Addressing risks

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 material spend that have been identified as high-risk include apparel, electronics, cleaning, hospitality services, and security. The measures taken to manage known and potential risks in these areas are identified below.

Raw cotton in handsGarments and apparel

We have formed an Apparel panel with pre-approved suppliers. These suppliers have completed a modern slavery questionnaire in addition to a Capability Uplift Plan that addresses any identitifed shortcomings in their questionnaire responses.

Hands holding mineral rockComputers and electronic equipment – including related conflict minerals

We continue working with our affiliate to drive considerable transparency into our electronics supply chain. This has enabled us to identify a variety of work sites with risks or violations related to modern slavery. This information helps guide engagement and remediation efforts.

Cleaner cleaning floorCleaning and security services

Cleaning and security were both addressed by tenders that took into account modern slavery risk during the planning phase. This included specific approaches to increase transparency, and maintaining ongoing transparency and compliance. Cleaning agreements include productivity maximums to prevent over work.