As required, 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, hospitality, cleaning services and conflict minerals used in electronics. The measures taken to manage risks and potential risk in these areas are identified below. Additional areas of focus have been identified and are in the process of review.
Garments and apparel
Monash University requests 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. Monash is also looking into another exciting initiative in this area.
Computers and electronic equipment – including related conflict minerals
Monash has engaged one of its 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 supply chains.
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 its primary supplier, Monash considers this industry to be of particular risk and will assess, during its forthcoming modern slavery program of work, additional measures to support heightened awareness and transparency of suppliers within this supply chain, with a focus on suppliers other than the primary supplier.
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 AUPN has also discussed alternative remediation techniques that could have been used, instead of simply ceasing to use the subcontractor in question.
In Australia, Monash engages its cleaning staff via well known third-party labour 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 particular area of potential modern slavery risk. Though there is no evidence to indicate any issues, as part of its ongoing modern slavery program of work, Monash will undertake a deeper assessment of the industry due to the inherent risk in the wider cleaning industry, and, to ensure a best-in-class approach, may implement changes to further reduce risk in this area such as participation in the Cleaning Accountability Framework.