In accordance with the Australian Modern Slavery Act 2018, a Modern Slavery Statement is a mandatory annual statement that organisations with greater than $100m in consolidated annual revenue are required to prepare. The purpose of this report is to provide information on the risks of modern slavery in the reporting entity’s operations and supply chain. It will also detail the actions taken to address those risks.
The report must include information on the entity’s due diligence processes, any actions taken to address identified risks, and the effectiveness of those actions. It must also describe the entity’s policies and procedures relating to modern slavery, and the relevant training provided to staff.
Modern Slavery Statements are a key tool in the Australian legislative environment aimed at combatting modern slavery and ensuring that large businesses and organisations are taking steps to identify and address risks of modern slavery in their operations and supply chains.
Who needs to produce a Modern Slavery statement?
The Modern Slavery Act mandates that all Australian entities with a consolidated annual revenue of more than $100 million AUD must produce an annual Modern Slavery Statement. This also applies to foreign entities carrying on business in Australia with a total annual revenue of more than $100 million AUD.
Once submitted, Modern Slavery Statements are maintained by the Australian Border Force in a publicly accessible register. These can be viewed in the Online Register for Modern Slavery Statements.
How do clients on Cm3 manage their Modern Slavery risks?
Cm3’s ecosystem contains a number of tools that can assist the collection of information required about vendors (including Contractors and Suppliers) to enable businesses to meet their reporting requirements under the Modern Slavery Act. Cm3 can also work closely with clients to meet more specific data collection requirements and produce recommendations.
One Cm3 client, Red Bull Australia Pty Ltd, recently published their Modern Slavery Statement for 2022. The document outlined their engagement of Cm3 for the distribution of a Modern Slavery questionnaire to their key partners across sectors such as marketing, media, and services, totalling approximately 50% of local spend.
Cm3 Modern Slavery Supplier Audit Results
In 2021 we engaged our recognised third-party supplier, Cm3, to issue Ethical Sourcing screening questions and a subsequent Modern Slavery questionnaire to Red Bull Australia Tier 1 spend suppliers. These results were reviewed by a Cm3 Compliance Manager and subsequently used to generate recommendations from both a supplier and systems perspective.
During 2022, we will continue to focus on those higher risk suppliers as identified within our 2021 questionnaire. In addition, we will investigate the opportunity for our new and existing Tier 1 suppliers to complete a Red Bull supplied training module around Modern Slavery risks within the Supply Chain. The intention of this initiative is to increase their awareness of the global modern slavery risks and how to combat this within their own Supply Chain.
During the 2022 reporting period, Red Bull actioned a number of the recommendations provided by Cm3 as a result of analysis of suppliers’ survey responses. Red Bull’s identified areas for further attention includes “specific formulation of actions/recommendations from Cm3 Questionnaire for Tier 1 respondents” and “tabling these regularly at key performance indicator meetings, setting deadlines and ensuring agreed recommendations are appropriately actioned.”
Similarly, Scentre Group detailed within their Modern Slavery statement how their use of Cm3 assisted in their engagement and assessment of contractors.
Suppliers who provide services in our Westfield Living Centres and are pre-qualified using Cm3 (an external supplier prequalification provider) also complete a modern slavery self-assessment questionnaire as part of our onboarding and prequalification process.
In 2022, Scentre Group will continue to review the results of these self-assessments to identify any additional areas of high risk, the level of supplier understanding and engagement about the risk of modern slavery, and use this review to inform our approach for further supplier engagement.