Modern Slavery Act Report
Five-year plan View
We have a five-year plan to address modern slavery risks within our global, complex, operations and supply chain – with a clearly defined governance structure supported by an expert advisory panel. We recognise that as this plan is implemented, it needs to remain responsive to new lessons and dynamic in execution. We continue to learn, adjust and improve our plan. Like many other companies and institutions, our understanding of modern slavery, and this five-year plan, will continue to evolve, develop and grow.
- Supporting procurement systems and processes
- Basic tracking system
- Internal risk assessments
- Initial risk assessments
- Compliance monitoring
- Onshore and offshore training
- Advanced tracking system
- Industry deep-dive
- Agreement and sourcing templates update
- Assessment of new risks
- Operational framework
- Compliance monitoring
- Commence onboarding of offshore wholly controlled entities
- Training program review
- Expanded compliance monitoring
- Offshore agreement and sourcing templates update
- Implementation of operational framework
- Expand offshore training rollout
- Identify risks in onshore research and education activities
- Commence onboarding of offshore partially controlled entities
- Continuous improvement for onshore entities
- Continue to expand offshore training
- Offshore research and education
- Continuous improvement
- Program review
Working with our suppliers View
We recognise that we cannot do this alone – it requires accountability and a sustained effort in conjunction with our suppliers, partners and the wider Monash University community.
Our suppliers vary from common goods and services to some of the most specialised suppliers worldwide that support our leading research projects. We also undertake research in a multitude of remote areas across the world.
After a thorough consultation process with key suppliers and stakeholders throughout the University, we are now implementing the following actions to assess and address operational and supply risks.
All new suppliers must confirm they are compliant with relevant modern slavery requirements as part of our supplier onboarding process. They are not able to be paid until they have completed this process, including electronically confirming they are compliant with all relevant obligations. A failure to confirm compliance stops the onboarding process and initiates manual intervention and review.
A robust framework of template wording has been created for implementation in key formal template agreements (where Monash is procuring goods or services). These are being continuously improved as our program of work progresses. In addition, we provide comprehensive written responses to all queries from third parties seeking to clarify the Monash component of their supply chain or as part of sponsorship and funding applications.
Recognising the wide diversity of our global supply chain, an additional supplier questionnaire has been created. This includes clear expressions of requirements and guided steps in English. This is used in conjunction with dialogue to achieve an understanding of the supplier’s practice and culture and to identify the best way to work in partnership with suppliers, beginning with directly-engaged suppliers.
Using a combination of reliable resources including those from the Department of Home Affairs, Global Slavery Index, International Labour Organisation, industry and academic expertise, we have identified areas within our supply chain that are considered to be of high risk. Our new technology solution for 2022 will seek to delve deeper into our supply chain to enhance risk assessment. We use the risk assessment outcomes to prioritise actions against each high-risk area.
Actions to address risks View
A suite of methods is used to delve into high-risk areas, including, but not limited to:
- ‘deep-dive’-type analyses
- bespoke supplier assessments
- engagement of third-party consultants or agents who specialise in industry best-practice, to provide reports which may include them undertaking them onshore or offshore site visits or staff discussions, as required
- tabling concerns through the Modern Slavery Steering Committee governance structure for guidance on targeted actions and effectiveness measures.
Current areas of spend that have been identified as high risk include apparel, fish, rice, cocoa, electronics, cleaning & hospitality services and conflict minerals used in electronics. The measures taken to manage known and potential risks in these areas are identified below.
Garments and apparel
We request information from suppliers to identify those that may not be in compliance with their legal obligations such as the Fair Work Act 2009, and encourages suppliers and/or their supply chain to comply with industry codes such as Ethical Clothing Australia, Better Cotton Initiative and Fairtrade.
Computers and electronic equipment – including related conflict minerals
We have engaged one of our key computer suppliers, and review its approach addressing risks of modern slavery in its supply chain. The supplier was found to be well-advanced in this area.
The supplier has a clear and well-known zero-tolerance approach to modern slavery in its supply chain and is a founding member of the Responsible Business Alliance, a leading global alliance aimed at improved corporate social responsibility within a supply chain.
The supplier publishes a Conflict Minerals Report detailing its efforts to purchase processed goods from non-conflict sources, as it has a heavy dependence on third-party manufactured components made from refined, mined minerals.
Though satisfied with the actions of our primary supplier, we understand from our research the computer equipment industry is inherently high-risk, particularly at the raw material extraction and assembly stages.
In 2022, we commenced an affiliation with an international labour rights monitoring organisation, Electronics Watch, to delve deep into the supply chain of the key computer equipment we purchase. The affiliation will increase supply chain transparency across our key products and strengthens our efforts to influence change.
Monash University, in conjunction with the Australian University Procurement Network (AUPN), identified an instance of modern slavery within its supply chain for latex gloves. The following actions were identified as likely being implemented by a recruiting company that was a third party providing labour supply services to an offshore subcontractor to a Monash supplier:
- Deceptive recruiting practices
- High recruitment fees
- Passport withholding
- Forced salary deductions
- Forced overtime
- Substandard living conditions.
The subcontractor took steps to provide financial reparation to the affected migrant unskilled workers and to ensure passports were accessible, and also terminated use of the recruiting company. In addition, Monash’s direct supplier ceased utilising the subcontractor in question.
The outcome of this globally significant issue continues to be monitored as it progresses and has been the subject of global media coverage. Sources monitored include the supplier’s published continuous improvement report.
The supplier’s due diligence of recruiting agencies has been improved including ensuring they comply with SEDEX Members Ethical Trade Audit (SMETA) or the Business Social Compliance Initiative (BSCI) Code of Conduct.
This supplier and the entire glove manufacturing industry continues to be monitored as a high-risk supply chain.
In Australia, we engage our cleaning staff via well known third-party service providers that are only engaged after a robust tendering process. Terms and conditions are made binding via comprehensive formal agreements. Further subcontracting of the work is only permitted with the approval of Monash University.
Despite these measures, Monash has identified this to be a high risk. Though there is no evidence to indicate any issues, as part of its ongoing modern slavery program of work, we will undertake a deeper assessment of this area due to the inherent risk in the wider cleaning industry. To step up our effort, we will introduce modern slavery due dilligence measures in our cleaning tenders. We are also reviewing the participation in the Cleaning Accountability Framework.
Continuously reviewing and improving our actions View
The effectiveness of our actions can be assessed at different levels. In subsequent years of our five-year modern slavery program, we will undertake a robust assessment of the effectiveness of our actions including:
- Internal compliance checks, with checklists designed in conjunction with our academic experts. Examples already identified include:
- confirming the use of the correct contract and RFT templates containing the latest modern slavery terms
- the supplier onboarding gate being effectively in place
- training completion rate by key staff
- supplier questionnaires
- documentation of all high-risk areas and their status through to completion
- External sector engagement, such as via the AUPN, to assess cross-university effectiveness, combined supplier influence and compare sector performance with Monash.
- External stakeholder engagement to continue the dialogue with third parties in relation to risk identification and strategising in relation to identified risk.
- Affected labourers identified as being subject to modern slavery practices – how they are progressing after remediation steps have been taken. This is a longer-term goal.
- Where appropriate, the use of third-party partners or auditors to check on suppliers and factories – including offshore - to check that real and meaningful progress has been made and remains in effect.
Empowering our community View
Staff and students can learn more about modern slavery, including how to identify key indicators of its presence, by logging into MyDevelopment and completing the modern slavery training module.
Staff can access the training module here (once logged in). Students can search for the module by accessing MyDevelopment through the "Research" tile on my.monash.