Modern slavery statement

Our statement on modern slavery

We publish an annual statement on modern slavery where we outline how we have performed in our response to addressing modern slavery, and our future areas of focus. It is an important opportunity for us to reflect on our efforts, share our progress and learnings, and recognise where challenges persist and what we can do better.

The statement includes a description of our structure, business and supply chains, including the policies, standards and processes that contribute to our control framework to respect human rights and help protect against our involvement in modern slavery. We identify where we may be involved in modern slavery risks in our business and supply chains. We also explain our due diligence processes for how we assess and mitigate modern slavery risks including our approach to training and capacity building and how we engage and collaborate with stakeholders. We describe our grievance mechanisms and remediation processes. We also explain how we assess the effectiveness of our actions and outline the process of consultation undertaken across our business. Our statements align with the requirements of modern slavery reporting laws globally.

Assessing our effectiveness

We track and assess the effectiveness of our actions in a number of ways:

• internal tracking, including of due diligence and training activities
• internal assurance, including internal audits and reviews
• monitoring our asset and Group-level grievance mechanisms
• engaging with business partners and external stakeholders for input and feedback
• applying a theory of change and impact measurement framework to our modern slavery approach

Support for the UK, Australian and Canadian Modern Slavery Acts

We strongly support the UK, Australian and Canadian Modern Slavery Acts and we proudly advocated for the Australian Modern Slavery Act’s establishment. In 2018, we publicly endorsed the introduction of the draft legislation and its final passage by the Australian Parliament, including by signing a multi-stakeholder letter to the Prime Minister. In 2023, as part of the 3-year review of the Modern Slavery Act, we co-authored a submission to the Australian Government led-review with the Human Rights Resources and Energy Collaborative.

We continue to support the effective implementation of the Australian Modern Slavery Act. We continue to participate in collaborative initiatives such as the Human Rights Resources and Energy Collaborative, Minerals Council of Australia Modern Slavery Taskforce and the Global Compact Network Australia’s Modern Slavery Community of Practice, to share learnings, progress implementation of the Modern Slavery Acts and broader modern slavery risk management.

Practitioner-led collaboration

The Human Rights Resources and Energy Collaborative (HRREC) was formed in 2019 by practitioners committed to respecting human rights in our respective businesses and, addressing modern slavery risks in our operations and supply chains. It is a forum where practitioners can share learnings, challenges and develop best practice for respecting human rights.

Key achievements in 2023 included:

• Developed and launched with Walk Free a Modern Slavery Response and Remedy Framework, which is designed to provide practical guidance to assist companies with their response to modern slavery or related exploitation in their supply chains or operations.
• Developed guidance on social auditing in supply chains to promote a consistent, clear and effective approach for companies and suppliers in the industry and to use as training and awareness raising. This was designed to promote a “beyond audit” mindset and avoid pitfalls of auditing that was seen in the apparel and fast-moving goods industries.
• Co-authored a submission to the Australian Government-led review of the Modern Slavery Act 2018 (Cth).