Modern slavery risk mitigation for suppliers
Suppliers play a vital role in mitigating the risk of modern slavery in Victorian public health sector supply chains. To reduce risk and affect meaningful change, we encourage suppliers to take a proactive stance against modern slavery.
Suppliers on HSV collective agreements are required to:
- comply with HSV supplier mandatory minimum standards (for procurement activities commencing from 1 July 2024)
- if applicable, meet requirements under the Modern Slavery Act 2018.
Suppliers are also required to comply with the Victorian Government’s Buying for Victoria Supplier Code of Conduct and to follow the Fair Jobs Code for suppliers and businesses.
HSV supplier mandatory minimum standards
We are introducing modern slavery mandatory minimum standards that will apply to all HSV collective agreement procurement activity commencing from 1 July 2024.
The standards aim to mitigate modern slavery risks in the supply chains of goods and services we source for Victoria’s public health services. The standards are designed to raise supplier awareness about, and work to mitigate the risk of, modern slavery in their supply chains. Suppliers are expected to build their capacity to mitigate risks over time.
The standards form part of HSV’s modern slavery risk mitigation program. The standards are outlined below.
We will work with suppliers on implementing the standards into their operations and supply chains and we will conduct annual risk assessments to track progress over time.
The standards, examples and resources
The size of a supplier business will determine how each standard should be applied within the business. Small to medium businesses are not expected to show the same depth of compliance as large organisations. We have included examples of how this might work in your organisation under each of the standards set out below.
Standard 1 – Modern slavery policy
|
Suppliers must have a written policy that shows a commitment to addressing modern slavery risks faced by their business. The policy should be:
|
Example: small to medium supplier
Supplier A is a small supplier of pharmaceutical products. Supplier A does not have a standalone modern slavery policy. To meet standard 1, it has included a section in its business strategy that states a commitment to ethical sourcing by avoiding products and services from situations of forced labour. Supplier A takes relevant steps to ensure it meets this commitment.
Example: large supplier
Supplier B is a large, global pharmaceutical company. Supplier B has a comprehensive modern slavery policy integral to its corporate social responsibility charter. The policy was approved by the company board and has been communicated to key stakeholders including Supplier B’s employees, suppliers and contractors. The policy is regularly reviewed and forms part of Supplier B’s governance practices.
Resource
Modern Slavery: Information for Small Business is a factsheet prepared by the NSW Government Small Business Commissioner. The factsheet features a modern slavery policy template to aid small businesses to design a modern slavery policy.
Standard 2 – Due diligence
|
Suppliers must take actions to identify, prevent, and reduce modern slavery risks in their supply chains. Actions can include:
|
Example: small to medium supplier
Supplier A is a small, Australian supplier of medical equipment. Supplier A requires all new employees to provide official documentation that establishes their right to work in Australia. This process of due diligence helps ensure Supplier A is not inadvertently employing people under conditions of modern slavery.
Example: large supplier
Supplier B is a large manufacturer of medical equipment and has rigorous due diligence processes. Supplier B incorporates modern slavery clauses into new contracts and conducts pre-screening of all potential suppliers prior to engaging with them. Supplier B’s pre-screening process involves using a modern slavery risk assessment tool to assess a potential supplier’s risks and the actions it will take should any significant risks be identified.
Resources
- Guidance on Reasonable Steps to Manage Modern Slavery Risks in Operations and Supply-Chains: Inherent Risk Identification Tool is a tool provided by the NSW Government Department of Communities and Justice. The tool assigns modern slavery risk levels to 374 product categories procured by the NSW Government.
- Modern Slavery Benchmarking Tool is a tool provided by Walk Free. The tool helps companies establish best practices for assessing and addressing modern slavery risks across their operations and value chain. It offers an initial performance score and a list of improvement steps, including guidance on stakeholder disclosure.
Standard 3 – Grievance mechanism, response and remediation
|
Suppliers must have a formal process for employees and suppliers to report modern slavery concerns. This includes a process for responding to and remediating incidents of modern slavery. The grievance process should be accessible to:
Suppliers should also require their suppliers to have grievance processes. |
Example: small to medium supplier
Supplier A is a small business that specialises in medical supplies. Supplier A has a dedicated email address for reporting grievances. Employees can report concerns and suggestions by emailing the address. The process is confidential and can be anonymous. Supplier A follows up on concerns and suggestions raised and escalates to relevant authorities when required.
Example: large supplier
Supplier B is a major metropolitan hospital. Supplier B has a robust grievance reporting and remediation process available in multiple languages that all employees, patients, and suppliers can access. The process is transparent. Affected individuals are kept safe from repercussions, updated regularly throughout the process and informed about the outcome. Supplier B’s remediation process involves providing biennial training to its employees and external stakeholders. Supplier B also has strong connections with relevant authorities.
Resources
- Effective Modern Slavery Grievance Mechanisms: A Case Study Publication for Business is a report prepared by the United Nations Global Compact. The report aims to help Australian businesses understand, establish, and operate effective grievance mechanisms to address modern slavery in their operations and supply chains.
- Modern Slavery Response & Remedy Framework is a framework designed by Walk Free. The framework guides companies in the energy and resources sectors to address and remediate modern slavery in line with international and Australian standards.
Standard 4 – Training
|
To raise awareness and build capability for identifying and preventing modern slavery risks, suppliers must provide training to their employees and within their supply chain. This can include:
|
Example: small to medium supplier
Supplier A is a small supplier of personal protective equipment. Supplier A requires its procurement employees to complete annual modern slavery risk training. Supplier A records the training and seeks feedback from employees to identify opportunities to make improvements to the training over time.
Example: large supplier
Supplier B is a large, global pharmaceutical distributor. To raise awareness on modern slavery risks, Supplier B conducts extensive modern slavery training for all employees and contractors, and throughout their supply chain. The training is compulsory and is required to be completed biennially. Supplier B records the training and seeks feedback from those who have completed the training to identify opportunities to make improvements to the training over time. Supplier B includes information on the training in its annual statement required under the Modern Slavery Act.
Resources
- Free online modern slavery risk mitigation training has been developed by HealthShare Victoria to increase knowledge and awareness of modern slavery.
- Modern Slavery Resources made available by the Supply Chain Sustainability School include e-learning modules from beginner to advanced levels.
- It’s healthy to Fight Modern Slavery is a YouTube video that explores modern slavery in healthcare. The video looks at the role of NSW healthcare practitioners and the actions that can be taken to mitigate modern slavery in the healthcare sector.
Standard 5 – Determining effectiveness
|
Suppliers must be able to describe measures they use to identify the effectiveness of the actions they take to reduce or mitigate modern slavery risks. This can include:
|
Example: small to medium supplier
Supplier A is a medium-sized supplier of medical items. Supplier A sets key performance indicators to support modern slavery risk reduction and mitigation. For example, they aim to provide modern slavery risk mitigation training to all employees within the first year. The following year, Supplier A broadens its training program to include the first tier of its supply chain. Supplier A demonstrates it is progressively building modern slavery risk mitigation capacity by including different parts of its business in training over the ensuing years.
Example: large supplier
Supplier B is a large multinational healthcare corporation. Supplier B sets key performance indicators including undertaking regular audits, conducting supplier risk assessments, and providing employee training. Supplier B benchmarks its practices against applicable industry standards and includes this information in its annual statement required under the Modern Slavery Act. To assess the effectiveness of its modern slavery policy, Supplier B measures its performance against its key performance indicators and industry standards.
Resources
- Addressing Modern Slavery in Long and Complex Supply Chains is a research paper led by the University of Oxford Policy & Evidence Centre. It examines how organisations understand and implement effective governance strategies to address modern slavery in long and complex supply chains.
- 2023 Corporate Human Rights Benchmark is a report from the World Benchmarking Alliance (WBA). The WBA evaluated the top 2,000 globally influential companies (SDG2000) on their performance in respecting human rights. The benchmark findings offer valuable insights for companies to improve human rights practices, promote leadership engagement, and explore collaborative solutions to key industry challenges.
HSV risk mitigation training
We offer modern slavery risk mitigation training for suppliers.
The Modern Slavery Act
Under the Modern Slavery Act 2018, suppliers with annual revenue of at least $100 million are required to prepare an annual modern slavery statement. Businesses with revenue under $100 million can report voluntarily and are encouraged to do so.
To prepare a modern slavery statement, visit the Australian Government Attorney-General's Department modern slavery resources webpage, section 'Guidance material' for the Commonwealth Official Modern Slavery Act Guidance for Reporting Entities. The guide covers the actions to take to meet obligations under the Act.
For an overview of modern slavery, information on the Modern Slavery Act and how to prepare and submit statements, visit the modern slavery page on the Attorney-General’s Department website. For further guidance, suppliers should access the Attorney-General’s Department modern slavery resources.
Additional resources
We have collated resources from various organisations who work to address modern slavery risk. These resources may help you to meet your obligations and better understand modern slavery risk in your supply chain. (Please note HSV does not suggest these resources are exhaustive or best practice.)
Developing Modern Slavery Act resources
- Commonwealth Government instructions on complying with the Modern Slavery Act including reporting on efforts to address and prevent modern slavery in operations and supply chains, titled The Commonwealth Modern Slavery Act 2018 Guidance for Reporting Entities.
- A Red Cross introductory guide to Addressing modern slavery – A guide for Australian businesses.
- A University of NSW collaborative research project providing guidance for businesses on core aspects of human rights due diligence and how to strengthen their responses to the Modern Slavery Act, titled Good Practice Toolkit: Strengthening Modern Slavery Responses.
- A Global Compact Network Australia playbook, raising awareness and providing support to businesses to identify, manage and mitigate their risk of being involved in modern slavery, titled Modern Slavery Risk Management: A playbook for Australian SMEs.
Industry focus resources
Cleaning industry
- A report by the Cleaning Accountability Framework (CAF) titled Cleaning Contractors: Modern Slavery Guidance. The CAF is an organisation dedicated to improving labour practices in the cleaning industry. The CAF works with stakeholders across the supply chain to ensure ethical standards.
- A Cleaning Accountability Framework (CAF) YouTube video explaining how businesses should apply the UN Guiding Principles on Business and Human Rights in their modern slavery reporting. The video focuses on human rights due diligence and remediation, particularly in the cleaning industry through CAF certification and is titled CAF Certification through a modern slavery lens.
- An Everyday Slavery YouTube video exploring modern slavery in the cleaning industry, highlighting unfair pricing, lived experiences of exploitation, and what businesses and individuals can do to drive change, titled Modern Slavery in the Cleaning Industry.
Security industry
- A Cleaning Accountability Framework YouTube video featuring experts in modern slavery, labour law, supply chain due diligence, and temporary migrant workers, guiding universities on promoting good labour practices, titled University briefing on cleaning and security compliance.
- An Australasian Centre for Corporate Responsibility report, highlighting how complex labour hire and subcontracting in the security industry have led to widespread non-compliance with workplace laws, including modern slavery, titled Review of Victoria’s Private Security Industry.
Freight/Supply chain industry
- Presented by Chris Caskey and Rod Pickette, a YouTube video looking at how modern slavery occurs at sea and ways cargo owners can mitigate these risks, titled Bite Sized Learning: Modern Slavery Within Maritime Shipping Supply Chains.
- A Walk Free report on forced labour in the fishing industry, highlighting economic pressures and regulatory gaps that exploit fishers, particularly migrants. The report reviews technological and legal measures used to improve labour conditions and recommends actions to take to combat forced labour at sea and is titled Charting Progress Against Forced Labour at Sea.
Content reviewed: September 2024