The term modern slavery is used to describe situations where coercion, threats or deception are used to exploit victims and undermine or deprive them of their freedom. Modern slavery is only used to describe serious exploitation. It does not include practises like substandard working conditions or underpayment of workers.
Modern slavery includes eight types of serious exploitation: trafficking in persons; slavery; servitude; forced marriage; forced labour; debt bondage; deceptive recruiting for labour services; and child labour.
The Act requires the University to prepare an annual modern slavery statement explaining how the University is assessing and addressing modern slavery risks in its operations and supply chains.
The University's modern slavery compliance program has established new obligations that are embedded in all supplier engagement, sourcing and management activities going forward.
Local areas need to ensure that they adequately plan their supplier relationship management activities and new sourcing events to accommodate any additional steps required to comply with the University's modern slavery compliance program. This includes the identification, assessment, mitigation and monitoring of modern slavery risks identified in their supply chains.
Reporting entities are required to submit a statement on an annual basis within six months of the end of each reporting period. For the University, this will be no later then 30 June each year.
Individual areas will be required to manage modern slavery at a local level and maintain up to date records on any risks identified, how they've been addressed and the effectiveness of any action.
On an annual basis, the Finance Unit will coordinate the aggregation of local activities and consolidate the information into a draft modern slavery statement. The statement will be prepared and submitted for review through the University's governance structure.
The statement will be reviewed and endorsed by the University's Governance & Nominations Committee before going to Council for approval and will then be signed by the Vice Chancellor.
All statements are submitted to and published on the Modern Slavery Register at https://modernslaveryregister.gov.au/
A dedicated supplier questionnaire has been prepared for local areas, or the Finance Unit on their behalf, to send to suppliers. The responses to the questionnaire are required to be assessed and any modern slavery risks identified need to be appropriately considered and addressed.
As it is not practicable to assess over 10,000 active vendors, the University will prioritise suppliers using a risk-based approach based on the overall spend, or the prevalence of modern slavery in the origin (source country), sector or type of product or service being procured.
In addition to surveying existing suppliers, all new sourcing events need to consider the modern slavery risks associated with the source country/ies, sector or type of product or service being procured. Local areas are required to include specific modern slavery questions in their evaluation and ensure that appropriate contractual terms, commensurate with the identified risks, are included in contracts with new suppliers.
should something about the FRDM tool be added in regards to how we will be contacting all existing suppliers?
Outside of any agreed contracts, we cannot compel an existing supplier to respond to our questions. However, it is not in their long term interest to refuse to co-operate with the University. It is also highly unlikely that they will not already have been approached by other customers whose reporting periods pre-date the University’s reporting period. If necessary, ongoing refusal by a supplier to complete the questionnaire should be notified to the Chief Financial Officer and noted in the local area's records.
Instances or suspicions of modern slavery in UniSA’s supply chains must be notified to the Chief Financial Officer.
First and foremost, we have and enforce an effective compliance framework. We use that framework to demonstrate the University’s standards and expectations. However, we do not necessarily terminate contracts or relationships. We cannot eliminate modern slavery if we do not have relationships to leverage. Therefore we would look to work with suppliers to understand what action they themselves are taking to mitigate the risks and how they are going to monitor them. We will ourselves need to review that mitigation and follow-up on its perceived effectiveness. We will want to know what action the supplier has taken to ameliorate (i.e. improve) any instances of modern slavery and, in some circumstances and in accordance with the United Nations Guiding Principles on Human Rights, we may even look for intent to remediate the impact of modern slavery.