Modern Slavery Act Report

Combating modern slavery

We are committed to a future without labour exploitation and rights violations in the form of modern slavery. This hidden, large-scale exploitation within our community often harms those least able to defend themselves.

Awareness

An online modern slavery training module is available to all staff, to help them understand the issue, identify warning signs, and take extra care when buying. We are also embedding modern slavery risk mitigation and due diligence measures in relevant procurement templates, policies and procedures to support staff in addressing local level risks and issues.
Supply chain

We are taking a data-driven, risk based approach to focus our efforts on high-risk products, services and investments. This approach includes collaborating with third parties who have deep expertise in workers’ rights protection in specific industries, to improve the transparency of these high-risk areas.
Risk assessments

We’re enhancing the geographic and industry-based risk assessment processes used to assess our suppliers.
Rigorous processes

Our tendering documents and template agreements are being updated to include not only modern slavery, but a number of other sustainable procurement initiatives.
Focused policies

We will be updating relevant policies and procedures to include reference to modern slavery and associated legislation.
Preferred suppliers

Our staff are encouraged to work with Monash University-preferred providers and organisations with their own Modern Slavery Statements.

Podcast: Swipe Right for Slavery

Approximately 40 million people worldwide are enslaved in some way. And if you believe your hands are clean, you’re wrong. Listen to the What Happens Next? podcast on modern slavery.

Our approach

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.

2021
2022
2023
2024
2025

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.

New supplier onboarding
Template wording
Simplified questionnaires
Risk assessments

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.

Glove manufacturing

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.

Cleaning services

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.

Modern Slavery Act Report