pg. 12
"During FY20, we launched a pilot program through which we partnered with two suppliers in our prioritised high-risk categories (construction and cleaning) to identify opportunities to minimise modern slavery risks in our supply chain. To initiate the collaborations, we reviewed and validated their Responsible Sourcing assessments and held a workshop with each supplier to share challenges and opportunities.
The following common challenges and opportunities were raised across the workshops:
-Modern slavery risk assessments: a structured industry approach would help to manage the administrative workload in both assessing suppliers for risk and completing risk assessments
-Supply chain mapping: a coordinated process to help identify suppliers beyond our tier 1 suppliers to gain greater end to end supply chain transparency
-Labour hire practices: promoting transparency of contractor and sub-contractor relationships would help gain visibility of and manage risks in this space
-Employee communications and training: implementation would be supported by appropriately engaging suppliers’ employees in training programs that are aligned to their cultural background or native language
-Identification of available support and resources: engaging with industry and non-government bodies could help identify areas to leverage industry expertise and resources
Through this collaboration, we drafted a ‘Sustainability Partnership Plan’ (SPP) with each supplier, outlining key areas of focus and proposed actions that seek to strengthen capability and controls for managing modern slavery risks.
In FY21, we intend to finalise the SPP, jointly deliver on agreed actions, monitor effectiveness and use what we learn from the pilot to establish a formal ongoing process for engaging suppliers on future SPPs. The goal for this initiative is to deliver mutually beneficial outcomes that address modern slavery risks for both ourselves and our suppliers."
pg. 17
"Assessing the effectiveness of our actions
We are committed to continually improving our approach to advancing human rights. We recognise that measures of effectiveness are critical to assist in informing appropriate actions to address our modern slavery risks.
We sought to appraise the activities conducted during the year, by both tracking the output and seeking feedback from key stakeholders to gain insight into the effectiveness of our actions and inform improvement opportunities in future reporting periods. This included tracking general awareness training participation, updates to policy and procedure documents and the outcomes of our risk assessments.
We have outlined a description of the measures that we will seek to implement in FY21 in the table below. We recognise opportunities to build on these, which are captured in our future focus section on page 18.
AS A FINANCIAL SERVICES PROVIDER, LENDER AND INVESTOR
MEASURING EFFECTIVENESS
Number of channels used to raise suspicions or disclose of human rights issues
Number of suspicions or disclosures of modern slavery raised by customers through a suitable specialist team
Number of suspicions or disclosures of modern slavery issues received through grievance channels
Number of suspicions or disclosures of modern slavery issues remediated
AS A PURCHASER OF GOODS AND SERVICES
MEASURING EFFECTIVENESS
Percentage of suppliers in high-risk categories with completed responsible sourcing assessments
Number of suppliers in high-risk categories that have improved their risk rating
Number of suppliers who agreed to participate in Sustainability Partnership Plans
AS AN EMPLOYER
MEASURING EFFECTIVENESS
Percentage of employees who complete onboarding training to schedule
Percentage of employees that participate in modern slavery training
Number of visits to modern slavery intranet
Percentage of employee expats participating in cultural briefings"