How we're managing modern slavery risks

With the passage into law of the Modern Slavery Act in November 2018, we explain how we continue to manage modern slavery risks two years on.

The passage into law of the Modern Slavery Act in November 2018 was the culmination of many years of advocacy with our partners, the Responsible Investment Association of Australasia, and the Uniting Church’s Justice and International Mission unit.

Monitoring for modern slavery risks in cross-border supply chains is now mandatory for Australia’s largest organisations, whereby relevant organisations are required to publish annual modern slavery statements against six mandated criteria. This will improve accountability, transparency and comparability, and highlight industries and organisations that are most likely enabling modern slavery.

Managing modern slavery risk in our portfolios

Since the law was passed, we’ve continued to actively engage with companies within our portfolios on human rights issues including modern slavery and incorporated modern slavery considerations into our investment screening. Our Ethical Investment Policy specifically mandates the investment team to review companies for unacceptable business activities that would cover modern slavery.

As an ethical investor, we also integrate environment, social and governance (ESG) factors into our investment process. Through this ESG review we look at labour management and supply chain issues which can uncover modern slavery risks. Our Board and Investment Committee provide oversight of the investment team and relevant ethical and ESG issues and our Ethical Advisory Panel provides independent advice.

Managing modern slavery risk in our supply chain

In FY20, we took additional steps in mapping our supply chain to identify modern slavery risks. As part of the ongoing commitment, we will actively engage with our suppliers where findings indicate risks of modern slavery breaches. A formal joint statement with the Uniting Church in Australia – Synod of Victoria and Tasmania will be lodged with the Department of Home Affairs in March 2021.

Since the law passed, we have also updated our Outsourcing and Procurement Policy to embed modern slavery risk management throughout the procurement process, enabling a risk-conscious view and transparency in our supply chain.

As reporting from companies improves over time, we expect to have further insight on ways that we can improve our processes. We are committed to engaging with companies on modern slavery issues. We will continue to update our network in the coming months on the issue.