These specific options above are not explicitly listed. However, there are a few reasons why I'm not exactly sure how to categorize the company's compliance. They describe their supply chain (page 10), disclosing that they engaged with 3,304 Tier 1 suppliers in 2021. They also say that most of their modern slavery risks are more applicable to the supply chains they have rather than the full time employees that mostly work on mainland Australia. In regards to their supply chains, they are not very explicit in their expectations, but do note that they used the Global Slavery Index, Dow Jones Due Diligence Reports, and Robobai (a third party IT solution) to increase their understanding for the 2021 statement. They then list the modern slavery risks with related products or services the company provides. Then on page 20, they expand on their future processes to assess and respond to risks including supplier due diligence, new contractual clauses, and new supplier selection and onboarding procedures.
pg. 02
"― Embedded a modern slavery clause in a number of our Precedent Agreements;"
pg. 20
"In 2021, we updated our contract templates to include modern slavery provisions. These clauses oblige an APA counterparty to:
― comply with modern slavery laws;"
pg. 21
"The new form calls for suppliers to declare that they will respect their workers’ fundamental human rights including but not limited to:
― providing a safe working environment (and appropriate accommodation facilities if being provided)
― paying a fair wage in accordance with all relevant State and Commonwealth laws and regulations
― equal treatment without distinction based on gender, race, age, religion
― freedom from forced labour, including access to employee documentation and passports (if internationally sourced labour), and
― freedom to join a union or other similar collective bargaining arrangement."