains solar farms, and owns solar farms which sell green energy through wholesale power purchase agreements",0,0,0,0,1,0,0,0,0,0,0 14984,36,"Our business includes manufacturing, sales, development, construction and operation and maintenance so we cover the full breadth of this industry",0,0,0,0,1,0,0,0,0,0,0 1973,8,"This Statement describes the actions taken by those entities, and the entities they control, to identify, manage and mitigate the risks of modern slavery in their operations and supply chain during the financial year ending 30 June 2020 (reporting period)",0,0,0,0,0,0,0,0,0,0,0 1973,9,JOHN MARLAY JOHN MARLAY CHAIRMAN FLINDERS PORT HOLDINGS,0,0,0,0,0,0,0,0,0,0,0 1973,10,Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 1973,11,Tonnes of Cargo shipped through our Ports in 2019/20 Flinders Port Holdings,0,0,0,0,1,0,0,0,0,0,0 1973,12,"Modern Slavery Statement Our structure, operations and supply chains About Us Flinders Port Holdings is South Australias leading port infrastructure provider and a diversified marine, stevedoring and logistics group, playing an integral role in the economic development of the state and the wellbeing of its port communities",0,0,0,0,1,0,0,0,0,0,0 1973,13,The Group owns and operates ports in Port Adelaide and across regional South Australia and provides related services to facilitate the movement of port related cargo across the supply chain,0,0,0,0,1,0,0,0,0,0,0 1973,14,"These services are provided by a number of subsidiaries within the Group, including but not limited to FP, Flinders Logistics Pty Ltd, Flinders Warehousing & Distribution Pty Ltd and Flinders Adelaide Container Terminal Pty Ltd",0,0,0,1,0,0,0,0,0,0,0 1973,15,Group Structure & Operations This Statement applies to each company within the Group,0,0,0,0,0,0,0,0,0,0,0 3961,122,Reviewing the effectiveness of the Groups actions; and,0,0,0,0,0,0,0,0,0,0,0 3961,123,Developing roadmaps for continuous improvement,0,0,0,0,0,0,0,0,0,0,0 3961,124,The Committee also provides a platform for Group personnel to source information and ask questions about modern slavery,0,0,0,0,0,0,0,1,0,0,0 3961,125,POLICIES AND PROCEDURES QSA will review policies and procedures of each Group company and those of Quanta Services to consider introduction of local (Australian) policies and / or procedures for the Group to address modern slavery and human rights abuses,0,0,0,0,0,0,0,0,0,1,0 3961,126,"An action has been taken to update subcontractor prequalification processes to include questions about modern slavery, so that such risks may be evaluated prior to the RFQ phase of procurement, which may prompt subcontractors to be more proactive to modern slavery risks",0,0,0,0,0,0,0,1,0,0,0 3961,127,Deeper analysis of the Groups procurement spend data will be undertaken in the 2021 reporting year to commence mapping supply chain risk,0,0,0,0,0,0,0,1,0,0,0 3961,128,"Characteristics for consideration include industry, commodity, geography, labour engagement model, labour type (low-skilled, skilled, semi- professional, professional)",0,0,0,0,0,0,0,1,0,0,0 3961,129,"A supplier and subcontractor rating or evaluation system on modern slavery, for all stages of procurement (pre-qualification, RFQ response, contract negotiations, and performance evaluation) is also being considered",0,0,0,0,0,0,0,1,0,0,0 7771,68,Incorporating requirements into existing assurance processes,0,0,0,0,0,0,0,1,0,0,0 7771,69,This Statement was approved by Beyond Blues Board of Directors on 7 December 2021,1,0,0,0,0,0,0,0,0,0,0 7771,70,The Hon Julia Gillard AC (Board Chair),0,1,0,0,0,0,0,0,0,0,0 8585,0,MODERN SLAVERY STATEMENT PAGE 1 (08) 6166 2400 IMCPL.COM.AU MODERN SLAVERY STATEMENT DCL Corp Pty Ltd & Iron Mine Group of Companies for the Financial Year 30 June 2021,0,0,0,0,0,0,0,0,0,0,0 8585,1,MODERN SLAVERY STATEMENT PAGE 1,0,0,0,0,0,0,0,0,0,0,0 8585,2,OUR COMMITMENT,0,0,0,0,0,0,0,0,0,0,0 8585,3,REPORTING ENTITY OVERVIEW,0,0,0,0,0,0,0,0,0,0,0 8585,4,OUR OPERATIONS AND SUPPLY CHAIN,0,0,0,0,0,0,0,0,0,0,0 14984,37,"Risen Energy is committed to corporate social responsibility, including eliminating modern slavery",0,0,0,0,0,0,0,0,0,0,0 14984,38,Risen Energy has a vision to foster sustainable development and make lives better by bringing electricity powered by the sun to people worldwide,0,0,0,0,0,0,0,0,0,0,0 14984,39,Supply Chains Risen Energys core business involves the sale and supply of solar modules,0,0,0,0,1,0,0,0,0,0,0 14984,40,"Our supply chain consists of corporate services; warehouse, transport and logistic services; electricity equipment and supplies including solar panels",0,0,0,0,0,1,0,0,0,0,0 14984,41,The main product distributed by Risen Energy in 2022 was Photovoltaic (PV) modules which are manufactured by our parent company in China these are the devices that convert sunlight into electrical energy,0,0,0,0,0,1,0,0,0,0,0 14984,42,"The production of PV modules includes the following products: cells, wafers, ingots, polysilicon, metallurgical silicon, and quartzite",0,0,0,0,0,1,0,0,0,0,0 14984,43,We source these products from a range of suppliers including other entities in The Risen Group,0,0,0,0,0,1,0,0,0,0,0 14984,44,"Our suppliers are based in China (mainly Inner Mongolia, Zhejiang, Jiangsu, Sichuan and Yunnan provincial areas) and Germany",0,0,0,0,0,1,0,0,0,0,0 1973,16,Flinders Port Holdings is ranked as one of South Australias top 10 companies,0,0,0,0,1,0,0,0,0,0,0 1973,17,"The Group has an annual turnover of more than $200 million and as at the end of the reporting period, employed approximately 695 people",0,0,0,1,1,0,0,0,0,0,0 1973,18,"Through our operations, we facilitate the movements of circa $25 billion of trade, which is equivalent to 94% of South Australias international trade and 24% of the states Gross State Product (GSP)",0,0,0,0,1,0,0,0,0,0,0 1973,19,Our approach to modern slavery The Group is committed to ensuring that risks of modern slavery practices in our operations and supply chains are effectively identified and addressed,0,0,0,0,0,0,0,0,0,0,0 1973,20,"The term modern slavery is used in the Modern Slavery Act 2018 (Cth) to describe situations where coercion, threats or deception are used to seriously exploit victims and undermine or deprive them of their freedom",0,0,0,0,0,0,0,0,0,0,0 1973,21,The Modern Slavery Act defines modern slavery as including eight types of serious exploitation,0,0,0,0,0,0,0,0,0,0,0 1973,22,trafficking in persons,0,0,0,0,0,0,0,0,0,0,0 1973,23,slavery,0,0,0,0,0,0,0,0,0,0,0 3961,130,"TRAINING QSA will provide annual training and presentations, which will be recorded and made available to new employees through the induction process",0,0,0,0,0,0,0,1,0,0,0 3961,131,Targeted training is being considered for employees involved in supply chain management and procurement,0,0,0,0,0,0,0,1,0,0,0 3961,132,"TIER 2 RISKS The Group will investigate and consider if there are opportunities to use buying power to leverage improved supply chain risk assessment and mitigation by its direct suppliers, particularly suppliers that provide products and services that the Group identifies as having medium to high modern slavery risk",0,0,0,0,0,0,0,1,0,0,0 3961,133,"NEW MARKETS The Group is considering further project opportunities outside of Australia, as well as expanding its operations in Papua New Guinea",0,0,0,0,0,0,0,0,0,0,0 3961,134,QSA recognises that additional scrutiny will be required in the recruitment of labour and selection of suppliers in less developed nations,0,0,0,0,0,0,0,0,0,0,0 3961,135,"Should these opportunities materialise, the Groups actions and the effectiveness of such, will be addressed in future statements",0,0,0,0,0,0,0,0,0,0,0 3961,136,MARK BUMPSTEAD DIRECTOR & PRESIDENT QUANTA SERVICES AUSTRALIA Signed on behalf of the Directors of Quanta Services Australia This Statement has been prepared in consultation with each operating entity and has been approved by the Board of Directors for Mears Group Pty Ltd as principal governing body of the Quanta Services Australia group of companies,1,1,0,0,0,0,0,0,0,0,1 3961,137,"#WEARE QUANTA WWW.QUANTASERVICES.COM/AUSTRALIA Level 1, 599 Doncaster Road Doncaster VIC 3108 Australia",0,0,0,1,0,0,0,0,0,0,0 8585,5,RISKS OF MODERN SLAVERY IN OUR OPERATIONS AND SUPPLY CHAIN,0,0,0,0,0,0,0,0,0,0,0 8585,6,ACTIONS TAKEN BY IRON MINE SERVICES TO ASSESS AND ADDRESS,0,0,0,0,0,0,0,0,0,0,0 8585,7,PROCESS OF CONSULTATION,0,0,0,0,0,0,0,0,0,0,0 8585,8,IMPACT OF COVID-19 ON OUR FY21 STATEMENT,0,0,0,0,0,0,0,0,0,0,0 8585,9,ASSESSING THE EFFECTIVENESS OF OUR ACTIONS,0,0,0,0,0,0,0,0,0,0,0 8585,10,STATEMENT APPROVAL TABLE OF CONTENTS,0,0,0,0,0,0,0,0,0,0,0 8585,11,"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",0,0,0,0,1,0,0,0,0,0,0 8585,12,We and our indigenous Joint Venture partners have been delivering projects to Tier 1 Resource clients since 2013,0,0,0,0,1,0,0,0,0,0,0 14984,45,"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",0,0,0,0,0,1,0,0,0,0,0 14984,46,"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",0,0,0,0,0,1,0,0,0,0,0 14984,47,Risen Energy Services core business is the operation and asset management of solar farms,0,0,0,0,1,0,0,0,0,0,0 14984,48,Risen Energy Services supply chains consist of field and maintenance services; corporate services; consulting services,0,0,0,0,0,1,0,0,0,0,0 14984,49,"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",0,0,0,0,0,0,0,0,0,0,0 14984,50,"Here we identify where our higher risk areas may be, before we discuss how we have assessed and addressed those risks",0,0,0,0,0,0,0,0,0,0,0 14984,51,Operations We understand that renewable energy industries are considered high-risk industries in relation to modern slavery,0,0,0,0,0,0,1,0,0,0,0 14984,52,"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",0,0,0,0,0,0,1,0,0,0,0 1973,24,servitude,0,0,0,0,0,0,0,0,0,0,0 1973,25,forced marriage,0,0,0,0,0,0,0,0,0,0,0 1973,26,forced labour,0,0,0,0,0,0,0,0,0,0,0 1973,27,debt bondage,0,0,0,0,0,0,0,0,0,0,0 1973,28,the worst forms of child labour; and,0,0,0,0,0,0,0,0,0,0,0 1973,29,deceptive recruiting for labour or services,0,0,0,0,0,0,0,0,0,0,0 1973,30,"Our approach focuses on embedding our modern slavery response as a core element of the Groups values, culture and conduct",0,0,0,0,0,0,0,0,0,0,0 1973,31,Modern Slavery Statement 05,0,0,0,0,0,0,0,0,0,0,0 4128,0,RJ Vincent (RJV) Modern Slavery Statement 2020,0,0,0,0,0,0,0,0,0,0,0 4128,1,Table of Contents,0,0,0,0,0,0,0,0,0,0,0 4128,2,Introduction,0,0,0,0,0,0,0,0,0,0,0 4128,3,Structure,0,0,0,0,0,0,0,0,0,0,0 4128,4,Business Outline,0,0,0,0,0,0,0,0,0,0,0 4128,5,Workforce,0,0,0,0,0,0,0,0,0,0,0 4128,6,Supply Chain,0,0,0,0,0,0,0,0,0,0,0 4128,7,Policies and Procedures,0,0,0,0,0,0,0,0,0,0,0 8585,13,"Our client operations we support are typically are present in gold, iron ore and oil & gas sectors",0,0,0,0,1,0,0,0,0,0,0 8585,14,OUR COMMITMENT We are committed to social responsibility matters and recognizes the importance of human rights and opposes slavery of all forms,0,0,0,0,0,0,0,0,0,0,0 8585,15,"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",0,0,0,0,0,0,0,0,0,0,0 8585,16,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 2,0,0,0,0,0,0,0,0,0,0,0 8585,17,Reporting Entity Overview,0,0,0,0,0,0,0,0,0,0,0 8585,18,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),0,0,1,0,0,0,0,0,0,0,0 8585,19,"Our registered office located in Mt Lawley, WA and our financial year period is 1 July 2020 to 30 June 2021",0,0,0,1,0,0,0,0,0,0,0 8585,20,The corporate structure is outlined below and this combined statement covers all named entities,0,0,0,0,0,0,0,0,0,0,0 14984,53,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,0,0,0,0,0,0,0,0,0,0,0 14984,54,These were not Risen Group products DocuSign Envelope ID: 9714B3FC-DE88-4657-A83C-1C0FD6AF6F64,0,0,0,0,0,0,0,0,0,0,0 14984,55,Page 3,0,0,0,0,0,0,0,0,0,0,0 14984,56,Version: 1,0,0,0,0,0,0,0,0,0,0,0 14984,57,Active Date: 2 November 2023,0,0,0,0,0,0,0,0,0,0,0 14984,58,Page 3 of 7,0,0,0,0,0,0,0,0,0,0,0 14984,59,and we are not aware that is any connection with any aspects of our supply chain,0,0,0,0,0,0,0,0,0,0,0 14984,60,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,0,0,0,0,0,0,0,1,0,0,0 1973,32,"Our structure, operations and supply chains Supply Chain In the reporting period, the Group made payments to approximately 773 suppliers",0,0,0,0,0,1,0,0,0,0,0 1973,33,The Groups major categories of procurement included,0,0,0,0,0,1,0,0,0,0,0 1973,34,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,0,0,0,0,0,1,0,0,0,0,0 1973,35,Our small number of overseas vendors used in the reporting period were predominantly Original Equipment Manufacturers and suppliers of related spare parts,0,0,0,0,0,1,0,0,0,0,0 1973,36,"% 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",0,0,0,0,0,1,0,0,0,0,0 1973,37,"(including hardware, software and services) 3.25% Hire/Lease of Fleet & Equipment 1.18% Utilities 0.05% Travel",0,0,0,0,0,0,0,0,0,0,0 1973,38,"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",0,0,0,0,0,0,0,0,0,0,0 1973,39,"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",0,0,0,0,0,0,0,0,0,0,0 4128,8,Whistleblower Policy,0,0,0,0,0,0,0,0,0,0,0 4128,9,Potential Risks,0,0,0,0,0,0,0,0,0,0,0 4128,10,Actions,0,0,0,0,0,0,0,0,0,0,0 4128,11,Actions Taken in FY20,0,0,0,0,0,0,0,0,0,0,0 4128,12,Commitment,0,0,0,0,0,0,0,0,0,0,0 4128,13,Measure of Effectiveness,0,0,0,0,0,0,0,0,0,0,0 4128,14,Introduction Ralmana Pty Ltd trading as R.J,0,0,0,0,0,0,0,0,0,0,0 4128,15,"Vincent & Co (RJV) ABN 93009149106 and its subsidiaries, value excellence, safety, respect, effort, teamwork and accountability",0,0,0,0,0,0,0,0,0,0,0 8585,21,"For the purposes of reference across this statement, we will refer to the whole group, including DCL Corp Pty Ltd as Iron Mine Contracting",0,0,0,0,0,0,0,0,0,0,0 8585,22,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%,0,0,0,1,0,0,0,0,0,0,0 8585,23,"MODERN SLAVERY STATEMENT PAGE 3 Headquartered in Bayswater, Western Australia and employs over 300 people across project and workshop operations in Western Australia",0,0,0,1,1,0,0,0,0,0,0 8585,24,"Indigenous Partnerships Australia (IPA) is an affiliate company, formed with the express purpose of partnering with Traditional Owner businesses across Australia",0,0,0,0,1,0,0,0,0,0,0 8585,25,"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",0,0,0,0,0,0,0,0,0,0,0 8585,26,"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",0,0,0,0,0,1,0,0,0,0,0 8585,27,Equipment & fleet hire,0,0,0,0,0,1,0,0,0,0,0 8585,28,Consultancy,0,0,0,0,0,1,0,0,0,0,0 14984,61,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,0,0,0,0,0,0,0,0,0,0,0 14984,62,The steps we are taking in this regard are detailed below,0,0,0,0,0,0,0,0,0,0,0 14984,63,"In relation to our own employees, direct employees in Australia are engaged either by contract or under award agreements",0,0,0,0,0,0,0,1,0,0,0 14984,64,Our employees are free to associate with their respective union,0,0,0,0,0,0,0,1,0,0,0 14984,65,Risen Energy also offers its employees independent financial consulting,0,0,0,0,0,0,0,1,0,0,0 14984,66,"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",0,0,0,0,0,0,0,1,0,0,0 14984,67,"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",0,0,0,0,0,0,1,0,0,0,0 14984,68,We also acknowledge that our use of temporary workers on occasion is an area we need to monitor closely,0,0,0,0,0,0,1,0,0,0,0 1973,40,Risks that the Group may contribute to modern slavery practices include any acts or omissions that may facilitate or incentivise modern slavery,0,0,0,0,0,0,0,0,0,0,0 1973,41,"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)",0,0,0,0,0,0,0,0,0,0,0 1973,42,"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",0,0,0,0,0,0,0,0,0,0,0 1973,43,"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)",0,0,0,0,0,0,0,0,0,0,0 1973,44,"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)",0,0,0,0,0,0,0,0,0,0,0 1973,45,"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",0,0,0,0,0,0,0,0,0,0,0 1973,46,Entity risks: factors such as poor governance that may contribute to some entities (ie customers or suppliers) having particular modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 1973,47,Identifying the risks of modern slavery practices 07,0,0,0,0,0,0,0,0,0,0,0 4128,16,"These values are the foundation of how we conduct ourselves and interact with each other, our clients, suppliers, contractors and other stakeholders",0,0,0,0,0,0,0,0,0,0,0 4128,17,RJV is subject to the Modern Slavery Act 2018 that commenced operation on 1 January 2019,0,0,1,0,0,0,0,0,0,0,0 4128,18,"The Act requires reporting entities subject to the Act, to produce an annual modern slavery statement",0,0,0,0,0,0,0,0,0,0,0 4128,19,Our first annual statement is due on the 31st March 2021,0,0,0,0,0,0,0,0,0,0,0 4128,20,"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",0,0,0,0,0,0,0,0,0,0,0 4128,21,"We reject any and all forms of modern slavery which can take the form of unpaid or underpaid servitude, human trafficking and forced labour",0,0,0,0,0,0,0,0,0,0,0 4128,22,"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",0,0,0,0,0,0,0,0,0,0,0 4128,23,"In FY20, we started a detailed analysis of the risk of Modern Slavery in RJV operations and supply chain",0,0,0,0,0,0,1,0,0,0,0 8585,29,"Equipment parts, components and spares",0,0,0,0,0,1,0,0,0,0,0 8585,30,External labour & subcontractors,0,0,0,0,0,1,0,0,0,0,0 8585,31,PPE,0,0,0,0,0,1,0,0,0,0,0 8585,32,Workshop consumables and tooling,0,0,0,0,0,1,0,0,0,0,0 8585,33,Tyres & Rims,0,0,0,0,0,1,0,0,0,0,0 8585,34,IT equipment and consumables,0,0,0,0,0,1,0,0,0,0,0 8585,35,Transportation services,0,0,0,0,0,1,0,0,0,0,0 8585,36,Facilities,0,0,0,0,0,1,0,0,0,0,0 14984,69,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,0,0,0,0,0,0,0,0,0,0,0 14984,70,"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",0,0,0,0,0,0,1,0,0,0,0 14984,71,We have described our supply chains as set out above,0,0,0,0,0,0,0,0,0,0,0 14984,72,"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",0,0,0,0,0,0,1,0,0,0,0 14984,73,"We also consider some local suppliers may pose a higher risk such as suppliers of coffee and tea, cleaning, stationery and furniture",0,0,0,0,0,0,1,0,0,0,0 14984,74,We note that Germany and Australia are ranked by the global slavery index as having a low prevalence of modern slavery,0,0,0,0,0,0,1,0,0,0,0 14984,75,"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",0,0,0,0,0,0,1,0,0,0,0 14984,76,Risen Energy acknowledges that our supply chains extend beyond those that we have direct contractual relationships with,0,0,0,0,0,0,0,0,0,0,0 1973,48,"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)",0,0,0,0,0,0,0,1,0,0,0 1973,49,"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",0,0,0,0,0,0,0,0,0,0,0 1973,50,"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",0,0,0,0,0,0,0,1,0,0,0 1973,51,Operations The Group employs most of its workforce directly,0,0,0,0,1,0,0,0,0,0,0 1973,52,"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",0,0,0,0,1,0,0,0,0,0,0 1973,53,"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",0,0,0,0,0,0,0,0,0,0,0 1973,54,"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",0,0,0,0,0,0,0,0,0,0,0 1973,55,"However, these practices may be an indication of serious exploitation, or may escalate into modern slavery if not addressed",0,0,0,0,0,0,0,0,0,0,0 4128,24,"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",0,0,0,0,0,0,1,0,0,0,0 4128,25,"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",0,0,0,0,0,0,0,0,0,0,0 4128,26,"We value and observe all laws regarding corporate social responsibility, environmental and workplace safety protection, staff inclusion and diversity",0,0,0,0,1,0,0,0,0,0,0 4128,27,The statement supports the Australian governments work on modern slavery,0,0,0,0,0,0,0,0,0,0,0 4128,28,Structure 2.1,0,0,0,0,0,0,0,0,0,0,0 4128,29,Business Outline,0,0,0,0,0,0,0,0,0,0,0 4128,30,"RJV is a privately owned Western Australian company, based at 4-5 Kirke St Balcatta WA 6021",0,0,0,1,0,0,0,0,0,0,0 4128,31,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,0,0,0,0,1,0,0,0,0,0,0 8585,37,Recruitment,0,0,0,0,0,1,0,0,0,0,0 8585,38,Office supplies and staff amenities,0,0,0,0,0,1,0,0,0,0,0 8585,39,"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",0,0,0,0,0,1,0,0,0,0,0 8585,40,Earthmoving construction services Ore and mineral production Sustainable Outcomes Mining Support Services CIVIL CONSTRUCTION CRUSHING SCREENING INDIGENOUS PARTNERSHIP MINING CONTRACTING MINING SITE SERVICES,0,0,0,0,1,0,0,0,0,0,0 8585,41,"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",0,0,0,0,0,0,1,0,0,0,0 8585,42,% of our workforce resides and is employed in operations in Australia,0,0,0,0,1,0,0,0,0,0,0 8585,43,"Additionally, the Code of Ethics Policy commits all employees and those we work with, to not use forced, compulsory or child labour",0,0,0,0,0,0,0,1,0,0,0 8585,44,"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",0,0,0,0,0,1,1,1,0,0,0 14984,77,"We intend to commence interrogating and reviewing our second and third tier suppliers in future reporting periods, such as solar cell and wafer suppliers",0,0,0,0,0,0,0,1,0,0,0 14984,78,We also acknowledge the ongoing impact of the COVID-19 pandemic,0,0,0,0,0,0,0,0,0,0,0 14984,79,We understand that the effects of same continue to increase the vulnerability of workers around the world and place pressure on supply chains,0,0,0,0,0,0,0,0,0,0,0 14984,80,Mandatory Criteria 4: Actions to Assess and Address Risks Risen Energy is committed to taking efforts to assess and address the risks identified above,0,0,0,0,0,0,0,0,0,0,0 14984,81,We have adopted a continuous improvement approach,0,0,0,0,0,0,0,0,0,0,0 14984,82,"In May 2021, Sheffield Hallam University published a comprehensive report on Uyghur Forced Labour and Global Solar Supply Chains",0,0,0,0,0,0,0,1,0,0,0 14984,83,Following that report Risen Energy had productive and positive conversations with several tier 1 suppliers and members of The Risen Group located in China,0,0,0,0,0,0,0,1,0,0,0 14984,84,"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",0,0,0,0,0,0,0,1,0,0,0 1973,56,"Accordingly, we seek to also assess and address the risk of these practices",0,0,0,0,0,0,0,0,0,0,0 1973,57,"From time to time, the Group uses third party labour-hire arrangements to supplement our workforce and support our operations",0,0,0,0,0,1,1,0,0,0,0 1973,58,We recognise that we have less visibility and control over these workers and their employment terms and conditions,0,0,0,0,0,0,1,0,0,0,0 1973,59,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,0,0,0,0,0,0,0,1,0,0,0 1973,60,"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",0,0,0,0,1,0,0,0,0,0,0 1973,61,"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",0,0,0,0,0,0,1,0,0,0,0 1973,62,"However, this risk is likely reduced in the Australian context, due to our more remote geographic location",0,0,0,0,0,0,1,0,0,0,0 1973,63,"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",0,0,0,0,0,0,0,1,0,0,0 4128,32,"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",0,0,0,0,1,0,0,0,0,0,0 4128,33,"RJV has become a partner of choice through our diversified capability in the resources sector including gold, iron ore and mineral sands",0,0,0,0,1,0,0,0,0,0,0 4128,34,With a highly experienced and stable leadership group we bring a knowledge base and stability rarely seen in mining,0,0,0,0,0,0,0,0,0,0,0 4128,35,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,0,0,0,0,1,0,0,0,0,0,0 4128,36,"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",0,0,0,0,0,0,0,0,0,0,0 4128,37,"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",0,0,0,0,1,0,0,0,0,0,0 4128,38,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,0,0,0,0,0,0,0,0,0,0,0 4128,39,Our scope of services cover,0,0,0,0,1,0,0,0,0,0,0 8585,45,"According to the Global Slavery Index 2018 (GSI), Australia has a very low prevalence of modern slavery",0,0,0,0,0,0,0,0,0,0,0 8585,46,"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",0,0,0,0,0,1,1,0,0,0,0 8585,47,"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",0,0,0,0,0,1,1,0,0,0,0 8585,48,"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% % % % % %",0,0,0,0,0,1,1,0,0,0,0 8585,49,"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",0,0,0,0,0,0,0,0,0,1,0 8585,50,"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",0,0,0,0,0,0,0,1,0,0,0 8585,51,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,0,0,0,0,0,0,0,1,0,0,0 8585,52,This policy is communicated through a variety of methods including,0,0,0,0,0,0,0,1,0,0,0 14984,85,Our close involvement with the sources of these materials means we have a much greater level of oversight regarding the operations of those suppliers,0,0,0,0,0,0,0,0,0,0,0 14984,86,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-1C0FD6AF6F64,0,0,0,0,0,0,0,0,0,0,0 14984,87,Page 4,0,0,0,0,0,0,0,0,0,0,0 14984,88,Version: 1,0,0,0,0,0,0,0,0,0,0,0 14984,89,Active Date: 2 November 2023,0,0,0,0,0,0,0,0,0,0,0 14984,90,Page 4 of 7,0,0,0,0,0,0,0,0,0,0,0 14984,91,slavery standards,0,0,0,0,0,0,0,0,0,0,0 14984,92,"Around the world, international investors are increasingly tying their investment in renewable energy projects to similar human rights obligations",0,0,0,0,0,0,0,0,0,0,0 1973,64,Modern Slavery Statement 9 to maritime safety are upheld,0,0,0,0,0,0,0,1,0,0,0 1973,65,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,0,0,0,0,0,0,0,1,0,0,0 1973,66,"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)",0,0,0,0,0,0,0,1,0,0,0 1973,67,"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",0,0,0,0,0,0,0,1,0,0,0 1973,68,"Supply Chain In order to assist us to better understand our modern slavery risk in our supply chain, taking account of the Australian Governments guidance, we developed and sent a tailored modern slavery questionnaire to a sample group of our higher volume Tier 1 suppliers to test the usefulness of responses received",0,0,0,0,0,0,0,1,0,0,0 1973,69,"The responses received have helped to further refine this modern slavery supplier questionnaire for ongoing use during future reporting periods, including as we incorporate it into our supplier onboarding processes",0,0,0,0,0,0,0,1,0,0,0 1973,70,"To further assist us to scope our modern slavery risk in our supply chain in line with the regulatory guidance, we evaluated sector and industry risk, as well as product and services risk, to determine our high-risk procurement categories",0,0,0,0,0,0,0,1,0,0,0 1973,71,We also considered the relative % of total spend in each of the identified at-risk categories,0,0,0,0,0,0,0,1,0,0,0 4128,40,Load and Haul Operations,0,0,0,0,0,0,0,0,0,0,0 4128,41,Bulk Earthworks & Rehabilitation,0,0,0,0,0,0,0,0,0,0,0 4128,42,Urban Development,0,0,0,0,0,0,0,0,0,0,0 4128,43,Tunnels & Bridges,0,0,0,0,0,0,0,0,0,0,0 4128,44,Underground Services,0,0,0,0,0,0,0,0,0,0,0 4128,45,Road Construction,0,0,0,0,0,0,0,0,0,0,0 4128,46,Culvert Installation,0,0,0,0,0,0,0,0,0,0,0 4128,47,Drill and Blast,0,0,0,0,0,0,0,0,0,0,0 8585,53,As part of the onboarding process for new employees and contractors,0,0,0,0,0,0,0,1,0,0,0 8585,54,The Code of Ethics policy is displayed at all project offices; and,0,0,0,0,0,0,0,1,0,0,0 8585,55,"All of the mentioned documents are hosted and updated as required on the IMS company Additionally, our Recruitment and Selection Procedure details the responsibilities of our HR department to complete for all employees a pre-employment verification process that includes validation of identification of potential ID and age of potential employees",0,0,0,0,0,0,0,1,0,0,0 8585,56,"Our Subcontractor Onboarding checklist provides for the same verification of all our subcontractors identification and ages for labour hire, short term workers and personnel seeking to attend any of our projects",0,0,0,0,0,0,0,1,0,0,0 8585,57,"Supplier Assessment and On-Boarding Our actions across our suppliers were primarily geared around assessment and identification mechanisms through reporting, due diligence on new supplier on-boarding and supplier reviews",0,0,0,0,0,0,0,1,0,0,0 8585,58,A spend and category analysis for FY21 was undertaken on organizational spend footprint which helped to inform and assess our potential exposure and risks across our supply chain as already highlighted in 4,0,0,0,0,0,0,0,1,0,0,0 8585,59,"Risks of Modern Slavery in our Supply Chain Further to this, at supplier level, we updated our contractor management system, MyOSH, to incorporate screening of new suppliers to ascertain process and policies in place in relation to addressing modern slavery and ethical sourcing within their organization",0,0,0,0,0,0,0,1,0,0,0 8585,60,"Our procurement team maintains and conducts a schedule of business review meetings (BRM) across our key supplier relationships which enables a forum to identify and manage supply risks, including modern slavery",0,0,0,0,0,0,0,1,0,0,0 14984,93,Risen Energy has engaged external experts to closely follow the NSW Anti-Slavery Commissioners proposal of a Renewable Energy Code of Practice so that we can ensure steps we take in our modern slavery approach are consistent with best practice industry standards that are being discussed in those forums,0,0,0,0,0,0,0,0,0,1,0 14984,94,Values Our values include,0,0,0,0,0,0,0,0,0,0,0 14984,95,"Respect: respect everyones culture, background, time and privacy to build a foundation of mutual trust and a positive environment",0,0,0,0,0,0,0,0,0,0,0 14984,96,"Care: show utmost care about our work, our personal wellbeing, our team, our stakeholders, the community and the environment",0,0,0,0,0,0,0,0,0,0,0 14984,97,"Improvement: we commit to continuous improvement of our company, our products and our solutions",0,0,0,0,0,0,0,0,0,0,0 14984,98,"Excellence: we commit to being a renewable powerhouse by fostering the best practices, robust policies and developing world-class products and solutions",0,0,0,0,0,0,0,0,0,0,0 14984,99,"We believe that the culture of Risen Energy as embedded in these values is one that fosters and supports a strong approach to identifying, assessing and addressing modern slavery risks",0,0,0,0,0,0,0,0,0,0,0 14984,100,The renewable energy industry is one that we believe is very focussed on sustainability and taking care of the world,0,0,0,0,0,0,0,0,0,0,0 1973,72,"Impact of COVID-19 on our supply chain During the COVID-19 pandemic, the Groups focus has been maintaining the safety of its employees and other persons accessing or using our sites whilst maintaining our operations which are critical to the state",0,0,0,0,0,0,0,0,0,0,0 1973,73,The Groups initial response involved the procurement team identifying critical supplies to ensure continued support of the Groups operations and taking steps to secure those supplies,0,0,0,0,0,0,0,0,0,0,0 1973,74,"Recognising the possibility of increased exposure to modern slavery risk due to the impacts of COVID-19 on global supply chains, in particular increased pressures on suppliers and availability of supply, the Group continued, where possible, to secure supply from its qualified preferred suppliers",0,0,0,0,0,0,1,1,0,0,0 1973,75,Demands and lack of available supply (in particular for Personal Protective Equipment) did require procurement of a minimal amount of supplies from outside of the Groups preferred suppliers,0,0,0,0,0,0,1,0,0,0,0 1973,76,The amount procured was negligible,0,0,0,0,0,0,1,0,0,0,0 1973,77,"Procurement staff were made aware of the heightened risk of modern slavery when demand necessitated procurement outside of the Groups approved supplier list, and made additional enquiries as required",0,0,0,0,0,0,1,0,0,0,0 1973,78,Our actions to assess and address modern slavery risks Assessing the effectiveness of our actions,0,0,0,0,0,0,0,0,0,0,0 1973,79,OUR PLAN We developed a high-level plan for addressing our risks of modern slavery in our supply chain and operations in the reporting period (modern slavery response plan) which relevant staff have had responsibility for designing and implementing,0,0,0,0,0,0,0,1,0,0,0 4128,48,Project & Statutory Management,0,0,0,0,0,0,0,0,0,0,0 4128,49,Tailings Storage Facility Construction,0,0,0,0,0,0,0,0,0,0,0 4128,50,Hard Rock Quarry Operations,0,0,0,0,0,0,0,0,0,0,0 4128,51,Haul Road Construction & Maintenance,0,0,0,0,0,0,0,0,0,0,0 4128,52,ROM & Waste Dump Management,0,0,0,0,0,0,0,0,0,0,0 4128,53,Topsoil Removal & Management,0,0,0,0,0,0,0,0,0,0,0 4128,54,Concrete Installation and Removal,0,0,0,0,0,0,0,0,0,0,0 4128,55,Crusher Feed,0,0,0,0,0,0,0,0,0,0,0 8585,61,"To date however, no issue in relation to directly impacting us on modern slavery has arisen through these review meetings",0,0,0,0,0,0,1,0,0,0,0 8585,62,"Major Investment in Systems and Reporting We commenced a transformational review in FY21 and business case development to upgrade our enterprise business systems that would uplift reporting capability, improved integration and supporting business processes",0,0,0,0,0,0,0,1,0,1,0 8585,63,We anticipate that the enhancement in reporting capability and analytics will have help contribute to refining ongoing Modern Slavery risk identification and assessment across our supply chain,0,0,0,0,0,0,0,0,0,0,0 8585,64,"ACTIONS TAKEN BY IRON MINE SERVICES TO ASSESS AND ADDRESS In developing this Statement, we engaged and informed key functional areas (Procurement, Business Systems, Human Resources, HSEQ, Indigenous Partnerships, Finance, Commercial, Operations) across Iron Mine Services and its affiliated joint ventures",0,0,0,0,0,0,0,0,0,0,0 8585,65,Reviews of the statement were conducted by senior leadership members as to the Board of Directors,0,0,0,0,0,0,0,0,0,0,0 8585,66,PROCESS OF CONSULTATION,0,0,0,0,0,0,0,0,0,0,0 8585,67,"MODERN SLAVERY STATEMENT PAGE 6 During COVID19, the business experienced increased organic growth to meet increased client opportunities in the WA mining sector",0,0,0,0,0,0,0,0,0,0,0 8585,68,"With the additional focus in supporting our workforce through the pandemic and managing global supply risk disruptions impacting our supply chain, more comprehensive and targeted supplier engagement and educational initiatives to assess and address modern slavery were limited despite our best endeavors",0,0,0,0,0,0,0,0,0,1,0 14984,101,Whilst we are aware of the high-risks within our industry we believe the very values that underpin this industry are surely aligned to protective approaches to human rights and as such we are optimistic as to progress in this space,0,0,0,0,0,0,0,0,0,0,0 14984,102,Policies and Procedures We understand that staff play a key role in our due diligence,0,0,0,0,0,0,0,0,0,0,0 14984,103,"We have a range of policies applicable to all staff that further our approach to modern slavery directly but also that ensure our workplace generally aligns with legal and ethical workplace requirements including our: Modern Slavery Policy; Anti-bribery Policy; Whistleblower Protection Policy; Grievance Policy; Anti-discrimination, bullying and harassment Policy; Code of Business Conduct and Ethics",0,0,0,0,0,0,0,1,0,0,0 14984,104,Our Modern Slavery Policy refers to the UN Global Compact and Ethical Trading Initiative Base Code as underpinning our procurement policies,0,0,0,0,0,0,0,1,0,0,0 14984,105,"It generally provides our commitments to our own workforce as well as to identifying, assessing, and addressing risks in our supply chain",0,0,0,0,0,0,0,1,0,0,0 14984,106,"Our Code of Business Conduct and Ethics speaks to compliance with laws, improper personal gains/benefits, conflicts of interest, insider trading, competition and fair dealing, confidentiality, gifts/donations, record-keeping, proper use of assets, discrimination and harassment, environment, health and safety, money laundering, and suspicious activities",0,0,0,0,0,0,0,1,0,0,0 14984,107,It also explicitly prohibits any form of forced and child labour and provides avenues through which employees can report any illegal or unethical behaviour,0,0,0,0,0,0,0,1,0,0,0 14984,108,All employees have to sign off on a certificate of compliance with the Code of Business Conduct and Ethics,0,0,0,0,0,0,0,1,0,0,0 1973,80,The diagram below captures the core elements of that plan,0,0,0,0,0,0,0,1,0,0,0 1973,81,Our modern slavery response plan takes a targeted and continuous improvement approach that focusses on our Tier 1 suppliers and on key areas and associated tasks,0,0,0,0,0,0,0,1,0,0,0 1973,82,Flinders Port Holdings,0,0,0,0,0,0,0,0,0,0,0 1973,83,Conducting modern slavery risk assessment,0,0,0,0,0,0,0,1,0,0,0 1973,84,Undertaking supplier onboarding and contract review,0,0,0,0,0,0,0,1,0,1,0 1973,85,Developing policies and procedures,0,0,0,0,0,0,0,1,0,0,0 1973,86,Conducting training/awareness,0,0,0,0,0,0,0,1,0,0,0 1973,87,Establishing reporting channels,0,0,0,0,0,0,0,1,0,0,0 4128,56,"Workforce At the end of FY20 RJV had a workforce totalling approximately 160 people, employed on a full time equivalency basis",0,0,0,1,0,0,0,0,0,0,0 4128,57,This included 120 employed directly and approximately 40 employed through a number of local specialised labour hire companies,0,0,0,0,0,1,0,0,0,0,0 4128,58,"RJV has policies and procedures in place to ensure that all direct employees are screened, on- boarded and employed in a manner that mitigates the risk of Modern Slavery",0,0,0,0,0,0,0,1,0,0,0 4128,59,"Under our terms and conditions, all labour hire suppliers are required to comply with RJV policies and code of conduct",0,0,0,0,0,0,0,1,0,0,0 4128,60,"The business strives to ensure that all employees and contractors are aware of their rights and responsibilities by providing information, policies and a grievance mechanism for individuals to raise concerns and a process to resolve any issues raised",0,0,0,0,0,0,0,1,0,0,0 4128,61,Supply Chain During FY20 RJV began working on an analysis to review probability of the risk of Modern Slavery occurring within the supply chain,0,0,0,0,0,0,0,0,0,0,0 4128,62,The risk within the business is minimised by the fact that all business services are conducted solely within Western Australia,0,0,0,0,0,0,1,0,0,0,0 4128,63,"Machinery used in civil construction are sourced from Tier 1 suppliers, that have offices based in Australia and have advanced policies and procedures in place, along with quality systems",0,0,0,0,0,1,0,0,0,0,0 8585,69,IMPACT OF COVID19- ON FY21 STATEMENT Clinton Keenan Chief Executive Officer (Signing as authorised Responsible Member),0,1,0,0,1,0,0,0,0,0,0 8585,70,ASSESSING THE EFFECTIVENESS OF OUR ACTIONS The ongoing effectiveness of Modern Slavery assessment and continuous improvement implementation will be coordinated by the Procurement function with support of the leadership team,0,0,0,0,0,0,0,0,0,1,0 8585,71,"As FY21 is our first statement, we remain committed to reviewing our progress against actions moving forward",0,0,0,0,0,0,0,0,0,0,0 8585,72,"Process mechanisms that already exist within our business to gauge the effectiveness and validity of a range of actions outlined in our statement, include but not limited to",0,0,0,0,0,0,0,0,0,1,0 8585,73,Scheduled internal policy reviews and updates,0,0,0,0,0,0,0,0,0,1,0 8585,74,Grievance investigation process,0,0,0,0,0,0,0,0,0,1,0 8585,75,Supplier review meetings,0,0,0,0,0,0,0,0,0,1,0 8585,76,"STATEMENT APPROVAL This Statement is made on behalf of Iron Mine Contracting for the financial year ending 30 June 2021 and it has been approved by our governing body, the Board of Directors on 31st May 2022",1,0,0,0,0,0,0,0,0,0,0 14984,109,We understand that the nature of modern slavery is that victims and witnesses are often powerless to come forward,0,0,0,0,0,0,0,0,0,0,0 14984,110,Our Whistleblower Protection Policy is a particularly key part of our approach to modern slavery in that it provides a safe reporting avenue free of retribution,0,0,0,0,0,0,0,1,0,0,0 14984,111,We have updated both our Whistleblower Protection Policy and Grievance Policy to include human rights related complaints,0,0,0,0,0,0,0,1,0,0,0 14984,112,"Training We have engaged key business representatives and raised awareness across the group by implementing a training program for all staff, through which we publicise all new and updated policies and procedures relating to modern slavery",0,0,0,0,0,0,0,1,0,0,0 14984,113,"We are also preparing a more in-depth training program, with sessions to occur once per fortnight in DocuSign Envelope ID: 9714B3FC-DE88-4657-A83C-1C0FD6AF6F64",0,0,0,0,0,0,0,1,0,0,0 14984,114,Page 5,0,0,0,0,0,0,0,0,0,0,0 14984,115,Version: 1,0,0,0,0,0,0,0,0,0,0,0 14984,116,Active Date: 2 November 2023,0,0,0,0,0,0,0,0,0,0,0 1973,88,Developing a modern slavery reponse plan,0,0,0,0,0,0,0,1,0,0,0 1973,89,Reviewing actions against the plan,0,0,0,0,0,0,0,0,0,1,0 1973,90,"Modern Slavery Statement Our performance Consistent with our continuous improvement approach, our modern slavery response plan for the reporting period targeted our highest priority tasks, that is, identifying and addressing our risks of modern slavery in our operations and supply chain",0,0,0,0,0,0,0,0,0,0,0 1973,91,Our team have worked hard in the reporting period to undertake the following tasks that are relevant to our modern slavery response plan,0,0,0,0,0,0,0,0,0,0,0 1973,92,PLAN FY 19/20 TASKS,0,0,0,0,0,0,0,0,0,0,0 1973,93,ASSESS & IDENTIFY Risk assessment We undertook a supply chain modern slavery risk assessment exercise- focussing on our Tier 1 suppliers and trialling a risk assessment tool,0,0,0,0,0,0,0,1,0,0,0 1973,94,Due diligence We tested a supplier modern slavery questionnaire on a sample group of Tier 1 suppliers to be included in supplier onboarding documentation,0,0,0,0,0,0,0,1,0,0,0 1973,95,"ACTION Training and capacity building We trained relevant staff (including delivering training sessions for the Group Leadership Team and procurement team) on identifying and addressing the risk of modern slavery practices, and on modern slavery legislative compliance",0,0,0,0,0,0,0,1,0,0,0 4128,64,"Parts are purchased to service and maintain this equipment and these parts are all sourced from local suppliers, as are uniforms and other business consumables",0,0,0,0,0,1,0,0,0,0,0 4128,65,"Service providers including Labour hire who source labour and services locally, predominantly work under RJVs Audited Safety, Quality and Environment systems",0,0,0,0,0,1,0,0,0,0,0 4128,66,RJV has a subcontractor and supplier prequalification process which must be completed for any business that will be providing goods and services,0,0,0,0,0,0,0,1,0,0,0 4128,67,This process includes agreement to Modern slavery requirements,0,0,0,0,0,0,0,1,0,0,0 4128,68,"Terms and conditions are currently under review and being updated where necessary, to ensure that suppliers and contractors are made aware and have systems in place to meet these requirements",0,0,0,0,0,0,0,1,0,0,0 4128,69,"Policies and Procedures RJV does not tolerate any form of slavery, human trafficking, forced or child labour",0,0,0,0,0,0,0,0,0,0,0 4128,70,We have formal policies in place that are intended to promote the values of the business along with ethical and legally compliant business conduct,0,0,0,0,0,0,0,0,0,0,0 4128,71,Our policies contribute to our commitment to prevent,0,0,0,0,0,0,0,1,0,0,0 14984,117,Page 5 of 7,0,0,0,0,0,0,0,0,0,0,0 14984,118,person or via videoconference for the whole of Risen Energy to spread awareness on our anti-slavery requirements,0,0,0,0,0,0,0,1,0,0,0 14984,119,We have also created a Frequently Asked Question/Template Response document for our staff which spans 14 questions and which we hope will increase awareness as to our internal modern slavery approach and commitments,0,0,0,0,0,0,0,1,0,0,0 14984,120,We provide recognition for individual staff members who go above and beyond expectations in advocating for robust ethical sourcing,0,0,0,0,0,0,0,1,0,0,0 14984,121,Suppliers We have been working to communicate Risen Energys intention to take action to assess and address the risk of modern slavery in its supply chain through cooperation with our suppliers and clients to optimise their own approaches to their supply chains,0,0,0,0,0,0,0,1,0,0,0 14984,122,"We are focussing first on conducting a review process of critical suppliers, obtaining relevant information from those suppliers (for example, a particular panel manufacturer and its suppliers)",0,0,0,0,0,0,0,1,0,0,0 14984,123,"We have in place a supplier code of conduct which clearly details to our suppliers our expectations regarding modern slavery, human rights, labour practices, environmental responsibility, consumer safety, ethical conduct and data and privacy",0,0,0,0,0,0,0,1,0,0,0 14984,124,We advise suppliers that failure to comply may prompt us to reassess our relationship with the supplier,0,0,0,0,0,0,0,0,1,0,0 1973,96,Policy and procedure development We developed a Sustainability Policy and Ethical Sourcing Policy,0,0,0,0,0,0,0,1,0,0,0 1973,97,We commenced planning for,0,0,0,0,0,0,0,1,0,0,0 1973,98,the development of a Supplier Code of Conduct; and,0,0,0,0,0,0,0,1,0,0,0 1973,99,a review of procurement policies and procedures to incorporate anti-modern slavery requirements,0,0,0,0,0,0,0,1,0,1,0 1973,100,We revised our Group Whistleblower Policy,0,0,0,0,0,0,0,1,0,1,0 1973,101,"Supplier contract review and revision We included specific modern slavery compliance clauses in our template supplier agreements and in new/varied supplier contracts, including ensuring dispute resolution clauses include appropriate remediation options where a supplier is in breach of a modern slavery compliance clause",0,0,0,0,0,0,0,1,1,0,0 1973,102,Supplier onboarding We developed a pre-qualification supplier questionnaire and developed modern slavery related RFX questions (a set of questions requiring mandatory response as part of our formal market approach),0,0,0,0,0,0,0,1,0,0,0 1973,103,"Reporting channels We established an outsourced whistleblower reporting portal, FairCall, enabling reporting by internal and external parties",0,0,0,0,0,0,0,1,0,0,0 4128,72,"violations of human rights in our business, they including our Code of Conduct, Whistle-blower Policy and Corporate Social Responsibility Policy",0,0,0,0,0,0,0,1,0,0,0 4128,73,"Our policies set out conduct expectations and apply to all employees, contractors and consultants",0,0,0,0,1,0,0,1,0,1,0 4128,74,These policies are reviewed and updated on a regular basis to ensure that they remain current and compliant,0,0,0,0,0,0,0,1,0,1,0 4128,75,"Whistleblower Policy RJV values the people who work within the business and encourages a culture of openness, where employees can raise concerns about any business conduct or practices",0,0,0,0,0,0,0,1,0,0,0 4128,76,"The Whistleblower policy establishes a mechanism, so that staff and contractors can freely and anonymously (if desired) report conduct that goes against the ethics and values of the business",0,0,0,0,0,0,0,1,0,0,0 4128,77,This includes raising any concerns of Modern Slavery within the RJV supply chain,0,0,0,0,0,0,0,1,0,0,0 4128,78,Potential Risks In preparation for our first annual statement RJV are reviewing potential risks of modern slavery practices across our operations and supply chains using the RJV Risk Management Framework,0,0,0,0,0,0,0,1,0,0,0 4128,79,"During this assessment process, we have considered risks that may possibly cause, contribute or be directly linked to modern slavery practices",0,0,0,0,0,0,0,1,0,0,0 14984,125,It is also a mechanism through which we can request relevant information as to compliance and monitor this on an ongoing basis,0,0,0,0,0,0,0,1,0,1,0 14984,126,"We have also created modern slavery clauses and covenants for supply contract templates in our Australian operations, requiring suppliers to comply with the Act, implement appropriate controls and notify Risen Energy immediately if they become aware of any modern slavery within their own supply chains",0,0,0,0,0,0,0,1,0,0,0 14984,127,We are in the process of conducting reviews and updating all of our contract templates to ensure they include these clauses,0,0,0,0,0,0,0,1,0,0,0 14984,128,"In 2022, we also worked to map the part of our supply chain that relates to PV modules, given the suppliers of polysilicon have been identified as an area we need to ensure we have as complete as possible oversight of",0,0,0,0,0,0,0,1,0,0,0 14984,129,"We intend to interrogate and review second and third tier suppliers, such as those providing solar cell and wafers, in future reporting periods",0,0,0,0,0,0,0,1,0,0,0 14984,130,We aim to focus specifically on suppliers policies and procedures around worker labour and payroll conditions; factory audits of workplace practices; and processes for developing cooperative solutions that meet international human rights standards,0,0,0,0,0,0,0,1,0,0,0 14984,131,We have developed a modern slavery self-assessment template which enables us to undertake a risk assessment of our suppliers through a questionnaire and review form,0,0,0,0,0,0,0,1,0,0,0 14984,132,"This tool was developed using resources from the Global Slavery Index, Global Compact Network, TRACE International, the Transparency International Corruption Perceptions Index and the Australian Modern Slavery register",0,0,0,0,0,0,0,1,0,0,0 1973,104,REVIEW Performance assessment We focussed our approach by developing a plan of key tasks for the reporting period which we reviewed our actions against,0,0,0,0,0,0,0,0,0,1,0 1973,105,Oversight We expanded our internal risk and assurance capability with a view to incorporating oversight of modern slavery compliance into our audit program,0,0,0,0,0,0,0,0,0,1,0 1973,106,Each entity within the Group is committed to identifying and addressing risks of modern slavery in its operations and supply chain,0,0,0,0,0,0,0,0,0,0,0 1973,107,We have ensured that our Board and senior management are kept updated on activities in relation to our obligations under the reporting requirement in the Modern Slavery Act,0,0,0,0,0,0,0,1,0,0,0 1973,108,"Relevant senior staff, have been advised about, and involved in, our modern slavery response plan actions as relevant",0,0,0,0,0,0,0,1,0,0,0 1973,109,"We have conducted training sessions for our procurement team and our Group Leadership Team on our Modern Slavery Strategy, outlining our plan for the reporting period and the status of related tasks",0,0,0,0,0,0,0,1,0,0,0 1973,110,The Groups consultation approach has reflected the close relationship between its entities and the holistic approach the Group takes to embedding its compliance activities across its entities and departments,0,0,0,0,0,0,0,0,0,0,1 1973,111,"As part of its broader Sustainability Policy and accompanying Sustainability Plan, the Group aims to foster an organisational culture committed to corporate social responsibility, including the recognition of human rights",0,0,0,0,0,0,0,0,0,0,0 4128,80,The results from this assessment process have identified areas within the supply chain that have different risk profiles,0,0,0,0,0,0,0,1,0,0,0 4128,81,For example areas with lower risk include operational activities that are directly undertaken by RJV employees and contractors who are covered by our internal processes,0,0,0,0,0,0,1,0,0,0,0 4128,82,This process has also identified some potentially higher risk areas eg where a local supplier may source a product from overseas sources,0,0,0,0,0,0,1,0,0,0,0 4128,83,We are using these potential risk scenarios to prioritise our supplier engagement activities over the next financial year (FY2021),0,0,0,0,0,0,0,1,0,0,0 4128,84,"We have also identified that risk is minimised by sourcing equipment through local reputable suppliers with audited quality systems in place, rather than buying directly from overseas",0,0,0,0,0,0,0,1,0,0,0 4128,85,"This also increases our ability to meet with suppliers, agree terms and conditions, develop ongoing relationships and audit supplier processes",0,0,0,0,0,0,0,1,0,0,0 4128,86,Actions 6.1,0,0,0,0,0,0,0,0,0,0,0 4128,87,Actions Taken in FY20 The actions taken in FY20 to gain greater understanding of the RJV supply chain and to combat any risk of Modern Slavery include,0,0,0,0,0,0,0,0,0,0,0 14984,133,It contains over 20 questions that enable us to better understand the risks posed by each of our suppliers,0,0,0,0,0,0,0,0,0,0,0 14984,134,We have a vendor assurance program wherein all new and existing vendors will be subjected to due diligence processes that include answering a brief pre-qualifications questionnaire (PQQ) on an annual basis,0,0,0,0,0,0,0,1,0,0,0 14984,135,The PQQ enables us to identify potential areas of risk and to assess the business mechanisms and policies for managing modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 14984,136,"We have sent the PQQ to the majority of high risk suppliers identified with Risen Energys initial risk mapping exercise as detailed above, and are in the process of reviewing the responses received",0,0,0,0,0,0,0,0,0,1,0 14984,137,"After the review process suppliers will be further categorised as either entities whose modern slavery approach we are comfortable with, or entities that we will work further with to better understand the risks theyre facing and how to manage these",0,0,0,0,0,0,0,0,0,0,0 14984,138,Another step that we are proud of is that we have introduced social audits through the Initiative for Compliance and Sustainability (ISC) for our overseas production operations,0,0,0,0,0,0,0,1,0,0,0 14984,139,These audits are then provided to our Australian entities each year confirming compliance by our overseas entities,0,0,0,0,0,0,0,1,0,0,0 14984,140,At the end of 2021 a survey was conducted of the Risen Yiwu factory in the Zhejiang Province which generated an overall rating of 93 out of 100,0,0,0,0,0,0,0,0,0,1,0 1973,112,Flinders Port Holdings Consultation within the Group,0,0,0,0,0,0,0,0,0,0,0 1973,113,The Group is committed to continuously improving its understanding of and management of its modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 1973,114,"In doing so, the Group has engaged with industry to participate in discussion on risks and issues that arise",0,0,0,0,0,0,0,1,0,1,0 1973,115,"In particular, Group representatives have attended a number of procurement and legal industry engagement activities in relation to modern slavery in the reporting period, participating in modern slavery workshops and engaging with business peers and industry bodies on issues relevant to modern slavery",0,0,0,0,0,0,0,1,0,1,0 1973,116,"Most notably, key senior staff from the Groups Legal and Procurement teams have attended workshops run by modern slavery specialist law firms and roundtables and peer group meetings run by peak procurement industry groups and professional associations, to participate in discussion and education sessions on the Modern Slavery Act, issues arising in procurement and supply chains, and ways to approach them",0,0,0,0,0,0,0,1,0,0,0 1973,117,The attendance and active participation increased internal capacity and awareness in relation to addressing modern slavery risk and compliance with the Modern Slavery Act,0,0,0,0,0,0,0,1,0,0,0 1973,118,Modern Slavery Statement Continuous improvement 13,0,0,0,0,0,0,0,0,0,0,0 1973,119,Adopting a specialist ESG or modern slavery specific risk assessment tool for suppliers,0,0,0,0,0,0,0,1,0,0,0 4128,88,Due Diligence,0,0,0,0,0,0,0,0,0,0,0 4128,89,Mapping out the RJV supply chain and assessing potential Modern Slavery risks,0,0,0,0,0,0,0,1,0,0,0 4128,90,Included supplier risks of Modern Slavery within our risk register,0,0,0,0,0,0,0,1,0,0,0 4128,91,"Updating our supplier pre-qualification system, and supplier terms and conditions",0,0,0,0,0,0,0,1,0,0,0 4128,92,Updating QA procedures to incorporate Modern Slavery requirements,0,0,0,0,0,0,0,1,0,0,0 4128,93,Company policies,0,0,0,0,0,0,0,0,0,0,0 4128,94,Reviewed policies to incorporate Modern Slavery risks where appropriate,0,0,0,0,0,0,0,0,0,1,0 4128,95,Developed whistleblower policy and reporting mechanism,0,0,0,0,0,0,0,1,0,0,0 14984,141,DocuSign Envelope ID: 9714B3FC-DE88-4657-A83C-1C0FD6AF6F64,0,0,0,0,0,0,0,0,0,0,0 14984,142,Page 6,0,0,0,0,0,0,0,0,0,0,0 14984,143,Version: 1,0,0,0,0,0,0,0,0,0,0,0 14984,144,Active Date: 2 November 2023,0,0,0,0,0,0,0,0,0,0,0 14984,145,Page 6 of 7,0,0,0,0,0,0,0,0,0,0,0 14984,146,Mandatory Criteria 5: Assessing the Effectiveness of our Actions Risen Energy is aware that Modern Slavery risks are fluid and can change over time both as we obtain greater visibility and knowledge of our supply chains and also as the world and the occurrence of modern slavery alter and shift,0,0,0,0,0,0,0,0,0,0,0 14984,147,We know our efforts need to change with these risks,0,0,0,0,0,0,0,0,0,0,0 14984,148,We continue to hold meetings to finalise membership of a modern slavery working group in Australia,0,0,0,0,0,0,0,0,0,1,0 1973,120,Continuing to roll out modern slavery supplier questionnaires to targeted suppliers,0,0,0,0,0,0,0,1,0,0,0 1973,121,Exploring adoption of digital vendor and tender management platform,0,0,0,0,0,0,0,1,0,0,0 1973,122,Continuing to provide training and awareness about modern slavery to relevant employees in the Group,0,0,0,0,0,0,0,1,0,0,0 1973,123,Continuing to update procurement policies and procedures,0,0,0,0,0,0,0,1,0,0,0 1973,124,Conducting ongoing review of and updates to supplier contracts,0,0,0,0,0,0,0,0,0,1,0 1973,125,Establishing a Modern Slavery Working Group to oversee the program of work,0,0,0,0,0,0,0,1,0,0,0 1973,126,Developing our modern slavery response plan for the next reporting period,0,0,0,0,0,0,0,1,0,0,0 1973,127,Reviewing our actions in the next reporting period against that plan,0,0,0,0,0,0,0,0,0,1,0 4128,96,Training,0,0,0,0,0,0,0,0,0,0,0 4128,97,Development of training package in Modern Slavery,0,0,0,0,0,0,0,1,0,0,0 4128,98,"Onboarding process reviewed, so that awareness of the risks of Modern Slavery can be raised",0,0,0,0,0,0,0,0,0,1,0 4128,99,"Commitment RJV has updated and implemented processes and practices in the business, including a review of the procurement process and updating terms and conditions to minimise the risks of modern slavery within the supply chain",0,0,0,0,0,0,0,1,0,0,0 4128,100,Over the next 12 months RJV are committed to enhancing the measures already taken and continue developing greater understanding of the supply chain and partner processes,0,0,0,0,0,0,0,1,0,0,0 4128,101,"Measure of Effectiveness The actions taken to review and update the subcontractor and supplier pre-qualification process along with updating policies, implementing a Whistleblower procedure and amending terms and conditions appear to have been effective in increasing awareness and reducing risk of Modern Slavery within the business",0,0,0,0,0,0,0,1,0,1,0 4128,102,We will continue to monitor compliance of the actions put in place and commitments made through our quality systems and annual review of policies,0,0,0,0,0,0,0,0,0,1,0 4128,103,This Statement has been prepared to meet the seven mandatory criteria set out in the Commonwealth Modern Slavery Act 2018 and was approved by the RJV Board of Directors on 30/03/21,1,0,0,0,0,0,0,0,0,0,0 14984,149,This working group will coordinate our modern slavery approach going forward including consulting with internal stakeholders (such as human resources and procurement) to help develop and track the deliverables that have been targeted for completion,0,0,0,0,0,0,0,0,0,1,0 14984,150,"Risen Energy has also sought written feedback from employees in procurement, human resources, legal, commercial, sustainability, environmental and governance teams in the Risen Group as to our modern slavery approach which is being evaluated and will be incorporated into policies and procedures going forward",0,0,0,0,0,0,0,0,0,1,0 14984,151,We also intend to carry out an annual self-assessment program to check our policies and processes are being adhered to and build upon,0,0,0,0,0,0,0,0,0,1,0 14984,152,We also measure and track the following,0,0,0,0,0,0,0,0,0,1,0 14984,153,Competence evaluations of staff following modern slavery training sessions,0,0,0,0,0,0,0,0,0,1,0 14984,154,Tracking suppliers that have agreed to undertake modern slavery improvements following our risk assessment,0,0,0,0,0,0,0,0,0,1,0 14984,155,Annual reviews of key supplier responses to the PQQ,0,0,0,0,0,0,0,0,0,1,0 14984,156,Annual risk assessment of key suppliers in Chinese regions,0,0,0,0,0,0,0,1,0,0,0 1973,128,Drafting our next modern slavery statement,0,0,0,0,0,0,0,0,0,0,0 1973,129,Flinders Port Holdings Looking ahead In its next reporting period the Group plans to progress the following actions to assess and address its risk of modern slavery practices in its operations and supply chain,0,0,0,0,0,0,0,0,0,0,0 1973,130,Modern Slavery Statement This Statement was prepared to meet the mandatory reporting criteria set out at section 16 of the Modern Slavery Act,0,0,0,0,0,0,0,0,0,0,0 1973,131,The below table identifies where each criterion is addressed within the Statement,0,0,0,0,0,0,0,0,0,0,0 1973,132,MODERN SLAVERY ACT CRITERIA FPH MODERN SLAVERY STATEMENT,0,0,0,0,0,0,0,0,0,0,0 1973,133,Identify reporting entity,0,0,0,0,0,0,0,0,0,0,0 1973,134,Introduction 3,0,0,0,0,0,0,0,0,0,0,0 1973,135,"Describe the reporting entitys structure, operations and supply chains",0,0,0,0,0,0,0,0,0,0,0 4128,104,Tim Ryan Chief Executive Officer 10th June 2021,0,1,0,0,0,0,0,0,0,0,0 4471,0,apac.bgis.com MODERN SLAVERY STATEMENT,0,0,0,0,0,0,0,0,0,0,0 4471,1,BGIS MODERN SLAVERY STATEMENT 2 ABOUT THIS STATEMENT MODERN SLAVERY This statement has been prepared in accordance with the Modern Slavery Act 2018 (Cth) by the reporting entity BGIS Pty Ltd (ABN: 83 064 638 197) and its 6 subsidiaries (collectively BGIS) for the year ended 31 December 2020,0,0,1,0,0,0,0,0,0,0,0 4471,2,BGIS Pty Ltd makes this single joint statement on behalf of all 100% owned and controlled entities,0,0,0,0,0,0,0,0,0,0,0 4471,3,"BGIS holds a 50% interest in Campus Living MAM Pty Ltd, and a 50% interest in MBM Integrated Health Services Pty Ltd",0,0,0,1,1,0,0,0,0,0,0 4471,4,These entities are not subsidiaries of BGIS and therefore are not covered by this statement,0,0,0,1,0,0,0,0,0,0,0 4471,5,This statement was approved by the board of BGIS Pty Ltd on 25 June 2021,1,0,0,0,0,0,0,0,0,0,0 4471,6,Modern slavery is a serious violation of an individuals dignity and human rights,0,0,0,0,0,0,0,0,0,0,0 14984,157,Implementation of relevant international human rights and modern slavery benchmarks,0,0,0,0,0,0,0,0,0,0,0 14984,158,Assessments of feedback received through training sessions,0,0,0,0,0,0,0,0,0,1,0 14984,159,Regular reviews with suppliers,0,0,0,0,0,0,0,0,0,1,0 14984,160,"We believe that accountability for assessing and addressing modern slavery risks is held by all business units, but key responsibility for developing and monitoring compliance with our policies sits with our Chief Financial Officer, Chief Executive Officer, Chief Operations Officer and Group General Counsel",0,0,0,0,0,0,0,1,0,0,0 14984,161,"All of these accountabilities ultimately then rest with our Board, as the overall governance body",0,0,0,0,0,0,0,1,0,0,0 14984,162,We are also seeking feedback from our suppliers as to innovations and processes utilised by them which we might all adopt as a best practice to combat modern slavery,0,0,0,0,0,0,0,0,0,1,0 14984,163,"Risen Energy is committed to building on this foundation and to refining our tools to identify, assess and address modern slavery risks as we work to create a more sustainable world",0,0,0,0,0,0,0,0,0,0,0 14984,164,Mandatory Criteria 6: Consultation Risen Energy and Risen Energy Service share the same board of directors,0,0,0,0,0,0,0,0,0,0,1 1973,136,"Our structure, operations and supply chain 5",0,0,0,0,0,0,0,0,0,0,0 1973,137,Describe the risks of modern slavery practices in the operations and supply chains of the reporting entity and any entities it owns or controls,0,0,0,0,0,0,0,0,0,0,0 1973,138,Identifying the risks of modern slavery practices 7,0,0,0,0,0,0,0,0,0,0,0 1973,139,"Describe the actions taken by the reporting entity and any entities that the reporting entity owns or controls to assess and address these risks, including due diligence and remediation processes",0,0,0,0,0,0,0,0,0,0,0 1973,140,Identifying the risks of modern slavery practices Our actions to assess and address modern slavery risks Impacts of COVID-19 9 10 9,0,0,0,0,0,0,0,0,0,0,0 1973,141,Describe how the reporting entity assesses the effectiveness of actions being taken to assess and address modern slavery risks,0,0,0,0,0,0,0,0,0,0,0 1973,142,Assessing the effectiveness of our actions 10,0,0,0,0,0,0,0,0,0,0,0 1973,143,Describe the process of consultation with any entities the reporting entity owns or controls,0,0,0,0,0,0,0,0,0,0,0 4471,7,"Exploitative practices including human trafficking, slavery, servitude, forced labour, debt bondage and forced marriage are all considered modern slavery and are serious crimes under Australian law",0,0,0,0,0,0,0,0,0,0,0 4471,8,"On 1 January 2019, the Modern Slavery Act 2018 (the Act) commenced",0,0,0,0,0,0,0,0,0,0,0 4471,9,The Act asks organisations to identify the risk of modern slavery occurring in their operations and supply chains and set out the steps they are taking to address the risk,0,0,0,0,0,0,0,0,0,0,0 4471,10,BGIS Pty Ltd is pleased to submit its inaugural statement in accordance with the Act,0,0,0,0,0,0,0,0,0,0,0 4471,11,BGIS MODERN SLAVERY STATEMENT 3 MESSAGE FROM THE MANAGING DIRECTOR Modern Slavery is a matter of concern to us,0,0,0,0,0,0,0,0,0,0,0 4471,12,"The human rights of our people, clients, vendors and communities are respected in our policies and the way we operate",0,0,0,0,0,0,0,0,0,0,0 4471,13,"On behalf of BGIS in Australia and New Zealand, I am pleased to present our first Modern Slavery Statement aimed at addressing the reporting criteria outlined in the Modern Slavery Act 2018 (Commonwealth)",0,0,0,0,0,0,0,0,0,0,0 4471,14,We support a complex network of vendors and this is where we may be at risk of indirect exposure,0,0,0,0,0,0,1,0,0,0,0 14984,165,"As such, decisions around governance and operations including our approach to modern slavery occur in a centralised way and consultation on this issue is therefore a natural part of the way we do business",0,0,0,0,0,0,0,0,0,0,1 14984,166,"The board of each entity in the Risen Group meets at least four times per year to review (amongst other matters): key risks for that entity (including modern slavery related risks), payment of entitlements to all employees and procurement events which can include more intense audits of a random selection of procurement vendors to confirm the assigned risk levels",0,0,0,0,0,0,0,0,0,0,0 14984,167,"Employees within various departments including procurement, human resources, legal and compliance have been involved in this process",0,0,0,0,0,0,0,0,0,0,0 14984,168,This has ensured that relevant departments and management are aware of what actions they need to take to further our modern slavery approach,0,0,0,0,0,0,0,0,0,0,0 14984,169,DocuSign Envelope ID: 9714B3FC-DE88-4657-A83C-1C0FD6AF6F64,0,0,0,0,0,0,0,0,0,0,0 14984,170,Page 7,0,0,0,0,0,0,0,0,0,0,0 14984,171,Version: 1,0,0,0,0,0,0,0,0,0,0,0 14984,172,Active Date: 2 November 2023,0,0,0,0,0,0,0,0,0,0,0 1973,144,Consultation within the Group 12,0,0,0,0,0,0,0,0,0,0,0 1973,145,Any other relevant information,0,0,0,0,0,0,0,0,0,0,0 1973,146,Continuous improvement Looking ahead 13 14 PAGE This modern slavery statement (Statement) is made by Flinders Port Holdings Pty Ltd and Flinders Ports Pty Ltd for the financial year ending 30 June 2020,0,0,0,0,0,0,0,0,0,0,0 1973,147,"This Statement was approved by Flinders Port Holdings Pty Ltds Board of Directors, being the Board of Directors of Flinders Ports Pty Ltds parent company, on 26th February 2021",1,0,0,0,0,0,0,0,0,0,0 1973,148,STEWART LAMMIN,0,0,0,0,0,0,0,0,0,0,0 1973,149,"CHIEF EXECUTIVE OFFICER, FLINDERS PORT HOLDINGS",0,1,0,0,0,0,0,0,0,0,0 1973,150,"Flinders Port Holdings Appendix A Flinders Port Holdings Pty Ltd (Flinders Port Holdings) subsidiary companies (together, the Group) in the reporting period (FY19/20)",0,0,0,1,0,0,0,0,0,0,0 1973,151,Flinders Ports Pty Ltd,0,0,0,0,0,0,0,0,0,0,0 4471,15,This document is the foundation for us to identify where risks may exist in our operations and supply chain,0,0,0,0,0,0,0,0,0,0,0 4471,16,BGIS has not had any instances related to Modern Slavery but we seek to proactively mitigate risks in the future,0,0,0,0,0,0,1,0,0,0,0 4471,17,Our focus on the mitigation of Modern Slavery is underpinned by a robust governance environment that challenges BGIS to continuously assess risk and improve supply chain transparency,0,0,0,0,0,0,0,0,0,0,0 4471,18,We are committed to continuously improving to achieve long term change that will make a difference to modern slavery,0,0,0,0,0,0,0,0,0,0,0 4471,19,BGIS understands that the efforts to identify and mitigate modern slavery risks in our operations and our supply chains is ongoing,0,0,0,0,0,0,0,0,0,0,0 4471,20,We will seek to continuously refine and improve our approach in order that we effectively and transparently manage modern slavery risks for ourselves and our clients,0,0,0,0,0,0,0,0,0,0,0 4471,21,Dana Nelson President and Managing Director APAC,0,1,0,0,0,0,0,0,0,0,0 4471,22,"BGIS MODERN SLAVERY STATEMENT 4 ABOUT US We provide facility management, project and construction management, energy and sustainability solutions, asset management, building performance management, compliance management, workplace management and real estate services",0,0,0,0,1,0,0,0,0,0,0 14984,173,Page 7 of 7,0,0,0,0,0,0,0,0,0,0,0 14984,174,From our Governing Body Risen Energy makes this statement in accordance with section 13 of the Act,0,0,0,0,0,0,0,0,0,0,0 14984,175,Our Board is our principal governing body and this statement has been considered and approved of by the Board,1,0,0,0,0,0,0,0,0,0,0 14984,176,Eric Lee Irene Liu Directors and Responsible Members of Risen Energys Principal Governing Body DocuSign Envelope ID: 9714B3FC-DE88-4657-A83C-1C0FD6AF6F64,0,1,0,0,0,0,0,0,0,0,0 1973,152,Flinders Ports Adelaide Container Terminal Pty Ltd,0,0,0,0,0,0,0,0,0,0,0 1973,153,Flinders Ports Land Development Pty Ltd,0,0,0,0,0,0,0,0,0,0,0 1973,154,Flinders Logistics Pty Ltd,0,0,0,0,0,0,0,0,0,0,0 1973,155,Flinders Port Management Services Pty Ltd,0,0,0,0,0,0,0,0,0,0,0 1973,156,Flinders Spencer Gulf Ports Pty Ltd,0,0,0,0,0,0,0,0,0,0,0 1973,157,Adelaide Container Terminal Pty Ltd,0,0,0,0,0,0,0,0,0,0,0 1973,158,Spencer Gulf Portlink Pty Ltd,0,0,0,0,0,0,0,0,0,0,0 1973,159,Flinders Spencer Gulf Marine Service Pty Ltd,0,0,0,0,0,0,0,0,0,0,0 4471,23,"Our talented team of close to 1,400 people in Asia Pacific is supported by a global team of 8,000 people in Canada, USA and the United Kingdom",0,0,0,1,1,0,0,0,0,0,0 4471,24,"We deliver to clients in defence, justice, government, education, healthcare, utilities, finance, housing/ social housing, telecommunications, transportation, property, resources, oil & gas and sport & leisure",0,0,0,0,1,0,0,0,0,0,0 4471,25,"We manage 30,000 locations, totalling 31 million square metres of office and retail space, universities, schools, hospitals, stadiums, housing, bases, remote towns, warehouses, industrial assets and data centres",0,0,0,0,1,0,0,0,0,0,0 4471,26,"GLOBALLY 30,000+ LOCATIONS 8,000+ GLOBAL TEAM AU$4.6B CLIENT SPEND 50M m2+ MANAGED ASIA PACIFIC $1.4B+ CLIENT SPEND 17,000+ PROPERTIES 5,000 LEASES & LICENCES 2,500+ SUPPLY CHAIN PARTNERS AUSTRALIA & NEW ZEALAND 15M SQM MANAGED 1,400+ TEAM MEMBERS",0,0,0,0,1,1,0,0,0,0,0 4471,27,"BGIS MODERN SLAVERY STATEMENT 5 OUR SUPPLY CHAIN Australian suppliers constitute 86% of the 2020 active BGIS Pty Ltd supply chain (and over 95% of the spend), with the remaining vendors located internationally",0,0,0,0,0,1,0,0,0,0,0 4471,28,"CATEGORY CHARACTERISTICS Facilities Management Services This group of suppliers represents around half of the BGIS supply chain, both in spend and supplier volume",0,0,0,0,0,1,0,0,0,0,0 4471,29,"Services provided by these vendors primarily include labour based services of: cleaning, security services, grounds maintenance, air conditioning maintenance, electrical maintenance, hydraulic maintenance and fire systems maintenance",0,0,0,0,0,1,0,0,0,0,0 4471,30,"Industrial Consumables, Plant Hire & Equipment This category includes: industrial consumables and tools of trade, uniforms, PPE & safety equipment, catering / kitchen & laundry equipment, furniture and temporary plant hire",0,0,0,0,0,1,0,0,0,0,0 1973,160,Flinders Adelaide Container Terminal Pty Ltd,0,0,0,0,0,0,0,0,0,0,0 1973,161,"Flinders TBSH Pty Ltd (this company, a logistics business operator based in Townsville, Queensland, was divested in March 2020 and is no longer part of the Group)",0,0,0,0,0,0,0,0,0,0,0 1973,162,Flinders Warehousing & Distribution Pty Ltd Flinders Port Holdings,0,0,0,0,0,0,0,0,0,0,0 1973,163,Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 1973,164,P: + 61 (0)8 8447 0611 | F: + 61 (0)8 8447 0606 flindersportholdings.com.au/sustainability,0,0,0,0,0,0,0,0,0,0,0 1974,0,MODERN SLAVERY STATEMENT 2020,0,0,0,0,0,0,0,0,0,0,0 1974,1,REPORTING ENTITIES OUR APPROACH OUR BUSINESS OUR OPERATIONS OUR GOVERNANCE FRAMEWORK ASSESSING AND IDENTIFYING THE RISKS OF MODERN SLAVERY IPLS MODERN SLAVERY RISKS AND ACTIONS TO RESPOND ASSESSING EFFECTIVENESS CONSULTATION WITH CONTROLLED ENTITIES CONTINUOUS IMPROVEMENT APPROACH 3 3 3 4 6 8 9 10 10 11 CONTENTS This document is interactive,0,0,0,0,0,0,0,0,0,0,0 1974,2,Click any heading above to be taken to that page,0,0,0,0,0,0,0,0,0,0,0 4471,31,"Projects, Minor Works & Construction Minor works and construction activities include: demolition and construction, building fabric and carpentry, civil works, electrical systems, flooring supply and installation, roofing & guttering and professional project management services",0,0,0,0,0,1,0,0,0,0,0 4471,32,"Corporate Services This area of our operations includes key corporate items including: travel & accommodation, IT software and equipment, telephony, stationery and professional services such as finance, legal and other consultants",0,0,0,0,0,1,0,0,0,0,0 4471,33,"SUPPLY CHAIN DISTRIBUTION BY SPEND SUPPLY CHAIN DISTRIBUTION BY SUPPLIER COUNT Facilities Management Services Industrial, Consumables, Plant Hire & Equipment Projects, Minor Works & Construction Corporate Services Others",0,0,0,0,0,1,0,0,0,0,0 4471,34,"BGIS MODERN SLAVERY STATEMENT 6 MODERN SLAVERY RISKS BGIS Pty Ltd operations are primarily Australian based, which has a low inherent risk profile of modern slavery vulnerability",0,0,0,0,1,0,1,0,0,0,0 4471,35,"The highest concentration of modern slavery risk in our operations is within our supply chains, which are predominately labour based (see above Our Supply Chain) and international vendors",0,0,0,0,0,0,1,0,0,0,0 4471,36,"In 2020, BGIS reviewed its supply chain using a risk assessment and tiering model outlined below",0,0,0,0,0,0,0,0,0,0,0 4471,37,BGIS completed a risk assessment of its vulnerability to modern slavery practices in its supply chain based on the following,0,0,0,0,0,0,0,1,0,0,0 4471,38,Country Slavery Risk/Global Slavery Indexation,0,0,0,0,0,0,0,1,0,0,0 1974,3,Click the home icon at the bottom of any page to return to this menu,0,0,0,0,0,0,0,0,0,0,0 1974,4,Incitec Pivot Limited Modern Slavery Statement 2020 Previous Next Next Previous,0,0,0,0,0,0,0,0,0,0,0 1974,5,"REPORTING ENTITIES This statement is made by Incitec Pivot Limited (ACN 004 080 264) and its wholly-owned subsidiaries Dyno Nobel Asia Pacific Pty Ltd (ACN 003 269 010), Dyno Nobel Moranbah Pty Ltd (ACN 115 650 649), Incitec Fertilizers Pty Ltd (ACN 103 709 155), Southern Cross Fertilisers Pty Ltd (ACN 004 936 850), Incitec Pivot Explosives Holdings Pty Limited (ACN 124 351 328), Incitec Pivot Investments 1 Pty Ltd (ACN 130 242 090), Incitec Pivot Investments 2 Pty Ltd (ACN 130 242 045) and Dyno Nobel Pty Limited (ACN 117 733 463) (together with other controlled entities of Incitec Pivot Limited, IPL) in respect of the reporting period ended 30 September 2020",0,0,1,0,1,0,0,0,0,0,0 1974,6,"In this, our first Modern Slavery Statement, IPL sets out how it is identifying and addressing modern slavery risks across its supply chain and operations",0,0,0,0,0,0,0,0,0,0,0 1974,7,This statement is made pursuant to the Modern Slavery Act 2018 and has been approved by IPLs Board of Directors,1,0,0,0,0,0,0,0,0,0,0 1974,8,"OUR APPROACH Across all parts of the business, IPL takes its human rights obligations and responsibilities seriously and is committed to operating consistently with the United Nations Universal Declaration of Human Rights and the UN Guiding Principles on Business and Human Rights",0,0,0,0,0,0,0,0,0,0,0 1974,9,"IPLs aim is to ensure the importance it places on upholding human rights is replicated across its business partners and suppliers, throughout the value chain",0,0,0,0,0,0,0,0,0,0,0 1974,10,"OUR BUSINESS Incitec Pivot Limited is an Australian public company, listed on the Australian Securities Exchange",0,0,0,1,0,0,0,0,0,0,0 4471,39,Industry & Category Risk,0,0,0,0,0,0,0,1,0,0,0 4471,40,Volume Risk The assessments were graded along a matrix and resulted in the application of a residual Low / Medium / High ranking for each vendor,0,0,0,0,0,0,0,1,0,0,0 4471,41,The rankings then determine the audit and compliance activities that were to be conducted by BGIS with each tier of supplier (see below Our Actions),0,0,0,0,0,0,0,0,0,0,0 4471,42,"Country and Category risks are first assessed, with residual risk ratings per the diagram above",0,0,0,0,0,0,0,0,0,0,0 4471,43,"BGIS volumes are then considered with Low volumes, reducing the residual risk rating by one tier and High volumes increasing the residual risk rating by one tier",0,0,0,0,0,0,0,0,0,0,0 4471,44,CATEGORY RISK COUNTRY RISK Global Slavery Index BGIS identifies modern slavery country risk using the Global Slavery Index published by the Minderoo / Walk Free Foundation (2018)*,0,0,0,0,0,0,0,1,0,0,0 4471,45,"Walk Free Foundation uses cutting-edge prevalence estimation techniques including nationally-representative surveys in partnership with Gallup, risk-model extrapolation and Multiple Systems Estimation (MSE) to measure modern slavery globally",0,0,0,0,0,0,0,0,0,0,0 4471,46,The index also assesses government responses to this issue and vulnerability structures that impact populations around the world,0,0,0,0,0,0,0,0,0,0,0 1974,11,Each other reporting entity listed in the Reporting Entities section above is an Australian private company and a wholly-owned subsidiary of Incitec Pivot Limited,0,0,0,1,0,0,0,0,0,0,0 1974,12,"As a recognised world leader in the resources and agricultural sectors, IPLs products and services play a critical role in supporting the worlds energy, infrastructure, and raw materials needs, together with feeding people across the globe by driving agricultural performance and sustainability",0,0,0,0,1,0,0,0,0,0,0 1974,13,"With its 150-year history of advancing technological developments, IPLs Dyno Nobel business is a leading manufacturer of industrial explosives and supplier of premium blasting technologies",0,0,0,0,1,0,0,0,0,0,0 1974,14,"IPLs Dyno Nobel business operates in the Americas, Australia, Turkey and Asia Pacific",0,0,0,0,1,0,0,0,0,0,0 1974,15,Its explosives services and products are critical for the customers in the resources and civil construction sectors,0,0,0,0,1,0,0,0,0,0,0 1974,16,"IPL also has equity interests in a number of joint ventures, including a 50% interest in a manufacturer of ammonium nitrate in Australia, Queensland Nitrates Pty Ltd (ABN 63 079 889 268), and manufacturers of initiating systems, Sasol Dyno Nobel (Pty) Ltd and DetNet South Africa (Pty) Ltd (DetNet), both in South Africa",0,0,0,0,1,0,0,0,0,0,0 1974,17,IPLs Australian-based Fertilisers business is the largest manufacturer and distributor of fertiliser in Australia and has been supplying farmers with high quality products and services for more than 100 years,0,0,0,0,1,0,0,0,0,0,0 1974,18,Its products and services are critical for farmers to grow high- quality crops that feed Australians and people across the globe,0,0,0,0,0,0,0,0,0,0,0 4471,47,BGIS applies a weighted methodology that leverages the GSI material based on the following,0,0,0,0,0,0,0,1,0,0,0 4471,48,Prevalence of population in modern slavery (50%),0,0,0,0,0,0,0,1,0,0,0 4471,49,Population Vulnerability (25%); and,0,0,0,0,0,0,0,1,0,0,0 4471,50,Government response (25%) The resulting weighted scores are then graded to provide a residual country risk rating using a Low / Medium / High ranking,0,0,0,0,0,0,0,1,0,0,0 4471,51,These rankings are allocated against the BGIS supply chain to identify modern slavery risk based on country of incorporation,0,0,0,0,0,0,0,1,0,0,0 4471,52,* https://www.globalslaveryindex.org/2018/data/country-data/australia/,0,0,0,0,0,0,0,0,0,0,0 4471,53,BGIS MODERN SLAVERY STATEMENT 7 MODERN SLAVERY RISKS The impact of Covid-19 BGIS understands that the Covid-19 pandemic has the capacity to heighten vulnerability to modern slavery practices in global supply chains,0,0,0,0,0,0,1,0,0,0,0 4471,54,Our highest priority response to the pandemic has been toward the health and wellbeing of our people,0,0,0,0,0,0,0,0,0,0,0 1974,19,"IPL also manufactures industrial chemicals used by its customers for food production, transportation, medical products transfer and water treatment",0,0,0,0,1,0,0,0,0,0,0 1974,20,"With advanced technologies, manufacturing excellence and world class services, IPL is focused on developing the efficiency and sustainability of its customers and users across the resource and agricultural sectors",0,0,0,0,0,0,0,0,0,0,0 1974,21,IPL aims to make peoples lives better by unlocking the worlds natural resources through innovation on the ground,0,0,0,0,0,0,0,0,0,0,0 1974,22,Incitec Pivot Limited Modern Slavery Statement 2020 Next Previous,0,0,0,0,0,0,0,0,0,0,0 1974,23,"AT A GLANCE 60 Manufacturing facilities 7,300 Suppliers 5,000 Employees 3.1 billion AUD Spend with suppliers for the 2020 financial year 3,942.2 million Revenue for the 2020 financial year $ 374.5 million EBIT (ex IMIs) for the 2020 financial year OUR OPERATIONS Simsbury Graham Dinamita Waggaman, Louisiana Ormstown North Bay Duffield Carthage St Helens Donora Louisiana, Missouri Barry Cheyenne Van Wyck Brooksville Wolf Lake",0,0,0,1,1,1,0,0,0,0,0 1974,24,Maitland Ekati Meadowbank Tumbler Ridge Rainy River Lincoln Diavik Guadalajara Biwabik Flin Flon La Serena i i e e e e e e e e e e e e e e i i i i i a a a a a CHILE MEXICO USA CANADA e Incitec Pivot Limited Company Headquarters Incitec Pivot Fertilisers Quantum Fertilisers Corporate Office Manufacturing/Distribution Dyno Nobel Manufacturing legend Corporate Office Manufacturing/Distribution Initiation i Emulsion e AN a a Long term AN supplier Joint Ventures/Investments Salt Lake City Gomez Palacios Boisbriand Santiago Kalgoorlie Lihir Moranbah Helidon Moura (Queensland Nitrates) Geelong Townsville Mt Isa Phosphate Hill Portland Soma Tanjung Tabalong Sibolga Port Adelaide Port Hedland Warkworth Batu Kajang Kayseri Kooragang Island Devonport Port Lincoln Berau Tenggarong Muara Tuhup i e e e e e i e e e e e e e a AUSTRALIA TURKEY INDONESIA PAPUA NEW GUINEA SOUTH AFRICA Ankara Hong Kong CHINA Jakarta Perth a Melbourne Gibson Island Mary River Calgary Johannesburg (SASOL Dyno Nobel) Johannesburg (DetNet) i i 4 Incitec Pivot Limited Modern Slavery Statement 2020 Next Previous,0,0,0,0,0,0,0,0,0,0,0 1974,25,Dyno Nobel Dyno Nobel is IPLs global explosives business,0,0,0,0,1,0,0,0,0,0,0 1974,26,It is the second largest industrial explosives distributor in North America and the second largest industrial explosives distributor in Australia by volume,0,0,0,0,1,0,0,0,0,0,0 4471,55,"Our employees were provided personal protective equipment (PPE) which met Australian quality standards and ISO certifications and BGIS also performed a central role in assisting the PPE sourcing efforts of our clients throughout the pandemic, including those within the health sector",0,0,0,0,0,0,0,0,0,0,0 4471,56,"Additionally, early payment terms were introduced for large cohorts of our supply chain and BGIS materially expanded its enagement of Small and Medium enterprises (SMEs) to reduce modern slavery vulnerabilty in 2020",0,0,0,0,0,0,0,1,0,0,0 4471,57,Category Risk BGIS procurement maintains an industry segmentation and taxonomy model across the BGIS Pty Ltd supply chain,0,0,0,0,0,0,0,1,0,0,0 4471,58,This taxonomy has been indexed against modern slavery risk using a High / Medium / Low ranking methodology to identify likelihood of modern slavery by activity type,0,0,0,0,0,0,0,1,0,0,0 4471,59,The indexation is based upon the following industry attributes,0,0,0,0,0,0,0,1,0,0,0 4471,60,Prevalence of high staff and employment volumes within the category,0,0,0,0,0,0,0,1,0,0,0 4471,61,The relative wages and incomes of the staff employed in a given industry as a measure of income disadvantage and exploitation risk,0,0,0,0,0,0,0,1,0,0,0 4471,62,The proportion of goods and materials likely to be sourced from 3rd parties and overseas supply chains; and,0,0,0,0,0,0,0,1,0,0,0 1974,27,"Americas: Dyno Nobel Americas (DNA) provides ammonium nitrate, initiating systems and services to the Quarry & Construction sector primarily in the Southern US, Northeast US and Canada; the Base & Precious Metals sector in the US mid-West, US West and Canada and the Coal sector in the Powder River Basin, Illinois Basin and Appalachia",0,0,0,0,1,0,0,0,0,0,0 1974,28,"Incitec Pivot Investments 1 Pty Ltd, Incitec Pivot Investments 2 Pty Ltd and Dyno Nobel Pty Limited are Australian proprietary companies that are holding entities of the DNA business within the IPL corporate group",0,0,0,1,1,0,0,0,0,0,0 1974,29,They do not conduct any operations,0,0,0,0,1,0,0,0,0,0,0 1974,30,"Asia Pacific: Dyno Nobel Asia Pacific Pty Ltd (DNAP), provides ammonium nitrate based industrial explosives, initiating systems and services to the Metallurgical Coal and Base & Precious Metals sectors in Australia, and internationally to a number of countries including Indonesia, Papua New Guinea and Turkey through its subsidiaries and joint ventures",0,0,0,0,1,0,0,0,0,0,0 1974,31,"Dyno Nobel Moranbah Pty Ltd manufactures ammonium nitrate at its ammonium nitrate plant located in the Bowen Basin, Queensland",0,0,0,0,1,0,0,0,0,0,0 1974,32,Incitec Pivot Explosives Holdings Pty Limited is the holding entity of IPLs global explosives business,0,0,0,1,1,0,0,0,0,0,0 1974,33,This entity does not conduct any operations,0,0,0,0,1,0,0,0,0,0,0 1974,34,Incitec Pivot Fertilisers Incitec Pivot Fertilisers (IPF) is IPLs fertilisers business,0,0,0,0,1,0,0,0,0,0,0 4471,63,"Known high risk modern slavery industries such as textiles, electronics, food supply, cleaning and manufacturing",0,0,0,0,0,0,0,1,0,0,0 4471,64,The category indexation is then attributed against the BGIS supply chain to identify modern slavery risk based on industry of operation,0,0,0,0,0,0,0,1,0,0,0 4471,65,"BGIS MODERN SLAVERY STATEMENT 8 OUR ACTIONS Policy, Procedure and Governance Our commitments to reducing modern slavery vulnerability in BGIS operations and our supply chain are supported by a cohesive policy, procedural and governance framework",0,0,0,0,0,0,0,1,0,0,0 4471,66,Code of Business Conduct and Ethics The Code serves as a guide for staff conduct as a member of the BGIS team,0,0,0,0,0,0,0,1,0,0,0 4471,67,Preserving our corporate culture is vital to the organisation and following the Code helps us do that,0,0,0,0,0,0,0,1,0,0,0 4471,68,All staff receive training and certify their commitment to the Code each year,0,0,0,0,0,0,0,1,0,0,0 4471,69,"Modern Slavery Act Framework Released in November 2019, the BGIS Modern Slavery Act framework sets out an understanding of the risks and mitigation strategies that BGIS has adopted in meeting its legislative obligations and CSR objectives",0,0,0,0,0,0,0,1,0,0,0 4471,70,"The framework identifies appropriate resourcing, staffing and a training agenda to support a strong corporate culture, setting short and long term key performance indicators to ensure a transparent and efficient approach to managing modern slavery vulnerability in the BGIS supply chain",0,0,0,0,0,0,0,1,0,1,0 1974,35,"With an unrivalled position across Eastern Australia, it is the largest domestic manufacturer and supplier of fertilisers by volume produced from its strategically positioned manufacturing facilities, including the ammonium phosphate fertiliser plant in Phosphate Hill, complemented by the world scale sulphuric acid plant at Mount Isa, in North Queensland",0,0,0,0,1,0,0,0,0,0,0 1974,36,Southern Cross Fertilisers Pty Ltd owns and operates IPLs ammonium phosphate fertiliser plant in Phosphate Hill,0,0,0,0,1,0,0,0,0,0,0 1974,37,"Incitec Fertilizers Pty Limited operates IPLs manufacturing facilities in Gibson Island, Queensland, where it manufactures ammonia, granulated ammonium sulphate and urea, and in Geelong, Victoria, where it manufactures single super phosphate",0,0,0,0,1,0,0,0,0,0,0 1974,38,"Internationally, the fertilisers business sells to major offshore agricultural markets in Asia Pacific, the Indian subcontinent, Brazil and the United States",0,0,0,0,0,1,0,0,0,0,0 1974,39,It also procures fertilisers from overseas manufacturers to meet domestic seasonal peaks for its customers diversified crops,0,0,0,0,0,1,0,0,0,0,0 1974,40,"Global Manufacturing Americas: In North America, Dyno Nobel manufactures ammonium nitrate at its Cheyenne, Wyoming and Louisiana, Missouri plants",0,0,0,0,1,0,0,0,0,0,0 1974,41,"The Cheyenne, Wyoming plant is adjacent to the Powder River Basin, strategically placed for both the Base & Precious Metals sector and North Americas most competitive thermal coal mining region",0,0,0,0,1,0,0,0,0,0,0 1974,42,"The Louisiana, Missouri plant has a competitive logistic footprint from which to support the Quarry & Construction sector and mining in both the Illinois Basin and Appalachia",0,0,0,0,1,0,0,0,0,0,0 4471,71,The governance and review ecosystem of the framework are also set out in this framework,0,0,0,0,0,0,0,1,0,1,0 4471,72,"Sustainable Procurement Framework BGIS procurement has wholly adopted the principles of the ISO 20400 Sustainable Procurement Guidance in its procurement policy, guidelines, compliance and audit activities and leadership and works toward giving these principles expression in all purchasing activities undertaken by BGIS procurement staff and the broader BGIS business",0,0,0,0,0,0,0,1,0,0,0 4471,73,"Procurement Policy & Sustainable Procurement Policy The BGIS Procurement Policy begins with an overview of the BGIS procurement principles: Ethics, Safety & Sustainability",0,0,0,0,0,0,0,1,0,0,0 4471,74,Staff are given an overview of their responsibilities to uphold the BGIS Code of Ethics; our zero-tolerance approach to Bribery and Corruption; our Risk and Safety management policy requirements; and our commitments to Sustainability and the Environment and Supplier Diversity,0,0,0,0,0,0,0,1,0,0,0 4471,75,"In 2020, BGIS was proud to release its Sustainable Procurement Policy",0,0,0,0,0,0,0,1,0,0,0 4471,76,The policy is supported by an extended set of purchasing guidelines and checklists that further articulate our approach to Sustainable Procurement in accordance with the ISO 20400 pillars,0,0,0,0,0,0,0,1,0,0,0 4471,77,Key elements of our operating guidance with respect to Sustainable Procurement include business as usual processes that provide continual assessment of,0,0,0,0,0,0,0,1,0,0,0 4471,78,Organisational Governance,0,0,0,0,0,0,0,1,0,0,0 1974,43,"Initiating Systems are manufactured at Dyno Nobels facilities in Connecticut, Kentucky, Illinois, Missouri, Chile and Mexico, and are also sourced from DetNet, an IPL electronics joint venture",0,0,0,0,1,0,0,0,0,0,0 1974,44,"Asia Pacific: In Australia, Dyno Nobel manufactures ammonium nitrate at its Moranbah plant, which is located in the Bowen Basin, the worlds premier metallurgical coal region",0,0,0,0,1,0,0,0,0,0,0 1974,45,"Queensland Nitrates Pty Ltd, a joint venture of Dyno Nobel, operates its fully integrated, state of the art joint venture ammonium nitrate facility near Moura in Central Queensland",0,0,0,0,1,0,0,0,0,0,0 1974,46,Initiating Systems are manufactured at Dyno Nobels Helidon facility in Queensland and are also sourced from IPL facilities in the Americas and its joint ventures,0,0,0,0,1,0,0,0,0,0,0 1974,47,"The business also produces nitrogen-based fertilisers and industrial chemicals across four locations including its state of the art ammonia plant in Waggaman Louisiana, that are delivered to its fertiliser end markets via an integrated supply chain",0,0,0,0,1,0,0,0,0,0,0 1974,48,"Workforce IPL seeks to engage a workforce that is representative of its markets and communities across the global organisation, utilising a diverse range of people with broad and varied skill sets",0,0,0,0,0,0,0,0,0,0,0 1974,49,"Operating across five continents, a diverse and inclusive business with the right people in the right roles provides an engaging workplace and enables achievement of our business objectives",0,0,0,0,0,0,0,0,0,0,0 1974,50,Our inclusion in the global Bloomberg Gender Equality Index (GEI) for the third consecutive year demonstrates publicly our commitment to diversity and inclusion in the workplace,0,0,0,0,0,0,0,0,0,0,0 4471,79,Human Rights,0,0,0,0,0,0,0,1,0,0,0 4471,80,Labour Practices,0,0,0,0,0,0,0,1,0,0,0 4471,81,Environment,0,0,0,0,0,0,0,1,0,0,0 4471,82,Fair Operating Practices,0,0,0,0,0,0,0,1,0,0,0 4471,83,Consumer Issues; and,0,0,0,0,0,0,0,1,0,0,0 4471,84,Community,0,0,0,0,0,0,0,1,0,0,0 4471,85,"Tier 2 Subcontracting Guidelines: In 2019, BGIS Procurement released its Tier 2 Subcontracting Guidelines",0,0,0,0,0,0,0,1,0,0,0 4471,86,"Alongside this release, a complete audit of the Facilities Management supply chain was completed, designed specifically to provide greater transparency into the BGIS supply chain and any downstream subcontracting practices",0,0,0,0,0,0,0,1,0,1,0 1974,51,"We continue to progress towards specific, challenging and measurable objectives for gender diversity and Indigenous Australians",0,0,0,0,0,0,0,0,0,0,0 1974,52,"IPLs workforce is comprised of approximately 5,000 direct employees in full time and part time roles and 648 labour hire contractors",0,0,0,0,1,1,0,0,0,0,0 1974,53,"The roles filled by these employees and contractors are as diverse as our workforce, from labourers to engineers",0,0,0,0,1,1,0,0,0,0,0 1974,54,Breakdown of Labour Hire Contractor Workforce as at 30 September 2020 by Location: Location Number of Contractors Australia 449 USA & Canada 102 Chile 3 Mexico 11 Indonesia 83 Turkey All work is carried out by direct employees Labour hire is a key component of the workforce in Australia,0,0,0,1,0,1,0,0,0,0,0 1974,55,"It is used to supplement seasonal, maintenance and productivity demands and fluctuates to meet business requirements",0,0,0,0,0,1,0,0,0,0,0 1974,56,There is minimal use of labour hire contractors in IPLs operations outside of Australia and North America,0,0,0,0,0,1,0,0,0,0,0 1974,57,Incitec Pivot Limited Modern Slavery Statement 2020 Next Previous,0,0,0,0,0,0,0,0,0,0,0 1974,58,"Our Supply Chain IPL procures raw materials that are used directly in the manufacturing process for explosives, fertilisers and industrial chemicals and indirect materials and services that support the activities of the organisation",0,0,0,0,0,1,0,0,0,0,0 4471,87,BGIS MODERN SLAVERY STATEMENT 9 OUR ACTIONS Vendor Code of Conduct As a business that delivers services to all of our customers through a network of trusted Vendor partners it is essential that we always behave with unquestioned integrity consistent with our core values,0,0,0,0,0,0,0,1,0,0,0 4471,88,"To help our vendors and their employees, agents and sub vendors (collectively referred to as Vendors) understand these expectations we outline our commitment and expectations in the Vendor Code of Conduct which is formally acknowledged by all BGIS suppliers",0,0,0,0,0,0,0,1,0,0,0 4471,89,"The Code includes ensuring that the human rights of workers is upheld and expressly prohibits forced, bonded, indentured or involuntary labour and enforces compliance with applicable wage laws",0,0,0,0,0,0,0,1,0,0,0 4471,90,"Subcontracts BGIS has strengthened compliance with laws controls when engaging third parties, with provisions for compliance with the Modern Slavery Act 2018 now part of our standard subcontracting agreements",0,0,0,0,0,0,0,1,0,0,0 4471,91,These provisions also promote BGIS rights to audit and verify compliance,0,0,0,0,0,0,0,1,0,1,0 4471,92,"Whistleblower Policy BGIS are committed to fostering a culture in which team members feel supported to provide feedback, especially if they have concerns about ethical issues in the workplace",0,0,0,0,0,0,0,1,0,0,0 4471,93,"Our Integrity 24/7 reporting platform allows staff and suppliers to easily and anonymously communicate any misconduct, or gain clarity on something that may be cause for concern no matter how big or small",0,0,0,0,0,0,0,1,0,0,0 4471,94,"To manage the reporting system, we partner with NAVEX Global, an ethics and compliance company that has gone to great lengths to ensure reports entered in the system are completely confidential",0,0,0,0,0,0,0,1,0,0,0 1974,59,"IPLs largest categories of spend are: fertilisers, transport and site services which comprise 53% of the spend within the Asia Pacific business units and 32% on corporate and utilities within the Americas business unit",0,0,0,0,0,1,0,0,0,0,0 1974,60,"In FY20, approximately 70% of IPLs total procurement spend was with Australian domiciled entities, supplying goods and services originating from Australia and around the world",0,0,0,0,0,1,0,0,0,0,0 1974,61,The majority of spend in non-Australian entities was on fertiliser imports,0,0,0,0,0,1,0,0,0,0,0 1974,62,Our Asia Pacific and North American Procurement teams manage a Supplier Relationship Management (SRM) program to develop and continuously improve relationships with strategic suppliers,0,0,0,0,0,1,0,0,0,0,0 1974,63,"This is designed to promote stable, longer term, commercial relationships",0,0,0,0,0,1,0,0,0,0,0 1974,64,"In FY20, IPL engaged directly with approximately 7,300 suppliers domiciled across 45 countries across the globe",0,0,0,0,0,1,0,0,0,0,0 1974,65,"As part of the supplier risk assessment and tiering process, in FY20, IPL identified 40 (0.6%) potentially high-risk suppliers based on the potential risk of modern slavery indicators in the supply chain",0,0,0,0,0,0,1,0,0,0,0 1974,66,"This risk-based approach referenced data from the Global Slavery Index using the domiciled region, commodity and spend data to assist with determination of the risk",0,0,0,0,0,0,1,0,0,0,0 4471,95,The BGIS Whistleblower Policy aligns with legislative requirements and contains workflow demonstrating how all Integrity 24/7 matters are managed,0,0,0,0,0,0,0,1,0,0,0 4471,96,"Modern Slavery framework, Supplier Due Diligence BGIS undertook a comprehensive review of its 2020 active supply chain of 2700 vendors in alignment with our Modern Slavery framework objectives",0,0,0,0,0,0,0,1,0,0,0 4471,97,This included,0,0,0,0,0,0,0,1,0,0,0 4471,98,rd party due diligence assessment of the entire supply chain,0,0,0,0,0,0,0,1,0,0,0 4471,99,Extended supplier engagement through Modern Slavery questionnaire assessment for medium risk vendors,0,0,0,0,0,0,0,1,0,1,0 4471,100,Formal supplier auditing for high risk vendors Anti-Bribery and Corruption (ABC) BGIS utilises Dun & Bradstreet independent screening of all suppliers providing goods or services to BGIS as part of its anti-bribery and corruption (ABC) due diligence,0,0,0,0,0,0,0,1,0,1,0 4471,101,These reviews are undertaken prior to any new supplier being on-boarded to BGIS procure-to-pay platforms,0,0,0,0,0,0,0,1,0,1,0 4471,102,The Dunn & Bradstreet screening program is conducted in 2 phases as follows: New Vendors: Level 2 Intermediate,0,0,0,0,0,0,0,1,0,1,0 1974,67,These were immediately prioritised in the screening process to ensure that appropriate compliance and ongoing safeguards were implemented,0,0,0,0,0,0,0,0,0,0,0 1974,68,This process is discussed in further detail in the Assessing and Identifying the Risks of Modern Slavery section,0,0,0,0,0,0,0,0,0,0,0 1974,69,"Each of our suppliers also have their own supply chains, over which we presently have limited visibility",0,0,0,0,0,0,0,0,0,0,0 1974,70,"Understanding IPLs broader supply chain is a complex process, and we intend to further build our understanding of risks among our supplier network through engagement with suppliers and contractors over future periods",0,0,0,0,0,0,0,1,0,0,0 1974,71,"During FY20, the COVID-19 pandemic resulted in impacts in IPLs usual supply practices, however IPL reacted quickly to mitigate these impacts and associated risks of modern slavery",0,0,0,0,0,0,0,0,0,0,0 1974,72,Further information about IPLs approach to suppliers and identifying modern slavery risk is set out below,0,0,0,0,0,0,0,0,0,0,0 1974,73,"OUR GOVERNANCE FRAMEWORK IPLs Board is committed to achieving and demonstrating the highest standards of corporate governance and fulfilling its obligations in the best interests of its shareholders, its employees, and the broader community",0,0,0,0,0,0,0,0,0,0,0 1974,74,"The Board has implemented, and operates in accordance with, a set of corporate governance principles which are fundamental to the Companys continued growth and success",0,0,0,0,0,0,0,0,0,0,0 4471,103,"These screenings include assessment of: Sanctions / Watch lists / Politically Exposed Persons and Adverse Media relating to: Entity name, Legal names, Principal names, Related Parties and Global Parent",0,0,0,0,0,0,0,1,0,1,0 4471,104,An adverse finding or red flag surfaced during this process may result in a vendor being rejected by BGIS or a formal review and acceptance process completed with endorsements obtained by BGIS Managing Director prior to accepting any risk(s) identified,0,0,0,0,0,0,0,1,0,1,0 4471,105,Annual Review: All BGIS vendors are annually re-screened against the Dunn & Bradstreet databases to ensure that their company standing has not been compromised subsequent to on-boarding with BGIS,0,0,0,0,0,0,0,1,0,1,0 4471,106,These annual screenings are a Level 1 review and include assessment of: Sanctions / Watch lists and Politically Exposed Persons relating to the entity name,0,0,0,0,0,0,0,1,0,1,0 4471,107,Escalated reviews are performed on an ad-hoc basis where further information is required by BGIS,0,0,0,0,0,0,0,1,0,1,0 4471,108,These reviews include expanded screening of Open Source Litigation and Credit reporting material,0,0,0,0,0,0,0,1,0,1,0 4471,109,Supplier Prequalification All suppliers providing on-site services to BGIS and its clients are required to subscribe to the Avetta contractor management platform,0,0,0,0,0,0,0,1,0,0,0 4471,110,"This platform prequalifies suppliers against BGIS minimum company requirements and includes specific disclosures regarding compliance with the Modern Slavery Act, including",0,0,0,0,0,0,0,1,0,0,0 1974,75,"Stakeholders Board Board Committees Assurance and oversight through reporting Delegation Delegation Delegation Accountability Accountability Accountability Internal Audit External Auditor Audit and Risk Management Nominations Remuneration Health, Safety, Environment and Community Executive Team Managing Director & CEO Our People Independent Assurance 6 Incitec Pivot Limited Modern Slavery Statement 2020 Next Previous",0,0,0,0,0,0,0,0,0,0,0 1974,76,Our Policies Our policies and frameworks support IPLs day-to-day activities and are designed to ensure universally recognised human rights are safeguarded,0,0,0,0,0,0,0,0,0,0,0 1974,77,"Our Group-wide Modern Slavery Policy sets the minimum standards expected across the business, both internally and from our suppliers and customers, in identifying and addressing the risk of modern slavery within our operations and supply chains",0,0,0,0,0,0,0,1,0,0,0 1974,78,Our Human Rights Policy articulates the fundamental elements of our approach to human rights,0,0,0,0,0,0,0,1,0,0,0 1974,79,"It sets out IPLs commitment to respect human rights, in line with the Universal Declaration of Human Rights and other international frameworks",0,0,0,0,0,0,0,1,0,0,0 1974,80,"It defines our commitments to respect and support the dignity, well-being and human rights of our employees and those in the communities in which we operate, which includes ensuring a fair, safe and healthy working environment",0,0,0,0,0,0,0,0,0,0,0 1974,81,"Supplier Code of Conduct Our Supplier Code of Conduct sets out the values, principles and minimum standards of behaviour that we expect our suppliers to meet across the areas of safety, labour, human rights, diversity, environment, community and ethics",0,0,0,0,0,0,0,1,0,0,0 1974,82,"The principles outlined in the Supplier Code of Conduct have been embedded as part of our sourcing and procurement processes, and IPL engages with suppliers and contractors that demonstrate similar values and adhere to the minimum requirements outlined in the Supplier Code of Conduct",0,0,0,0,0,0,0,1,0,0,0 4471,111,"All suppliers must acknowledge that they have read, understood and adhere to the BGIS Supplier Code of Conduct which makes specific reference to the application of the Modern Slavery Act",0,0,0,0,0,0,0,1,0,0,0 4471,112,All suppliers must register and induct their staff via the platform providing BGIS with direct visibility of all staff the supplier intends to utilise in the provision of services to BGIS,0,0,0,0,0,0,0,1,0,0,0 4471,113,"BGIS MODERN SLAVERY STATEMENT 10 OUR ACTIONS Modern Slavery questionnaire In 2020, the Avetta prequalification was expanded to include specific review material to assess risk and vulnerability of modern slavery in the BGIS supply chain",0,0,0,0,0,0,0,1,0,0,0 4471,114,"For off-site suppliers, this material was distributed manually for completion and return",0,0,0,0,0,0,0,1,0,0,0 4471,115,Supplier completions were monitored by the BGIS procurement team for 160 suppliers deemed to be Tier 2 (medium residual risk) following our supplier risk assessment process [above],0,0,0,0,0,0,0,1,0,1,0 4471,116,Any exceptions resulted in a supplier escalated to Tier 1 status with auditing activities then conducted,0,0,0,0,0,0,0,1,0,1,0 4471,117,"The questionnaire is designed to identify risk, vulnerability and compliance in the BGIS supply chain by assessing: Supplier Auditing BGIS Procurement undertook formal auditing of suppliers with a residual high risk Tier 1 rating as follows: Service Suppliers: The majority of BGIS supplier relationships are within the facilities management services industry",0,0,0,0,0,0,0,1,0,0,0 4471,118,"Auditing in this field maintained a focus on labour practices, including",0,0,0,0,0,0,0,1,0,0,0 1974,83,Supply Contracts Our standard supply contracts were updated in 2019 to incorporate modern slavery provisions designed to identify modern slavery risks within the suppliers operations and supply chains,0,0,0,0,0,0,0,1,0,0,0 1974,84,"These provisions provide assurances to IPL as well as requiring suppliers to provide information and assistance to IPL to identify, evaluate, implement and report on any modern slavery risks within the suppliers business and supply chains",0,0,0,0,0,0,0,1,0,0,0 1974,85,"IPL regularly reviews its supply contracts and updates as necessary to ensure compliance with applicable laws and regulations, in addition to supporting IPLs broader policy objectives",0,0,0,0,0,0,0,0,0,1,0 1974,86,Our Values Our Company values are at the core of the way we work,0,0,0,0,0,0,0,0,0,0,0 1974,87,"With a One IPL One Team mindset and behaviours, coupled with cross functional and geographical collaboration across our businesses, we are able to capture diversity of thought in an inclusive environment where the contribution of everyone is valued",0,0,0,0,0,0,0,0,0,0,0 1974,88,Incitec Pivot Limited Modern Slavery Statement 2020 Previous Next,0,0,0,0,0,0,0,0,0,0,0 1974,89,ASSESSING AND IDENTIFYING THE RISKS OF MODERN SLAVERY IPL has developed a set of tools and procedures to identify and mitigate risks associated with human rights in its supply chain and operations,0,0,0,0,0,0,0,0,0,0,0 1974,90,"These tools and procedures have been developed by a team from across the global business, with representatives from key areas including Procurement, Sustainability, Supply Chain, Human Resources, IT, Legal and Risk",0,0,0,0,0,0,0,0,0,0,0 4471,119,Demonstration to BGIS that all staff employed in the provision of services are directly employed by the service provider and hold appropriate visa / permit rights where applicable,0,0,0,0,0,0,0,1,0,0,0 4471,120,"The evidence is to include, rostering, timetables and payroll material",0,0,0,0,0,0,0,1,0,0,0 4471,121,"Demonstration to BGIS that all staff employed have been paid their correct entitlements, including, but not limited to",0,0,0,0,0,0,0,1,0,0,0 4471,122,"The payment of award wages, including demonstration of correct overtime and penalty rate payments",0,0,0,0,0,0,0,1,0,0,0 4471,123,"That all leave entitlements and contributions have been met by the service provider, including evidence of annual and sick leave, evidence of long service leave contributions made by the service provider, and demonstration that all superannuation entitlements have been met",0,0,0,0,0,0,0,1,0,0,0 4471,124,Goods Suppliers: Tier 1 suppliers providing goods or materials to BGIS are primarily associated with industrial and construction supplies,0,0,0,0,0,0,0,1,0,0,0 4471,125,"Auditing in this field focuses on supply chain transparency, including",0,0,0,0,0,0,0,1,0,0,0 4471,126,"Demonstration to BGIS that the provision of goods and/or materials have been ethically sourced, including an understanding of",0,0,0,0,0,0,0,1,0,0,0 1974,91,The Procurement and Supply Chain teams have responsibility for identifying and assessing risks in the supply chain,0,0,0,0,0,0,0,1,0,0,0 1974,92,"These activities are supported by external tools referenced below and internal risk, control and audit registers contained in IPLs risk and controls system",0,0,0,0,0,0,0,1,0,0,0 1974,93,"IPL has a multi-year, systematic approach to integrating ethical supply chain transparency and due diligence throughout its supply chain",0,0,0,0,0,0,0,1,0,0,0 1974,94,"This risk-based, phased approach prioritises higher risk jurisdictions, commodities and services",0,0,0,0,0,0,0,1,0,0,0 1974,95,"Through implementation of these tools and procedures, IPL is able to deepen its understanding and assessment of suppliers and continuously implement improvements",0,0,0,0,0,0,0,0,0,0,0 1974,96,"IPL has operations in various locations around the globe, with a diverse workforce",0,0,0,0,0,0,0,0,0,0,0 1974,97,"IPLs human resources procedures across its operations contain a number of controls to ensure risks of human rights abuses, including child labour and forced labour, are managed, having regard to the jurisdiction specific requirements and risks",0,0,0,0,0,0,0,1,0,0,0 1974,98,These controls include proof of age and the requirement to provide security clearances in certain jurisdictions,0,0,0,0,0,0,0,1,0,0,0 4471,127,Country of origin,0,0,0,0,0,0,0,1,0,0,0 4471,128,Labour practices associated with the provision of the good or material,0,0,0,0,0,0,0,1,0,0,0 4471,129,Transparency of supply chain depth / tiering,0,0,0,0,0,0,0,1,0,0,0 4471,130,Eg,0,0,0,0,0,0,0,1,0,0,0 4471,131,Source of raw material and omponents; and,0,0,0,0,0,0,0,1,0,0,0 4471,132,Audit and assessment activities conducted by the supplier on its 3rd party supply partners,0,0,0,0,0,0,0,1,0,0,0 4471,133,"A total of 24 audits were completed with Tier 1 (high residual risk) vendors active within 2020, with no materially adverse findings",0,0,0,0,0,0,1,1,0,1,0 4471,134,"Annual turnover, company location",0,0,0,0,0,0,0,0,0,0,0 1974,99,"For example, in Indonesia, the minimum age for recruitment of employees and labour hire contractors is 20 years old, with minimum education requirements set as senior high school for all direct employment positions, supported by copies of the candidates ID and education certificate registered on the human resources records system",0,0,0,0,0,0,0,1,0,0,0 1974,100,"For third party contractor labour, minimum age and education requirements are stipulated with third party providers",0,0,0,0,0,0,0,1,0,0,0 1974,101,"In Turkey, in accordance with the local labour law, IPLs human resources team view and retain a copy of employees Turkish I.D",0,0,0,0,0,0,0,1,0,0,0 1974,102,during the recruitment process,0,0,0,0,0,0,0,1,0,0,0 1974,103,All of our employees are engaged through contracts of employment agreed by the company and the employee,0,0,0,0,0,0,0,1,0,0,0 1974,104,The IPL HR Data Collection Procedure requires all security guards hired by IPL to provide their qualification certificate prior to commencing work,0,0,0,0,0,0,0,1,0,0,0 1974,105,This certificate is required to show evidence of training in accordance with the UN Voluntary Principles on Security and Human Rights,0,0,0,0,0,0,0,1,0,0,0 1974,106,"Due Diligence To conduct an initial assessment of the risk of modern slavery in its supply chains, IPL used a risk-based, phased approach, prioritising higher risk jurisdictions, commodities and services",0,0,0,0,0,0,0,1,0,0,0 4471,135,Company statement requirements on Modern Slavery,0,0,0,0,0,0,0,0,0,0,0 4471,136,Controls to prevent bonded labour,0,0,0,0,0,0,0,0,0,0,0 4471,137,Supply chain transparency,0,0,0,0,0,0,0,0,0,0,0 4471,138,Country of origin,0,0,0,0,0,0,0,0,0,0,0 4471,139,Audit programs,0,0,0,0,0,0,0,0,0,0,0 4471,140,Policy statements,0,0,0,0,0,0,0,0,0,0,0 4471,141,Training programs,0,0,0,0,0,0,0,0,0,0,0 4471,142,Risk Assessments,0,0,0,0,0,0,0,0,0,0,0 1974,107,"The risk-based approach referenced data from the Global Slavery Index using the domiciled region, commodity and spend data to assist with determination of the risk",0,0,0,0,0,0,0,1,0,0,0 1974,108,"Based on that initial assessment, IPL identified 40 (0.6%) potentially high-risk suppliers, who were immediately prioritised for further due diligence assessment",0,0,0,0,0,0,1,0,0,0,0 1974,109,"As the next step, each of IPLs existing and new suppliers is assessed by a targeted modern slavery questionnaire, which is issued through the ethiXbase platform, developed in conjunction with Norton Rose Fullbright that covers screening processes, relationships, compliance mechanisms and workforce training",0,0,0,0,0,0,0,1,0,0,0 1974,110,"To date, over 2,700 questionnaires have been issued to our suppliers, with the remaining suppliers to receive questionnaires in FY21",0,0,0,0,0,0,0,0,0,0,0 1974,111,"Once responses are received from the suppliers, they are risk reviewed, and potential and/or actual risks identified",0,0,0,0,0,0,0,0,0,0,0 1974,112,Our Procurement teams prioritise the higher risk areas and work with suppliers on gap-closing action plans where appropriate,0,0,0,0,0,0,0,0,0,0,0 1974,113,IPL continues to evolve its use of third-party due diligence processes to further enable risk factor identification from public and private information sources to then determine and implement effective mitigation steps,0,0,0,0,0,0,0,1,0,0,0 1974,114,"Baseline tools used to support the efficacy of its processes include the Dow Jones Know Your Business portal, ethiXbase and the Transparency International Corruption Perception Index",0,0,0,0,0,0,0,1,0,0,0 4471,143,Controls reviews,0,0,0,0,0,0,0,0,0,0,0 4471,144,BGIS MODERN SLAVERY STATEMENT 11 EFFECTIVENESS OF ACTIONS The application of our Modern Slavery framework is underpinned by a robust governance environment that challenges BGIS to continuously assess risk and improve supply chain transparency,0,0,0,0,0,0,0,0,0,0,0 4471,145,"These efforts have resulted in a program of extensive supplier engagements that seek to improve the capability of our supply partners in order to demonstrate they understand and are taking actions to mitigate modern slavery vulnerability - not only in their direct service provision to BGIS, but also within their own supply chains",0,0,0,0,0,0,0,0,0,0,0 4471,146,Improving the capability of our supply partners is a key objective of the BGIS approach to Sustainable Procurement,0,0,0,0,0,0,0,0,0,0,0 4471,147,"Whilst self assessment can produce variability of response, the ongoing supplier engagement, through clarification and refinement, is both important in raising awareness of modern slavery vulnerability and reinforces BGIS commitments to providing the highest levels of quality and transparency to our clients",0,0,0,0,0,0,0,0,0,1,0 4471,148,"Similarly, the audit program undertaken of high residual risk suppliers, whilst not surfacing any material non- compliance in our supply chain, has identified areas of potential improvement in both the BGIS framework and the systems of control our supply partners use in their operations to provide transparency to BGIS",0,0,0,0,0,0,0,0,0,1,0 4471,149,These learnings are discussed further within Next Steps below,0,0,0,0,0,0,0,0,0,0,0 4471,150,"BGIS MODERN SLAVERY STATEMENT 12 CONSULTATION The BGIS Modern Slavery framework was established by key members of the senior leadership team from our Procurement, Legal, People & Culture and Operating divisions",0,0,0,0,0,0,0,0,0,0,0 1974,115,"Whistleblower System IPL is committed to a culture of compliance, ethical behaviour and good corporate governance that encourages the reporting of improper, illegal and unethical behaviour",0,0,0,0,0,0,0,0,0,0,0 1974,116,"Having a Whistleblower Protection Policy in place and accessible to all employees, in multiple formats and languages, empowers them to confidentially report unethical or illegal conduct and raise concerns regarding actual or suspected contraventions of ethical or legal standards, without fear of victimisation, reprisal or harassment",0,0,0,0,0,0,0,1,0,0,0 1974,117,"In some countries where we operate, there are laws in place that impose specific obligations and protections in relation to whistleblowers",0,0,0,0,0,0,0,1,0,0,0 1974,118,"In Australia, IPL has adopted the Australian Whistleblower Protection Policy to supplement its Group policy",0,0,0,0,0,1,0,1,0,0,0 1974,119,"IPLs Whistleblower Hotline (Navex Global) is an externally managed, worldwide service that is multi-lingual and confidential, and reporters may remain anonymous if they wish",0,0,0,0,0,0,0,1,0,0,0 1974,120,"Navex Global may be contacted at any time and take reports in all countries in which IPL operates and in all our major operating languages, being English, French, Spanish, Chinese, Turkish and Bahasa",0,0,0,0,0,0,0,0,0,0,0 1974,121,"Where a matter has been reported to Navex Global, a Whistleblower Protection Officer will review the report and determine how it should be handled",0,0,0,0,0,0,0,0,1,0,0 1974,122,To report a matter visit: IPLs Whistleblower Hotline Workforce Training Employees and contractors in supplier facing roles are required to undertake modern slavery training via IPLs on-line learning and development system,0,0,0,0,0,0,0,1,0,0,0 4471,151,Progress of the supplier engagements is regularly communicated to the executive leadership team accountable for all BGIS entities,0,0,0,0,0,0,0,0,0,0,1 4471,152,BGIS also provides our clients with information regarding our approach to mitigating modern slavery vulnerability in our operations and supply chains,0,0,0,0,0,0,0,0,0,0,0 4471,153,Further staff communication and training programs are targeted for completion during 2021,0,0,0,0,0,0,0,0,0,0,0 4471,154,"On 1 October 2020, BGIS wholly acquired HFM Asset Management Pty Ltd (HFM)",0,0,0,1,0,0,0,0,0,0,0 4471,155,BGIS has commenced consultation with HFM to apply the BGIS Modern Slavery framework governance to the HFM supply chain,0,0,0,0,0,0,0,0,0,0,1 4471,156,BGIS MODERN SLAVERY STATEMENT 13 NEXT STEPS BGIS has made sound progress in the identification of modern slavery risks and efforts to mitigate those risks in our operating practices through the application of our Modern Slavery framework,0,0,0,0,0,0,0,0,0,0,0 4471,157,Our priorities for 2021 seek to further embed these practices by,0,0,0,0,0,0,0,0,0,0,0 4471,158,improving the support and guidance we provide to suppliers during our assessment programs to leverage the learnings gained within the 2020 audit program,0,0,0,0,0,0,0,0,0,1,0 1974,123,"The module focuses on raising individual awareness of modern slavery, what it means, how it manifests, identification of potential or actual risks, and how to take action if a risk is identified",0,0,0,0,0,0,0,0,0,0,0 1974,124,"To date, approximately 87% of personnel assigned this training have completed it",0,0,0,0,0,0,0,0,0,1,0 1974,125,"This training will be expanded across IPLs global business to ensure it captures the broader workforce, including workforce in higher risk jurisdictions",0,0,0,0,0,0,0,0,0,0,0 1974,126,Remediation Procedure Our Remediation Procedure provides guidance on what to do when the risk (actual or perceived) of modern slavery becomes apparent,0,0,0,0,0,0,0,0,1,0,0 1974,127,"The Procedure defines the roles and responsibilities of those involved in the remediation process, including communication procedures, investigatory steps and actions that must be followed if an incidence of modern slavery is identified and/or substantiated",0,0,0,0,0,0,0,0,1,0,0 1974,128,The Procedure also sets out when a Remediation Action Plan (RAP) is required to be developed and requires the RAP to be tailored to the individual circumstance,0,0,0,0,0,0,0,0,1,0,0 1974,129,Incitec Pivot Limited Modern Slavery Statement 2020 Next Previous,0,0,0,0,0,0,0,0,0,0,0 1974,130,"IPLS MODERN SLAVERY RISKS AND ACTIONS TO RESPOND As we continue to implement and embed our compliance tools, IPL will report any modern slavery risk areas within its operations and supply chains as they are identified annually",0,0,0,0,0,0,0,0,0,0,0 4471,159,expanding our training programs to increase awareness and capability for staff undertaking 3rd party purchasing activities,0,0,0,0,0,0,0,1,0,0,0 4471,160,regularly publishing and reporting outputs of our supplier auditing programs to all areas of our operations to raise ongoing awareness of modern slavery risk,0,0,0,0,0,0,0,0,0,1,0 4471,161,"completing consultation with our HFM entity and further entities who have joined the group in 2021, after the close of the reporting period applicable to this statement",0,0,0,0,0,0,0,0,0,0,1 4471,162,BGIS understands that the efforts to identify and mitigate modern slavery risks in our operations and our supply chains is ongoing,0,0,0,0,0,0,0,0,0,0,0 4471,163,We will seek to continuously refine and improve our approach in order that we effectively and transparently manage modern slavery risks for ourselves and our clients,0,0,0,0,0,0,0,0,0,0,0 4471,164,"apac.bgis.com Head office Level 36, World Square 680 George Street, Sydney NSW 2000 Asia Pacific offices Adelaide | Brisbane | Melbourne | Perth | Sydney | Auckland | Singapore T: 1800 351 235 E: enquiries@apac.bgis.com",0,0,0,1,0,0,0,0,0,0,0 4511,0,Modern Slavery Statement,0,0,0,0,0,0,0,0,0,0,0 4511,1,University of Tasmania 2020,0,0,0,0,0,0,0,0,0,0,0 1974,131,"In accordance with our risk-based, tiered approach IPL is prioritising and working with higher risk suppliers to identify and evaluate risks, using third party data and processes where required",0,0,0,0,0,0,0,0,0,0,0 1974,132,"IPL continues its focus on the well-known human rights risk areas of shipping, with further detail included below",0,0,0,0,0,0,1,0,0,0,0 1974,133,"Other areas of risk in IPLs supply chains include procurement of raw materials and finished goods from higher risk jurisdictions, procurement of technology hardware, Personal Protective Equipment (PPE) and clothing and labour hire",0,0,0,0,0,1,1,0,0,0,0 1974,134,IPL acknowledges that the economic and social impacts of the pandemic could lead to increased modern slavery risks in some parts of its operations and supply chains,0,0,0,0,0,0,1,0,0,0,0 1974,135,IPL reacted quickly to mitigate these impacts though rigorous risk assessment and collaboration with suppliers,0,0,0,0,0,0,1,0,0,0,0 1974,136,"In the Asia Pacific region additional PPE such as face masks and sanitiser were sourced from four existing suppliers who were actively in use prior to the pandemic, for whom due diligence checks had been completed previously",0,0,0,0,0,1,1,0,0,0,0 1974,137,IPL Chartered Vessels IPL utilises various processes with the objective of chartering vessels from reputable vessel owners and operators with proven track records in marine operations and safety,0,0,0,0,0,1,0,0,0,0,0 1974,138,These processes include maintaining appropriate terms and conditions in our shipping contracts and charter parties,0,0,0,0,0,0,0,0,0,0,0 4511,2,M O D E R N SLA V ER Y S T A T E M E N T,0,0,0,0,0,0,0,0,0,0,0 4511,3,"INTRODUCTION This inaugural Statement is for the University of Tasmania, and its controlled entities for the period 1 January 2020 to 31 December 2020",0,0,0,0,0,0,0,0,0,0,0 4511,4,The University of Tasmania is committed to protecting and respecting human rights and has a zero-tolerance approach to slavery and human trafficking in all its forms,0,0,0,0,0,0,0,0,0,0,0 4511,5,The Statement is made in accordance with the requirements in the Modern Slavery Act 2018 (Cth) and sets out the actions taken by the University of Tasmania for the reporting period,0,0,0,0,0,0,0,0,0,0,0 4511,6,"Modern slavery is a broad term used to describe human trafficking, slavery and slave-like practices, often in situations that are used to exploit victims and undermine or deprive them of their freedom",0,0,0,0,0,0,0,1,0,0,0 4511,7,The University is committed to ensuring that we prevent and do not contribute to acts of modern slavery within our supply chains and operations,0,0,0,0,0,0,0,0,0,0,0 4511,8,M O D E R N SLA V ER Y S T A T E M E N T,0,0,0,0,0,0,0,0,0,0,0 4511,9,GOVERNANCE FRAMEWORK MODERN SLAVERY STATEMENT DEVELOPMENT AND APPROVAL,0,0,0,0,0,0,0,0,0,0,0 1974,139,"IPLs charter party agreements include a requirement that the minimum standards of crew wages and terms and conditions of employment - as set out by the International Transport Workers Federation (ITF) - are met, and modern slavery provisions are being included in all new charter party contracts and variations",0,0,0,0,0,0,0,1,0,0,0 1974,140,IPL acknowledges a potential for risk in connection with the period of time crews can remain on board a vessel,0,0,0,0,0,0,1,0,0,0,0 1974,141,This risk has increased during the COVID-19 pandemic as ship owners have been forced to change crews and divert to unscheduled ports to maintain their crew changes,0,0,0,0,0,0,1,0,0,0,0 1974,142,"To manage this risk, the agreements that IPL has with ship owners conform with the Australian Maritime Safety Authority (AMSA) Regulations which dictate the maximum periods crew members can stay on board",0,0,0,0,0,0,0,1,0,0,0 1974,143,"IPL reviews crew lists for each vessel it charters on an individual crew member basis, whether owned by the counterparty or other owner, to verify compliance with AMSAs standards, rejecting vessels that do not comply with AMSAs regulations",0,0,0,0,0,0,0,1,0,0,0 1974,144,"Additionally, IPL uses the vetting service RightShip for every vessel chartered to assist in managing maritime risk and to provide Greenhouse Gas Emissions Ratings (GHG Rating), amongst other measures",0,0,0,0,0,0,0,0,0,0,0 1974,145,"IPL also uses PurpleTRAC to perform a Port State control (PSC) check on every vessel that is chartered, which further ensures safety requirements are met",0,0,0,0,0,0,0,1,0,0,0 1974,146,Modern slavery surveys have been issued to the majority of our sea freight counterparties and suppliers,0,0,0,0,0,0,0,1,0,1,0 4511,10,S TRA TE GIC A L I G N M E N T University of Tasmania Strategic Plan 2019-2024 Strategic Framework for Sustainability,0,0,0,0,0,0,0,0,0,0,0 4511,11,S T A T E M E N T O W NER University Council,0,0,0,0,0,0,0,0,0,0,0 4511,12,"C OMP L I A N C E O W NER General Counsel, Executive Director Legal and Risk",0,0,0,0,0,0,0,0,0,0,0 4511,13,OP ERA T I O N AL O V E R S I G H T Statement Development,0,0,0,0,0,0,0,0,0,0,0 4511,14,COO Division: Legal and Risk,0,0,0,0,0,0,0,0,0,0,0 4511,15,Procurement Risk COO Division: Procurement,0,0,0,0,0,0,1,0,0,0,0 4511,16,"Operational Risks - Research Division, Partnerships & Future Students Division",0,0,0,0,0,0,0,0,0,0,0 4511,17,Continuous Improvement Plan - COO Division: Legal and Risk,0,0,0,0,0,0,0,0,0,0,0 1974,147,We are currently reviewing their responses and any identified risks will be investigated by carrying out further due diligence investigations and meeting with suppliers to agree on action plans,0,0,0,0,0,0,0,0,0,1,0 1974,148,Procurement of Raw Materials and Finished Goods IPLs key raw materials and finished goods are purchased by our Supply Chain and Procurement teams who manage the end to end negotiations and delivery of these products sourced from around the globe,0,0,0,0,0,1,0,0,0,0,0 1974,149,"Key items sourced include but are not limited to urea, phosphate rock, sulphuric acid and ammonium nitrate",0,0,0,0,0,1,1,0,0,0,0 1974,150,"IPL acknowledges the potential risk of modern slavery, based on the jurisdictions in which some of these materials originate or have been manufactured",0,0,0,0,0,0,1,0,0,0,0 1974,151,"As such, our processes incorporate a number of due diligence activities which inform us further on the perceived and actual risks",0,0,0,0,0,0,0,0,0,0,0 1974,152,"In relation to the procurement of fertiliser for the Asia Pacific region, we have 14 suppliers who provide key raw materials and finished fertiliser products",0,0,0,0,0,1,0,0,0,0,0 1974,153,These suppliers are selected and closely managed by subject matter experts within our Supply Chain team,0,0,0,0,0,0,0,0,0,0,0 1974,154,The majority of companies from which we procure are large state owned entities which are subject to human rights regulations within their own jurisdictions,0,0,0,0,0,1,0,0,0,0,0 4511,18,P OL IC Y A L I G N M E N T,0,0,0,0,0,0,0,0,0,0,0 4511,19,Sustainability Policy,0,0,0,0,0,0,0,0,0,0,0 4511,20,Risk Management and Business Policy,0,0,0,0,0,0,0,0,0,0,0 4511,21,Entities and Affiliated Organisations Policy,0,0,0,0,0,0,0,0,0,0,0 4511,22,Procurement Policy Compliance Policy,0,0,0,0,0,0,0,0,0,0,0 4511,23,AP P RO V AL,0,0,0,0,0,0,0,0,0,0,0 4511,24,University Council,0,0,0,0,0,0,0,0,0,0,0 4511,25,Audit & Risk Committee,0,0,0,0,0,0,0,0,0,0,0 1974,155,IPL continues to evaluate supplier responses to the IPL Modern Slavery Questionnaire and will report the outcomes in future years,0,0,0,0,0,0,0,0,0,1,0 1974,156,Incitec Pivot Limited Modern Slavery Statement 2020 9 Next Previous,0,0,0,0,0,0,0,0,0,0,0 1974,157,"Technology Hardware IPL purchases technology hardware from large, well known brands",0,0,0,0,0,1,0,0,0,0,0 1974,158,"Some of these branded products are manufactured by companies that are subject to UK, Australian or Californian human rights legislation, and are required to publish modern slavery statements in accordance with the relevant legislation",0,0,0,0,0,0,0,0,0,0,0 1974,159,"However, IPL recognises the potential for risk of modern slavery in technology hardware supply chains as the majority of hardware manufacturing occurs in countries that do not have a good track record for respecting the rights of workers",0,0,0,0,0,0,1,0,0,0,0 1974,160,IPL has 105 vendors in the Information Technology category,0,0,0,0,0,1,0,0,0,0,0 1974,161,We have purchased hardware from 12 of these in FY20,0,0,0,0,0,1,0,0,0,0,0 1974,162,"To understand our technology supply chain further, we are evaluating responses to the supplier questionnaire, with a view to conducting further investigation where the responses highlight a potential risk or where further information is required",0,0,0,0,0,0,0,0,0,1,0 4511,26,Sustainability Committee,0,0,0,0,0,0,0,0,0,0,0 4511,27,M O D E R N SLA V ER Y S T A T E M E N T,0,0,0,0,0,0,0,0,0,0,0 4511,28,Mandatory Criterion 1 - Identify the reporting entity REPORTING ENTITY The University of Tasmania is a statutory authority constituted under the University of Tasmania Act 1992 (Tas) (UTAS Act),0,0,0,1,0,0,0,0,0,0,0 4511,29,The University is also a registered charity under the Australian Charities and Not-For-Profit Commission Act 2012 (Cth),0,0,0,1,0,0,0,0,0,0,0 4511,30,"This Statement is for the University of Tasmania, and its controlled entities (A.M.C",0,0,1,1,0,0,0,0,0,0,0 4511,31,"Search Limited, UTAS Properties Pty Ltd, Tasmania University Union Inc, UTAS Holdings Pty Ltd, and Sense-Co Tasmania Pty Ltd), together referred to as the University",0,0,1,1,0,0,0,0,0,0,0 4511,32,ABN 30 764 374 782,0,0,0,1,0,0,0,0,0,0,0 4511,33,"Registered Office 2 Churchill Avenue, Sandy Bay, Tasmania",0,0,0,1,0,0,0,0,0,0,0 1974,163,We will continue to review our supply chain for the procurement of IT equipment in line with our policies and procedures,0,0,0,0,0,0,0,0,0,1,0 1974,164,Personal Protective Equipment (PPE) and Clothing PPE incorporates clothing and equipment to protect each person on an IPL site,0,0,0,0,0,0,0,0,0,0,0 1974,165,"Clothing includes hi-visibility shirts, trousers and boots",0,0,0,0,0,0,0,0,0,0,0 1974,166,"PPE includes gloves, glasses, hard hats and ear protection",0,0,0,0,0,0,0,0,0,0,0 1974,167,IPL has four PPE suppliers based in Australia providing goods to the Asia Pacific region,0,0,0,0,0,1,0,0,0,0,0 1974,168,There are seven suppliers based in the United States and providing goods to IPLs operations in North America and Mexico,0,0,0,0,0,1,0,0,0,0,0 1974,169,IPLs PPE and clothing suppliers are in the process of receiving and completing the supplier questionnaire,0,0,0,0,0,0,1,0,0,0,0 1974,170,Those responses received to date have not identified any risks of modern slavery,0,0,0,0,0,0,1,0,0,0,0 4511,34,"Modern slavery is a broad term used to describe human trafficking, slavery and slave-like practices, often in situations that are used to exploit victims and undermine or deprive them of their freedom",0,0,0,0,0,0,0,0,0,0,0 4511,35,The University is committed to ensuring that we prevent and do not contribute to acts of modern slavery within our supply chains and operations,0,0,0,0,0,0,0,0,0,0,0 4511,36,"Mandatory Criterion 2 - Describe the structure, operations and supply chains of the reporting entity STRUCTURE The University is governed by the University Council established under the UTAS Act and has responsibility for high-level strategic direction, major financial planning, monitoring management performance, compliance, and the allocation of funds",0,0,0,1,0,0,0,0,0,0,0 4511,37,"The University Council delegates broad powers to the Vice-Chancellor as the managerial and academic leader, to manage the Universitys operations, and to Academic Senate who advise University Council on all academic matters relating to the University",0,0,0,0,0,0,0,0,0,0,0 4511,38,"The University receives funds from the Australian Government, as well as the State and Local Governments, to assist with education programs covering a wide range of disciplines across different education qualification levels",0,0,0,0,1,0,0,0,0,0,0 4511,39,"In addition to Government funding, the University receives donations, funds and fees from private organisations and individuals that are used for the different programs led by the University or correspond to the education services provided by it",0,0,0,0,1,0,0,0,0,0,0 4511,40,"The University is organised into: COLLEGES College of Arts, Law and Education, College of Health and Medicine, College of Science & Engineering, College of Business and Economics, and University College",0,0,0,0,1,0,0,0,0,0,0 4511,41,"SPECIALIST INSTITUTES Australian Maritime College, Institute for Marine and Antarctic Studies, Menzies Institute for Medical Research, and the Tasmanian Institute for Agriculture",0,0,0,0,1,0,0,0,0,0,0 1974,171,Labour Hire Our workforce consists of both directly hired employees and contractors,0,0,0,0,0,0,0,0,0,0,0 1974,172,Labour hire contractors are a key component of IPLs workforce in Australia,0,0,0,0,0,1,0,0,0,0,0 1974,173,There is limited use of labour hire contractors in IPLs operations outside of Australia and North America,0,0,0,0,0,1,0,0,0,0,0 1974,174,Labour hire in Australia is managed through a small panel of contracted suppliers,0,0,0,0,0,0,0,1,0,0,0 1974,175,IPL maintains regular contact with these suppliers as part of the Supplier Relationship Management Program,0,0,0,0,0,0,0,1,0,0,0 1974,176,"Additionally, IPL is in the process of selecting and implementing a global Contractor Management System to enable improved onboarding and monitoring of contractors across the organisation",0,0,0,0,0,0,0,1,0,0,0 1974,177,"ASSESSING EFFECTIVENESS IPL tracks, manages and reports progress on a range of indicators used to assess the effectiveness of our business programs",0,0,0,0,0,0,0,0,0,0,0 1974,178,"Our processes, including risk assessments, audits and grievance mechanisms, assist in identifying areas for improvement, which are documented using a centralised reporting system",0,0,0,0,0,0,0,0,0,1,0 4511,42,"DIVISIONS Vice-Chancellor, Chief Operating Officer, Academic, Research, and Future Students",0,0,0,0,1,0,0,0,0,0,0 4511,43,CONTROLLED ENTITIES A.M.C,0,0,0,0,0,0,0,0,0,0,0 4511,44,"Search Limited, UTAS Properties Pty Ltd, Tasmania University Union Inc, UTAS Holdings Pty Ltd, and Sense-Co Tasmania Pty Ltd",0,0,0,1,0,0,0,0,0,0,0 4511,45,CONTROLLED,0,0,0,0,0,0,0,0,0,0,0 4511,46,INSTITUTES,0,0,0,0,0,0,0,0,0,0,0 4511,47,M O D E R N SLA V ER Y S T A T E M E N T,0,0,0,0,0,0,0,0,0,0,0 4511,48,GOVERNANCE University Council delegates oversight of the Legal Compliance Framework to the University Audit and Risk Committee,0,0,0,0,0,0,0,1,0,0,0 4511,49,"The Universitys Compliance function, reporting to the General Counsel, Executive Director Legal and Risk, is responsible for the development of this Statement and oversight of the implementation of our modern slavery initiatives",0,0,0,0,0,0,0,1,0,0,0 1974,179,"These processes are being utilised to track, manage and report the progress of IPLs modern slavery compliance system",0,0,0,0,0,0,0,0,0,1,0 1974,180,"As we deepen our understanding of the modern slavery risks within IPLs supply chains, we will continue to develop tools to assess the effectiveness of our modern slavery identification and assessment processes and will report on this annually",0,0,0,0,0,0,0,0,0,0,0 1974,181,IPL has not experienced any adverse modern slavery allegations or circumstances impacting its supply chains or operations during FY20 and remains confident that its assessment and identification procedures are effective,0,0,0,0,0,0,1,0,0,0,0 1974,182,"CONSULTATION WITH CONTROLLED ENTITIES IPL has centralised management and procurement practices, with the Procurement and Supply Chain teams having responsibility for identifying and assessing risks in IPLs global supply chain",0,0,0,0,0,0,0,0,0,0,0 1974,183,"This Modern Slavery Statement has been prepared with input from Procurement and Supply Chain teams across all jurisdictions in which we operate and in consultation with representatives from other key areas of our global business including Sustainability, Human Resources, Legal and Risk",0,0,0,0,0,0,0,0,0,0,1 1974,184,"The Modern Slavery Statement has been provided to the Executive Team and the directors of each reporting entity for comment, prior to being put to the Board of Incitec Pivot Limited for review and approval",0,0,0,0,0,0,0,0,0,0,1 1974,185,Incitec Pivot Limited Modern Slavery Statement 2020 Next Previous,0,0,0,0,0,0,0,0,0,0,0 1974,186,Incitec Pivot Limited Modern Slavery Statement 2020 11 CONTINUOUS IMPROVEMENT APPROACH Over the next year IPL will continue its focus on identifying and addressing modern slavery risks across its global business and supply chains,0,0,0,0,0,0,0,0,0,0,0 4511,50,Accountability for addressing modern slavery risk is shared across multiple areas ensuring that our initiatives and supporting processes are embedded broadly,0,0,0,0,0,0,0,1,0,0,0 4511,51,"Risks of modern slavery are reported and monitored centrally through the Legal Compliance Framework, and are supported by actions such as education and awareness",0,0,0,0,0,0,0,1,0,0,0 4511,52,OPERATIONS The University is the sole higher education provider in Tasmania,0,0,0,0,1,0,0,0,0,0,0 4511,53,We are located on a remarkable and distinctive island with unique natural and Indigenous heritages,0,0,0,0,0,0,0,0,0,0,0 4511,54,"Our 33,000 students attend campuses located in three of the States distinct regions, as well as New South Wales, online, and internationally in collaboration with partner institutions in Asia",0,0,0,0,1,0,0,0,0,0,0 4511,55,"The University employs 1869 full-time equivalent staff, 670 part-time and 259 casual staff across diverse operations, which supports our fundamental purpose to deliver world leading teaching, learning and research",0,0,0,1,1,0,0,0,0,0,0 4511,56,"Our operations include financial, safety, people, IT, asset, risk, sustainability and facility management, as well as student services such as scholarships, student exchange, library services, English language support, counselling, and accommodation",0,0,0,0,1,0,0,0,0,0,0 4511,57,"Our cutting-edge research is critical for Tasmania, making great use of our unique location, while contributing meaningfully to global priorities",0,0,0,0,0,0,0,0,0,0,0 1974,187,Key areas of focus will include: further refining of the supplier due diligence program including engaging with the suppliers in relation to their responses to the supplier questionnaire; expanding and mandating modern slavery awareness training among our people; and further improving the identification and mitigation of risks by increasing awareness among our supplier community and ensuring transparency and accountability with each supplier,0,0,0,0,0,0,0,1,0,0,0 1974,188,IPL will continue to track and publicly report its progress and publish a Modern Slavery Statement annually,0,0,0,0,0,0,0,0,0,0,0 1974,189,This statement has been approved by IPLs Board of Directors,1,0,0,0,0,0,0,0,0,0,0 1974,190,"Jeanne Johns Managing Director & CEO, Incitec Pivot Limited March 2021 Next Previous",0,1,0,0,0,0,0,0,0,0,0 4511,58,"We are committed to realising the economic, social and environmental impacts from our research outputs, working with domestic and international partners to use and commercialise university owned intellectual property",0,0,0,0,1,0,0,0,0,0,0 4511,59,"We engage with the Tasmanian community, State Government, the Commonwealth Government, other universities, commercial partners, and third parties to deliver learning and teaching and undertake research",0,0,0,0,1,0,0,0,0,0,0 4511,60,"We are connected to alumni across Tasmania and around the world, all of whom are deeply committed to Tasmania and the values that are central to our mission",0,0,0,0,0,0,0,0,0,0,0 4511,61,M O D E R N SLA V ER Y S T A T E M E N T,0,0,0,0,0,0,0,0,0,0,0 4511,62,SUPPLY CHAIN We purchase a diverse range of goods and services in accordance with the University Procurement Policy,0,0,0,0,0,0,0,0,0,0,0 4511,63,"The Procurement Policy supports the Universitys values and guides behaviour in relation to all operational, capital and research procurement related activities for the purpose of advancing the Universitys objectives",0,0,0,0,0,0,0,1,0,0,0 4511,64,This includes specific guiding principles in relation to risks of modern slavery,0,0,0,0,0,0,0,1,0,0,0 4511,65,Our supply chain is complex and geographically diverse,0,0,0,0,0,1,0,0,0,0,0 4511,66,We procure goods and services from small family businesses through to global multi-national companies,0,0,0,0,0,1,0,0,0,0,0 4511,67,"For the reporting period, the University procured $255.4 million in goods in services from 11,500 suppliers",0,0,0,0,0,1,0,0,0,0,0 4511,68,"PROCUREMENT POLICY PRINCIPLES All procurement decisions must reflect value for money, are not limited to price, consider sustainable and ethical principles, maximise opportunities for local suppliers, and include managing the risk of modern slavery",0,0,0,0,0,0,0,0,0,0,0 4511,69,Goods and services procured by the University include,0,0,0,0,0,1,0,0,0,0,0 4511,70,Building and construction services and supplies,0,0,0,0,0,1,0,0,0,0,0 4511,71,"Electronic goods (server hardware, computers, audio visual equipment, tablets and phones)",0,0,0,0,0,1,0,0,0,0,0 4511,72,"Facilities, asset and waste management services",0,0,0,0,0,1,0,0,0,0,0 4511,73,"Laboratory supplies (small and large equipment, chemicals, consumables, pharmaceuticals)",0,0,0,0,0,1,0,0,0,0,0 4511,74,Food and catering supplies,0,0,0,0,0,1,0,0,0,0,0 4511,75,Domestic and international travel services,0,0,0,0,0,1,0,0,0,0,0 4511,76,Furniture,0,0,0,0,0,1,0,0,0,0,0 4511,77,Office supplies,0,0,0,0,0,1,0,0,0,0,0 4511,78,Books and printing The University has preferred supplier arrangements through University-Wide Contracts (UWCs),0,0,0,0,0,1,0,0,0,0,0 4511,79,"Preferred suppliers are pre-qualified on a range of criteria, including responses to questions about management of modern slavery risk in their supply chains and operations",0,0,0,0,0,0,0,1,0,0,0 4511,80,"OPERATING, RESEARCH AND CAPITAL EXPENDITURE",0,0,0,0,0,0,0,0,0,0,0 4511,81,Operating Funds Capital Works Research and Teaching,0,0,0,0,1,0,0,0,0,0,0 4511,82,$65.57M (25.68%),0,0,0,0,0,0,0,0,0,0,0 4511,83,$114.93M (45%),0,0,0,0,0,0,0,0,0,0,0 4511,84,$74.89M (29.32%),0,0,0,0,0,0,0,0,0,0,0 4511,85,M O D E R N SLA V ER Y S T A T E M E N T,0,0,0,0,0,0,0,0,0,0,0 4511,86,"Mandatory Criterion 3 - Describe the risks of modern slavery practices in the operations and supply chains of the reporting entity RISKS OF MODERN SLAVERY Management of modern slavery risk, both in our supply chains and operations, is assessed and managed in accordance with the University Risk Management Framework and the University Risk Appetite",0,0,0,0,0,0,0,1,0,0,0 4511,87,The Audit and Risk Committee is responsible for providing oversight on behalf of University Council,0,0,0,0,0,0,0,1,0,0,0 4511,88,"During 2020, the University undertook a risk assessment of its supply chains and operations to identify any risks of modern slavery",0,0,0,0,0,0,0,1,0,0,0 4511,89,"In understanding the risks of modern slavery within supply chains and operations, the University is taking a proactive approach to managing any potential or emerging modern slavery risks",0,0,0,0,0,0,0,1,0,0,0 4511,90,"We do this by contributing to and leveraging the work of the Australian University Procurement Network (AUPN) (supply chains), and utilising third party resources including",0,0,0,0,0,0,0,1,0,0,0 4511,91,Modern Slavery Registry Global Slavery Index,0,0,0,0,0,0,0,0,0,0,0 4511,92,Verisk Maplecraft Human Rights indices,0,0,0,0,0,0,0,0,0,0,0 4511,93,Global Compact Network,0,0,0,0,0,0,0,0,0,0,0 4511,94,Transparency International Corruption Perceptions Index,0,0,0,0,0,0,0,0,0,0,0 4511,95,OECD Due Diligence Guidance for Responsible Business Conduct,0,0,0,0,0,0,0,0,0,0,0 4511,96,RISK ASSESSMENT The University carried out a detailed risk assessment across our all of our operations,0,0,0,0,0,0,0,1,0,0,0 4511,97,"We have assessed risks that may cause, contribute or are linked to modern slavery practices",0,0,0,0,0,0,0,1,0,0,0 4511,98,Potential risks have then been analysed and evaluated in accordance with the University Risk Management Framework,0,0,0,0,0,0,0,1,0,0,0 4511,99,The three areas identified as having potential risks of modern slavery are,0,0,0,0,0,0,1,0,0,0,0 4511,100,Procurement,0,0,0,0,0,0,0,0,0,0,0 4511,101,Research Operations,0,0,0,0,0,0,0,0,0,0,0 4511,102,International Operations Our assessment to date has not identified any cases of modern slavery in either our operations or supply chains,0,0,0,0,0,0,1,0,0,0,0 4511,103,"However, we recognise that despite our best efforts to identify modern slavery, it may be associated with the goods and services we procure due to the complex and diverse nature of our supply chains",0,0,0,0,0,0,1,0,0,0,0 4511,104,"By its nature, modern slavery can be difficult to detect given it often sits in legitimate industries",0,0,0,0,0,0,0,0,0,0,0 4511,105,"Due to controls, the residual risks of modern slavery are low to moderate",0,0,0,0,0,0,1,0,0,0,0 4511,106,"SPOTLIGHT ON OUR INVESTMENT PORTFOLIO Our investment portfolio spans Australian and international equity markets, infrastructure, private equity investments, and across a number of sectors",0,0,0,0,1,0,0,0,0,0,0 4511,107,"The assessment of modern slavery risks in the investment portfolio is considered through our assessment of environment, social, and governance (ESG) factors in our investment decision process",0,0,0,0,0,0,0,1,0,0,0 4511,108,Our Treasury and Investment Policy mandates a positive screen that considers the United Nations Sustainable Development Goals,0,0,0,0,0,0,0,1,0,0,0 4511,109,"The key elements underpinning the United Nations Principles of Responsible Investment (PRI) are embedded within our investment decision process, with fund managers required to be signatories to the PRI or have equivalent policies in place",0,0,0,0,0,0,0,1,0,0,0 4511,110,"We also undertake an annual strategy review, including a performance assessment of fund managers",0,0,0,0,0,0,0,0,0,1,0 4511,111,"To this extent, the University does not knowingly invest directly or indirectly in organisations that are in breach of the Modern Slavery Act 2018 (Cth)",0,0,0,0,0,0,1,0,0,0,0 4511,112,M O D E R N SLA V ER Y S T A T E M E N T,0,0,0,0,0,0,0,0,0,0,0 4511,113,"AUSTRALIAN UNIVERSITY PROCUREMENT NETWORK (AUPN) The University is a member of the AUPN, which is leading a sector-wide collaboration to support all member universities to meet the challenge of human rights transparency and assist members to fulfil the reporting requirements of the Modern Slavery Act 2018 (Cth)",0,0,0,0,0,0,0,1,0,0,0 4511,114,"The AUPN provides support to assist member universities to manage risks, develop processes and support education initiatives in relation to",0,0,0,0,0,0,0,0,0,0,0 4511,115,"Potential risks of modern slavery applied against spend categories using the AUPN taxonomy, and",0,0,0,0,0,0,0,1,0,0,0 4511,116,Potential risks of modern slavery applied against country locations using supplier head office location,0,0,0,0,0,0,0,1,0,0,0 4511,117,"Using the aggregated sector data, a list of suppliers with potentially high risks of modern slavery presence in their supply chain has identified that the highest risks within higher education sector supply chains are",0,0,0,0,0,0,1,0,0,0,0 4511,118,risks of modern slavery,0,0,0,0,0,0,0,0,0,0,0 4511,119,Our university has provided the AUPN with spend data for 2018 and 2019,0,0,0,0,0,0,0,1,0,0,0 4511,120,"This data has been combined with more than 27 other member universities, which reflects the broad supply chains of the sector",0,0,0,0,0,0,0,1,0,0,0 4511,121,Initial INFORMATION TECHNOLOGY & COMMUNICATIONS (ICT),0,0,0,0,0,0,0,0,0,0,0 4511,122,CLOTHING & APPAREL,0,0,0,0,0,0,0,0,0,0,0 4511,123,"analysis of the aggregated spend data covers more than $24.1 billion annualised spend across more than 304,205 individual suppliers",0,0,0,0,0,0,0,1,0,0,0 4511,124,"Using this data, the AUPN have developed a Modern Slavery Risk Dashboard, which the University is using as the first step to provide an indication of risk across two different lenses: FOOD CONSTRUCTION CLEANING",0,0,0,0,0,0,0,1,0,0,0 4511,125,"We are leveraging the due diligence work the AUPN are carrying out on high-risk global companies to inform our approach to modern slavery risk management, mitigation and remediation",0,0,0,0,0,0,0,1,0,0,0 4511,126,We will concentrate our internal due diligence resourcing efforts on identified local (Australian) high risk suppliers,0,0,0,0,0,0,0,0,0,0,0 4511,127,TOTAL UNIVERSITY SPEND BY CATEGORY,0,0,0,0,0,0,0,0,0,0,0 4511,128,$3.28M (1.28%) $5.17M (2.02%) $9.2M (3.61%) $9.36M (3.67%),0,0,0,0,0,1,0,0,0,0,0 4511,129,$9.73M (3.81%),0,0,0,0,0,0,0,0,0,0,0 4511,130,$24.8M (9.72%),0,0,0,0,0,0,0,0,0,0,0 4511,131,$37.65M (14.75%) $1.8M (0.7%),0,0,0,0,0,0,0,0,0,0,0 4511,132,$85.78M (33.6%),0,0,0,0,0,0,0,0,0,0,0 4511,133,"$55.98M (21.93%) Corporate professional services Construction, refurbishment and works IT and Telecoms Buildings and grounds Laboratories and research Marketing and media Utilities Property Office related supplies and services Travel and entertainment Library services Student services Logisitics and storage Lecturer and teaching expenses Plant and vehicles",0,0,0,0,0,1,0,0,0,0,0 4511,134,"The University will utilise internal procurement data and the AUPN technology solution to further interrogate our supply chain, identify risk, focus resources and inform actions around modern slavery risk management",0,0,0,0,0,0,0,1,0,0,0 4511,135,M O D E R N SLA V ER Y S T A T E M E N T,0,0,0,0,0,0,0,0,0,0,0 4511,136,"Mandatory Criterion 4 - Describe the actions taken by the entity to assess and address risks, including due diligence and remediation processes ACTIONS TAKEN TO ADDRESS RISKS, DUE DILIGENCE AND REMEDIATION The University is taking a risk-based, continuous improvement approach to managing risks of modern slavery",0,0,0,0,0,0,0,1,0,0,0 4511,137,"In 2020, we have undertaken seven main actions",0,0,0,0,0,0,0,1,0,0,0 4511,138,Detailed risk assessment in relation to our domestic operations,0,0,0,0,0,0,0,1,0,0,0 4511,139,Leveraged our AUPN membership to understand the potential risks of modern slavery in our supply chains,0,0,0,0,0,0,0,1,0,0,0 4511,140,Implemented due diligence processes within our procurement procedures,0,0,0,0,0,0,0,1,0,0,0 4511,141,Provided academic expertise and advice to the AUPN Modern Slavery Academic Advisory Board,0,0,0,0,0,0,0,1,0,0,0 4511,142,Commenced an educational program in high- risk areas to support awareness about the risks of modern slavery,0,0,0,0,0,0,0,1,0,0,0 4511,143,Reviewed all template contracts and purchase order terms to incorporate clauses to identify and manage modern slavery risks,0,0,0,0,0,0,0,1,0,0,0 4511,144,Implemented a contract management approach to risk management and remediation CONTRACT MANAGEMENT APPROACH TO RISK MITIGATION AND REMEDIATION Our procurement processes place an onus on suppliers and contractors to provide the University with certain evidence and information about the management of modern slavery risks within their organisations,0,0,0,0,0,0,0,1,0,0,0 4511,145,"Beyond procurement, our immediate response has been the development of appropriate contract management processes",0,0,0,0,0,0,0,1,0,0,0 4511,146,"The University risk assessment identified a number of areas that could potentially be at risk, including some areas in research and our international operations",0,0,0,0,0,0,1,0,0,0,0 4511,147,Our initial response to this has been to embed our expectations in our contracts to highlight our commitment to the importance of ensuring awareness and visibility about the risks of modern slavery,0,0,0,0,0,0,0,0,0,0,0 4511,148,This includes,0,0,0,0,0,0,0,0,0,0,0 4511,149,International agreements and partnerships,0,0,0,0,0,0,0,0,0,0,0 4511,150,General MOUs,0,0,0,0,0,0,0,0,0,0,0 4511,151,General & Construction contracts,0,0,0,0,0,0,0,0,0,0,0 4511,152,Leases,0,0,0,0,0,0,0,0,0,0,0 4511,153,Work Integrated Learning Any contracts or agreements containing modern slavery clauses,0,0,0,0,0,0,0,1,0,0,0 4511,154,Require certain disclosures and notifications,0,0,0,0,0,0,0,1,0,0,0 4511,155,Require annual audit and reviews,0,0,0,0,0,0,0,1,0,0,0 4511,156,Require evidence to be provided about how risks of modern slavery are managed and mitigated,0,0,0,0,0,0,0,1,0,0,0 4511,157,Provide for termination where modern slavery is identified and the party refuses to remediate or address risk (last resort),0,0,0,0,0,0,0,0,1,0,0 4511,158,M O D E R N SLA V ER Y S T A T E M E N T,0,0,0,0,0,0,0,0,0,0,0 4511,159,"DUE DILIGENCE Suppliers and Contracts All new suppliers, contractors and partners are subjected to our due diligence process, prior to onboarding or contract award",0,0,0,0,0,0,0,1,0,0,0 4511,160,"Suppliers of goods and services with a spend of more than $200,000 are requested to answer a pre-qualification questionnaire administered as part of the Request for Tender (RFT)",0,0,0,0,0,0,0,1,0,0,0 4511,161,Responses to the questionnaire are evaluated by the University procurement team,0,0,0,0,0,0,0,1,0,0,0 4511,162,"Questionnaire responses help us identify potential areas of risk, and where identified, the supplier will be referred for further detailed due diligence",0,0,0,0,0,0,0,1,0,0,0 4511,163,AUPN Data The AUPN technology platform will assist to inform our due diligence assessments,0,0,0,0,0,0,0,1,0,0,0 4511,164,"Initially, we will use data across each category or by location",0,0,0,0,0,0,0,1,0,0,0 4511,165,"Where a potential risk is identified, we will investigate the supplier further and refer them for a more detailed assessment that may be undertaken by our Procurement and Compliance teams",0,0,0,0,0,0,0,1,0,0,0 4511,166,Further assessments include requiring the supplier or partner to provide relevant internal policies and procedures or audit reports,0,0,0,0,0,0,0,1,0,0,0 4511,167,International Partners The COVID-19 pandemic has presented challenges in carrying out detailed risk assessment and due diligence on high risk international partners,0,0,0,0,0,0,1,0,0,0,0 4511,168,The University will recommence this work once borders reopen and we are in a position to engage with our international partners face to face,0,0,0,0,0,0,0,0,0,0,0 4511,169,REMEDIATION We have not received any notifications about risks of modern slavery in the reporting period,0,0,0,0,0,0,1,0,0,0,0 4511,170,"In anticipation of reports, the University is developing remediation processes that take an educative and collaborative approach to mitigate risks of modern slavery",0,0,0,0,0,0,0,0,1,0,0 4511,171,"In most cases, the University will favour working with suppliers and business partners to resolve or substantially mitigate issues, rather than ending the agreement with the supplier or partner",0,0,0,0,0,0,0,0,1,0,0 4511,172,This is due to the potential adverse effects on the livelihood of the suppliers staff members,0,0,0,0,0,0,0,0,1,0,0 4511,173,EDUCATION & AWARENESS Our Staff The Modern Slavery Project Team was drawn from the areas across the University most likely to be at risk,0,0,0,0,0,0,0,1,0,0,0 4511,174,Assessing risk activities required member representatives to engage broadly across their respective area to raise awareness and educate staff about modern slavery,0,0,0,0,0,0,0,1,0,0,0 4511,175,This has resulted in deep engagement and a broad level of understanding across the high risk areas,0,0,0,0,0,0,0,0,0,0,0 4511,176,This work will continue into the next reporting period,0,0,0,0,0,0,0,0,0,0,0 4511,177,"Our Partners The University will seek to influence suppliers and partner behaviour, working with identified high risk areas to educate and build awareness about the risks of modern slavery",0,0,0,0,0,0,0,1,0,0,0 4511,178,"We will set our expectations in accordance with our values, and place people at the centre of our decision making, with a view to ensuring that our activities do not cause or contribute to risks of modern slavery",0,0,0,0,0,0,0,0,0,0,0 4511,179,"Our Students Our students have indicated that they have strong views about how the University should address issues of sustainability, including human rights risks",0,0,0,0,0,0,0,0,0,0,0 4511,180,"The University will continue to engage with students to raise awareness about risks of modern slavery, provide support for students who may be at risk, and provide safe pathways for reporting any suspected modern slavery",0,0,0,0,0,0,0,1,0,0,0 4511,181,M O D E R N SLA V ER Y S T A T E M E N T,0,0,0,0,0,0,0,0,0,0,0 4511,182,Mandatory Criterion 5 - Describe how the reporting entity assess the effectiveness of actions being taken to address modern slavery risks ASSESSING EFFECTIVENESS Audit and Risk Committee The University Audit and Risk Committee have a key oversight role in assessing and ensuring the effectiveness of the Modern Slavery Continuous Improvement Plan,0,0,0,0,0,0,0,0,0,1,0 4511,183,Twice yearly reports are provided to the Committee which outline,0,0,0,0,0,0,0,0,0,1,0 4511,184,Emerging risks,0,0,0,0,0,0,0,0,0,1,0 4511,185,Incidences of modern slavery and remediation activities,0,0,0,0,0,0,0,0,0,1,0 4511,186,"Progress against the Continuous Improvement Plan Procurement In the first reporting period, the University has incorporated mandatory questions to modern slavery criteria within Request for Tender documents",0,0,0,0,0,0,0,1,0,1,0 4511,187,We are assessing responses received to those questions and will utilise this data to inform our approach to supplier engagement and awareness,0,0,0,0,0,0,0,0,0,1,0 4511,188,Contracts Our immediate response to mitigation of potential modern slavery risk has been to implement specific contract clauses within a broad range of agreements including with our international partners,0,0,0,0,0,0,0,1,0,0,0 4511,189,"We have committed to ongoing monitoring of contracts, and will use this data to inform our review processes and gaps",0,0,0,0,0,0,0,0,0,1,0 4511,190,"Community Feedback from staff, students and community members forms an integral part of assessing the Universitys effectiveness in relation to modern slavery",0,0,0,0,0,0,0,0,0,1,0 4511,191,"We will continue to engage with our community to ensure that our approach not only meets regulatory compliance, but also exceeds community expectations",0,0,0,0,0,0,0,0,0,1,0 4511,192,Mandatory Criterion 6 - Describe the process of consultation with any controlled entities CONSULTATION University controlled entities operate in accordance with the University Controlled and Associated Entities Governance Principles,0,0,0,0,0,0,0,0,0,0,1 4511,193,Boards of controlled entities report to University Council and must ensure its functions and activities are carried out in accordance with its constitution and relevant laws,0,0,0,0,0,0,0,0,0,0,1 4511,194,Boards must also ensure oversight of risk and compliance issues including obligations under the Modern Slavery Act 2018 (Cth),0,0,0,0,0,0,0,0,0,0,1 4511,195,"The University consults and works closely with controlled entities to ensure their compliance obligations, including risk management in relation to modern slavery, are met",0,0,0,0,0,0,0,0,0,0,1 4511,196,"Mandatory Criterion 7 - Any other relevant information REPORTING CONCERNS In all aspects of University activities, we are focused on ensuring the protection and respect of human rights across our business and supply chain",0,0,0,0,0,0,0,0,0,0,0 4511,197,Staff and students have a number of pathways to gain access to information about how the University manages risks of modern slavery as well as ways to report (including anonymously) suspected cases of modern slavery,0,0,0,0,0,0,0,1,0,0,0 4511,198,"This includes reporting concerns to the Safe and Fair Community Unit (SaFCU), where we have established reporting procedures and mechanisms to investigate any concerns regarding unethical or illegal conduct, including concerns in relation to modern slavery and human trafficking",0,0,0,0,0,0,0,1,0,0,0 4511,199,The 2020 University Modern Slavery Statement was endorsed by University Council on 30 April 2021,1,0,0,0,0,0,0,0,0,0,0 4511,200,Signed,0,1,0,0,0,0,0,0,0,0,0 4511,201,Chancellor Vice-Chancellor,0,1,0,0,0,0,0,0,0,0,0 4680,0,MODERN SLAVERY STATEMENT 2020,0,0,0,0,0,0,0,0,0,0,0 4680,1,"Introduction The Reporting entity, Think Childcare Group, a stapled entity listed on the Australian Securities Exchange (ASX:TNK) comprising: Think Childcare Limited ACN 600 793 388 (TNK) and Think Childcare Development Limited ACN 635 178 166 (TND), both being public companies limited by shares and together with its controlled entities, as outlined in the 2020 Think Childcare Group Annual Report (collectively, the Group) is a unique operator and developer of greenfield child care Services with corporate headquarters based in Sydney, Australia",0,0,1,1,1,0,0,0,0,0,0 4680,2,This joint statement is the first report of the Group under the Act for the period ended 31 December 2020 and was guided by the Modern Slavery Act 2018 (Cth) (Act) and Commonwealth Modern Slavery Act 2018 Guidance for Reporting Entities and covers the activities of the Group,0,0,0,0,0,0,0,0,0,0,0 4680,3,"The Groups owned and controlled entities, operate under the direction and governance of the Boards of TNK and TND and share the same executive management team who have been consulted to develop this modern slavery statement",0,0,0,1,0,0,0,0,0,0,1 4680,4,Our executive management and the Boards have been kept informed of the key requirements of the Act and the actions undertaken to address and assess the modern slavery risks as detailed in this statement,0,0,0,0,0,0,0,0,0,0,0 4680,5,The Group operates on a calendar year reporting period and is reporting for the period 1 January 2020 to 31 December 2020 (Report Period),0,0,0,0,0,0,0,0,0,0,0 4680,6,"Structure and operations Think Childcare Group is a stapled entity listed on the Australian Securities Exchange (ASX: TNK) comprising Think Childcare Limited (TNK) (ABN 81 600 793 388) and its controlled entities and Think Childcare Development Limited (TND) (ABN 55 635 178 166) and its controlled entities (collectively, the Group)",0,0,0,1,0,0,0,0,0,0,0 4680,7,TNK is an owner and operator of predominately mature child care Services under the Nido brand supported by long term leases,0,0,0,0,1,0,0,0,0,0,0 4680,8,"TNK also manage child care Services on behalf of TND, third-party incubators and clients",0,0,0,0,1,0,0,0,0,0,0 4680,9,Figure 1: Highlights of the Groups operations as at 31 December 2020,0,0,0,0,1,0,0,0,0,0,0 4680,10,TND is an owner of greenfield child care Services and continues to source a pipeline of high quality child care Services located in premium markets,0,0,0,0,1,0,0,0,0,0,0 4680,11,TND focuses on developing purpose-built child care Services under the Nido brand and operating model,0,0,0,0,1,0,0,0,0,0,0 4680,12,"Additionally, it invests in upgrading facilities at developing child care Services and trades-up child care Services before selling the child care Services to TNK",0,0,0,0,1,0,0,0,0,0,0 4680,13,Our operations are entirely based in Australia,0,0,0,0,1,0,0,0,0,0,0 4680,14,"As a Group, at 31 December 2020, our national portfolio consisted of 93 long day child care Services for children between the ages of six weeks and six years old across Australia",0,0,0,0,1,0,0,0,0,0,0 4680,15,The Group has an ownership interest in 83 of these child care Services,0,0,0,0,1,0,0,0,0,0,0 4680,16,Figure 2: Location of child care Services across Australia as at 31 December 2020,0,0,0,0,1,0,0,0,0,0,0 4680,17,Further information about the Group and our operations can be found in the 2020 Think Childcare Group Annual Report at: https://thinkchildcare.com.au/assets/pdf/TNK%202020%20Group%20Annual%20Report%20to%20s ecurity%20holders.pdf,0,0,0,0,0,0,0,0,0,0,0 4680,18,Our supply chain Our direct suppliers are located in Australia,0,0,0,0,0,1,0,0,0,0,0 4680,19,"During the Report Period, we procured services from over 500 suppliers and contractors",0,0,0,0,0,1,0,0,0,0,0 4680,20,These ranged from large multinational businesses to small operations located in the regions and communities in which our child care Services operate,0,0,0,0,0,1,0,0,0,0,0 4680,21,"In total, we spent over $18 million in our supply chain, with less than 0.2% of expenditure paid to suppliers outside Australia, in operating our businesses and developing and delivering our child care Service pipeline",0,0,0,0,0,1,0,0,0,0,0 4680,22,The majority of overseas products and services were IT and marketing subscriptions,0,0,0,0,0,1,0,0,0,0,0 4680,23,11 7,0,0,0,0,0,0,0,0,0,0,0 4680,24,ACT 2,0,0,0,0,0,0,0,0,0,0,0 4680,25,Our top 4 supply chain categories were,0,0,0,0,0,0,0,0,0,0,0 4680,26,Spend Category,0,0,0,0,0,0,0,0,0,0,0 4680,27,"Examples of suppliers engaged Leasehold development and improvements Include costs associated with the fit-out phases of new child care Services, as well as upgrades and refurbishments to existing child care Services: Builders and trades people, material suppliers, whitegoods and furniture suppliers and classroom equipment suppliers",0,0,0,0,0,1,0,0,0,0,0 4680,28,"Rent and outgoings related services Suppliers of facilities management services such as cleaners, hygiene and pest control waste management, landscaping and utilities (energy, gas, water)",0,0,0,0,0,1,0,0,0,0,0 4680,29,"Service consumables Goods and services required for the care of children at our child care Services, including suppliers of groceries and food products, sanitary items (ie nappies, wipes, toilet paper), craft supplies and educational material",0,0,0,0,0,1,0,0,0,0,0 4680,30,"Corporate office costs Suppliers of IT equipment and software licence fees, marketing, professional services (audit, legal, other consultants) and travel",0,0,0,0,0,1,0,0,0,0,0 4680,31,Modern Slavery Risk in our Operations and Supply Chain,0,0,0,0,0,0,0,0,0,0,0 4680,32,"As our operations are solely based in Australia, our engagement of casual employees through labour hire agencies and all of our direct suppliers are based in Australia, however, we recognise that some of our direct suppliers have operations or may have supply chains which are quite layered, in foreign countries",0,0,0,0,1,1,1,0,0,0,0 4680,33,"Additionally, we recognise that the pressure on suppliers to maintain competitive pricing can be a driver for modern slavery",0,0,0,0,0,0,0,0,0,0,0 4680,34,"From an operational perspective, as most of our suppliers are Australian contractors local to our child care Services, we are comfortable that there is a very low risk of modern slavery",0,0,0,0,0,0,1,0,0,0,0 4680,35,"During the Report Period, we implemented a number of initiatives and processes to strengthen our oversight of the Groups modern slavery risks, supported by our frameworks, policies and procedures",0,0,0,0,0,0,0,0,0,0,0 4680,36,We have implemented the following processes to embed modern slavery considerations for our current supply chain and the onboarding of new suppliers: We have undertaken an internal risk assessment of our supply chain in order to better understand our exposure to modern slavery risks,0,0,0,0,0,0,0,1,0,0,0 4680,37,This assessment is still ongoing and updated on a regular basis,0,0,0,0,0,0,0,1,0,0,0 4680,38,"For suppliers that we determine are high risk, we would engage with that supplier further to assess and establish their risk profile",0,0,0,0,0,0,0,1,0,0,0 4680,39,We established a supplier code of conduct and a supplier procurement process and continue to perform reviews of our current suppliers to assess their modern slavery risk profile,0,0,0,0,0,0,0,1,0,1,0 4680,40,"For the onboarding of new suppliers, enhanced due diligence is performed where a supplier is classified as having an elevated risk of modern slavery",0,0,0,0,0,0,0,1,0,0,0 4680,41,"For all new supply contracts and renewal of existing supply contracts, suppliers are requested to acknowledge our Modern Slavery Policy and Supplier Code of Conduct",0,0,0,0,0,0,0,1,0,0,0 4680,42,"For suppliers who lack awareness of the risk of modern slavery or the risks in their supply chain, we would engage with them to improve their understanding of modern slavery and visibility of their supply chain",0,0,0,0,0,0,0,1,0,0,0 4680,43,"Our employees, contractors and suppliers are encouraged to report concerns regarding questionable business practices, unethical conduct, and suspected non-compliance with policies",0,0,0,0,0,0,0,1,0,0,0 4680,44,"Assessing the effectiveness of actions being taken to assess and address Modern Slavery risks We are in the process of developing a framework for assessing the effectiveness of actions taken to manage our modern slavery risk, which will involve tracking, reporting and reviewing the effectiveness of our approach",0,0,0,0,0,0,0,0,0,0,0 4680,45,"Governance and Management The Boards of TNK and TND have ultimate responsibility for the Groups governance, strategy, performance and management of risks and opportunities",0,0,0,0,0,0,0,0,0,0,0 4680,46,"To assist the Boards in its duties, the Group has an Audit, Risk and Compliance Committee and an executive general manager team which includes the Risk and Compliance Officers",0,0,0,0,0,0,0,0,0,0,0 4680,47,"The Group is committed to effective corporate governance policies and practices, and we undertake regular reviews of our governance obligations",0,0,0,0,0,0,0,0,0,1,0 4680,48,"Policies and procedures Our approach to modern slavery risk is supported by the Groups Modern Slavery Policy in conjunction with a broader framework of policies and processes, including our Code of Conduct, Whistleblower Policy and our Employee Assistance Program",0,0,0,0,0,0,0,1,0,0,0 4680,49,We will continue to review and improve policies and procedures based on the outcomes of our actions,0,0,0,0,0,0,0,0,0,1,0 4680,50,Looking forward The Group will continue to review the progress of our actions and improve our practices to strengthen our management controls,0,0,0,0,0,0,0,0,0,1,0 4680,51,"During the 2021 financial year, we will focus on the following tasks: Finalise our framework for assessing the effectiveness of our actions taken to manage modern slavery risk",0,0,0,0,0,0,0,1,0,0,0 4680,52,"We will continue with our internal risk assessment of our supply chain to prioritise high risk suppliers and where appropriate, to collaborate with our suppliers to address modern slavery risk",0,0,0,0,0,0,0,1,0,0,0 4680,53,"Providing employees, contract managers and suppliers with the necessary training to equip them with the knowledge and skills to identify high risk suppliers",0,0,0,0,0,0,0,1,0,0,0 4680,54,Ensure that all new suppliers receive updated commercial terms that incorporate modern slavery requirements,0,0,0,0,0,0,0,1,0,0,0 4680,55,We are confident that our actions to date will assist us to address modern slavery risk,0,0,0,0,0,0,0,0,0,0,0 4680,56,We are committed to building on from this work to further embed our modern slavery policy and processes,0,0,0,0,0,0,0,0,0,0,0 4680,57,across the Group,0,0,0,0,0,0,0,0,0,0,0 4680,58,"Additionally, we look forward to working with our suppliers to continue strengthening our management of modern slavery risks",0,0,0,0,0,0,0,0,0,0,0 4680,59,This statement was approved by the boards of Think Childcare Limited and Think Childcare Development Limited on behalf of itself and all the other reporting entities covered by this joint statement on 22 June 2021,1,0,0,0,0,0,0,0,0,0,0 4680,60,Mathew Edwards Managing Director and Chief Executive Officer 25 June 2021,0,1,0,0,0,0,0,0,0,0,0 4744,0,"| 1 QBE Insurance Group Limited (QBE) is an international insurance and reinsurance company, with operations in all the key insurance markets",0,0,0,0,1,0,0,0,0,0,0 4744,1,"It is listed on the Australian Securities Exchange and is headquartered in Sydney, employing more than 11,690 people in 27 countries",0,0,0,1,0,0,0,0,0,0,0 4744,2,"QBE operates in four divisions North America, Australia Pacific, QBEs Group Shared Services Centre in the Philippines and International (United Kingdom, Europe, Asia, Canada, and the Middle East)",0,0,0,0,1,0,0,0,0,0,0 4744,3,"In accordance with the Australian Commonwealth Modern Slavery Act 2018 (Cth) and section 54 of the Modern Slavery Act 2015 (UK), this statement describes the steps that QBE Insurance Group Limited and those entities detailed at the end of this statement have taken during the financial year ended 31 December 2020 to ensure that slavery and human trafficking is not taking place in any of our supply chains or within our own business",0,0,1,0,0,0,0,0,0,0,0 4744,4,"2020 Modern Slavery and Human Trafficking Statement Our position on modern slavery We reject any form of slavery, servitude, forced or compulsory labour (including child labour) and human trafficking and are committed to implementing and enforcing effective systems and controls to ensure these practices do not take place in our own business or our supply chains",0,0,0,0,0,0,0,0,0,0,0 4744,5,"To this end, we aim to identify and manage any risks related to modern slavery across our own organisation and through our supply chain relationships",0,0,0,0,0,0,0,0,0,0,0 4744,6,"Respecting human rights Wherever we operate, we respect the human rights of our employees, customers, communities and those of our suppliers and business partners",0,0,0,0,0,0,0,0,0,0,0 4744,7,"We are committed to, and promote adherence to, internationally recognised human rights standards and guiding principles, including",0,0,0,0,0,0,0,1,0,0,0 4744,8,International Bill of Human Rights,0,0,0,0,0,0,0,1,0,0,0 4744,9,International Labour Organisations eight fundamental Conventions; and,0,0,0,0,0,0,0,1,0,0,0 4744,10,United Nations Guiding Principles on Business and Human Rights,0,0,0,0,0,0,0,1,0,0,0 4744,11,QBE is working to align our sustainability agenda to support the advancement of the United Nations Sustainable Development Goals (SDGs),0,0,0,0,0,0,0,1,0,0,0 4744,12,"We have chosen to prioritise five of these goals, including Goal 8: Decent work and economic growth",0,0,0,0,0,0,0,1,0,0,0 4744,13,"One of the focus areas for this goal is on protecting human and labour rights within our business and across our supply chain, essential for ensuring QBE remains a responsible employer and business partner",0,0,0,0,0,0,0,0,0,0,0 4744,14,In 2020 QBE became a signatory to the United Nations Global Compact,0,0,0,0,0,0,0,1,0,0,0 4744,15,"We continue to work to integrate the ten universal principles relating to human rights, labour, environment and anti-corruption across our strategy, culture and day-to-day operations and QBE is committed to respecting human rights in the way it does business globally",0,0,0,0,0,0,0,0,0,0,0 4744,16,Further information can be found in our 2020 Sustainability Report,0,0,0,0,0,0,0,0,0,0,0 4744,17,"| 2 Policies and governance Our Boards and their Committees provide the necessary leadership to implement strong corporate governance across the Group so that our decisions and actions are based on transparency, integrity, responsibility and performance, which promotes the long-term sustainability and ongoing success of our business",0,0,0,0,0,0,0,0,0,0,0 4744,18,"QBE has policies and standards in relevant areas, including our",0,0,0,0,0,0,0,1,0,0,0 4744,19,Group Code of Ethics and Conduct (the Code),0,0,0,0,0,0,0,1,0,0,0 4744,20,Modern Slavery Risk & Compliance Standard,0,0,0,0,0,0,0,1,0,0,0 4744,21,Group Human Rights Policy,0,0,0,0,0,0,0,1,0,0,0 4744,22,Group Anti-bribery and Anti-corruption Policy,0,0,0,0,0,0,0,1,0,0,0 4744,23,Group Sanctions Policy,0,0,0,0,0,0,0,1,0,0,0 4744,24,Group Whistleblowing Policy,0,0,0,0,0,0,0,1,0,0,0 4744,25,Group Outsourcing Policy,0,0,0,0,0,0,0,1,0,0,0 4744,26,Procurement Policy,0,0,0,0,0,0,0,1,0,0,0 4744,27,"Global Work, Health and Safety Policy; and",0,0,0,0,0,0,0,1,0,0,0 4744,28,Global Diversity and Inclusion Policy,0,0,0,0,0,0,0,0,0,0,0 4744,29,These policies are periodically reviewed to ensure they are aligned with modern slavery requirements,0,0,0,0,0,0,0,0,0,1,0 4744,30,"In 2020, the Modern Slavery Risk & Compliance Standard was developed detailing minimum requirements around due diligence to minimise the risk of modern slavery in our supply chains",0,0,0,0,0,0,0,1,0,0,0 4744,31,"These policies are available on our intranet and public summaries for some of these policies, as well as our Supplier Sustainability Principles, are available here",0,0,0,0,0,0,0,0,0,0,0 4744,32,"Ethics and conduct As a responsible business, QBE is committed to dealing honestly and fairly with our customers",0,0,0,0,0,0,0,0,0,0,0 4744,33,"We are committed to the proper management of the risk of unfair customer outcomes and any detriment to the integrity of the insurance industry, wherever we operate",0,0,0,0,0,0,0,0,0,0,0 4744,34,The Code sets out our commitment and responsibility to respect human rights,0,0,0,0,0,0,0,0,0,0,0 4744,35,"It also addresses the responsibilities we all have to QBE, to each other, and to our customers, suppliers, communities, and governments",0,0,0,0,0,0,0,0,0,0,0 4744,36,"It sets out the standards of behaviour we expect of our people, which include our directors and contractors and embodies our commitment to good corporate governance, responsible business and ethical practices",0,0,0,0,0,0,0,0,0,0,0 4744,37,"Our supply chain QBEs third-party counterparties includes suppliers (eg IT, consultancy, professional service, recruitment, facilities, etc) and other third parties supporting Underwriting and Claims processes, including directly appointed, customer nominated parties",0,0,0,0,0,1,0,0,0,0,0 4744,38,"We acknowledge and recognise the potential for modern slavery to occur within our supply chains, regardless of location",0,0,0,0,0,0,1,0,0,0,0 4744,39,We expect our suppliers to manage their business and supply chains in a manner that respects human rights as set out in the International Bill of Human Rights and the UN Guiding Principles on Business and Human Rights,0,0,0,0,0,0,0,1,0,0,0 4744,40,We are reinforcing this expectation in contractual obligations with suppliers on the terms of QBEs own global supply agreements for goods and services,0,0,0,0,0,0,0,1,0,0,0 4744,41,We have categorised our suppliers with whom we have a direct relationship (first tier suppliers) and assessed these for potential exposure to modern slavery and human trafficking,0,0,0,0,0,0,0,1,0,0,0 4744,42,Supplier Sustainability Principles The Supplier Sustainability Principles (Principles) outline the minimum standards required to conduct business with QBE across a range of sustainability topics which include ensuring suppliers remain compliant with relevant local and national laws related to human rights in respect of their employees and business operations,0,0,0,0,0,0,0,1,0,0,0 4744,43,"The Principles set out the expectation that suppliers ensure all employees and contractors are working of their own free will and that no bonded, forced or involuntary labour, child labour, human trafficking or other form of slavery is employed in the delivery of all products or services",0,0,0,0,0,0,0,1,0,0,0 4744,44,| 3 Risk management and due diligence QBEs supplier management framework governs key supplier arrangements and assists to manage QBEs commercial risk in our dealings with suppliers,0,0,0,0,0,0,0,1,0,0,0 4744,45,Supplier risk assessments are undertaken for certain procurement activities to identify the level of risk inherent in proceeding with a potential arrangement,0,0,0,0,0,0,0,1,0,0,0 4744,46,During 2020 we implemented a new risk assessment and due diligence approach for modern slavery risk using self-assessment questionnaire tools,0,0,0,0,0,0,0,1,0,0,0 4744,47,Modern slavery risk is reviewed periodically for QBEs suppliers and processes and controls have been strengthened during 2020,0,0,0,0,0,0,0,1,0,0,0 4744,48,"We have been working to improve reporting, investigation, and remediation of incidents",0,0,0,0,0,0,0,0,0,0,0 4744,49,"Training on modern slavery and human trafficking To support the roll out of these new risk management and due diligence processes, training on modern slavery and human trafficking has been provided during 2020 to Procurement teams involved in the on-boarding and on-going management of our suppliers",0,0,0,0,0,0,0,1,0,0,0 4744,50,Effectiveness of steps being taken Modern slavery risk is tracked and monitored as part of QBEs supplier management reporting and exception reporting processes,0,0,0,0,0,0,0,1,0,0,0 4744,51,"Ongoing activities QBE is committed to continuous improvement and to ensuring that adequate policies, processes, systems, and controls are in place to identify and mitigate modern slavery and human right issues and risks, within our business and supply chains",0,0,0,0,0,0,0,0,0,0,0 4744,52,"QBE has implemented a global action plan, which will be rolled out during 2021",0,0,0,0,0,0,0,1,0,0,0 4744,53,The plan will deliver,0,0,0,0,0,0,0,1,0,0,0 4744,54,"Training and awareness raising, including targeted learning for employees who have key responsibilities for identifying and managing modern slavery risk",0,0,0,0,0,0,0,1,0,0,0 4744,55,Processes to continue to improve monitoring and assessment of the effectiveness of steps taken through KPIs and regular reporting; and,0,0,0,0,0,0,0,0,0,1,0 4744,56,Extending existing risk management and due diligence processes to other third-party groups,0,0,0,0,0,0,0,1,0,0,0 4744,57,"We acknowledge that these matters continue to evolve, which in turn means that businesses must adapt to identify and mitigate these risks but also understand the human element which requires all business to be vigilant and versatile",0,0,0,0,0,0,0,0,0,0,0 4744,58,"Approval of this statement This statement was approved by the Board of QBE Insurance Group Limited ABN 28 008 485 014 on 10 June 2021 and the Boards of EO plc, QUK, QUL, QBE Europe, QMSUK and QBE Partner Services on 28 June 2021 and has been prepared on behalf of QBE Insurance Group Limited and its subsidiaries and controlled entities as documented in Note 7.3.1 in the 2020 Annual Report",1,0,0,0,0,0,0,0,0,0,0 4744,59,"Signed, Richard Pryce Interim Group Chief Executive Officer Dated: 10 June 2021 Jason Harris Chief Executive Officer, International Dated: 28 June 2021",0,1,0,0,0,0,0,0,0,0,0