This year marks UNSW Sydney’s first year reporting on its obligations to the Modern Slavery Act 2018.
Modern slavery is a term used to describe practices such as forced labour, human trafficking, child labour and other severely exploitative practices which typically involve the use of coercion, deception or deprivation of liberty. It is estimated that modern slavery affects over 40 million people worldwide and can be involved in the supply chains which bring everyday items to our homes and businesses.
“Modern slavery is prevalent in both domestic and global supply chains. UNSW has an important role to play to work with its suppliers to identify and address this issue to ensure that workers around the world are not exploited,” Professor Justine Nolan from UNSW Law said.
In recognition of the significance of modern slavery risks and the need to address them, the Federal Government introduced the Modern Slavery Act 2018 (the Act). The Act requires entities with an annual consolidated revenue of more than $100 million to annually publish a ‘Modern Slavery Statement’, reporting on the modern slavery risks within their operations and supply chains, and the actions being taken to address such risks.
Deputy Vice-Chancellor, Equity, Diversity and Inclusion (DVC EDI), Professor Eileen Baldry recounts her experience and astonishment over modern slavery in this age:
“Some years ago, I visited the Slavery Museum in Liverpool, England. Until then I had known intellectually about slavery, but that visit made real the unimaginably terrible inhumane experiences and conditions slaves endured and highlighted the profit made by British and American slave traders and owners. How can it be that almost 200 years after it was ‘abolished’, unscrupulous slave traders still exist and hold other human beings in servitude; and how can it be that people like me can unknowingly buy things produced by slaves? This abhorrent trade must cease, and UNSW must do all in its power to contribute to its end.”
UNSW has identified and prioritised risk areas in order to implement actions to identify, prevent, minimise and remediate risks. UNSW is committed to ensuring a strong response to modern slavery, including the following:
- UNSW operations and supply chains do not cause, involve or contribute to modern slavery; and
- UNSW suppliers, collaborators and others with whom UNSW does business, respect and share the University’s commitment to minimising the risk of modern slavery.
The Strategic Procurement team within the Division of Finance is responsible for addressing the key risks within the UNSW supply chain by collaboratively working with UNSW suppliers. The University is also a member of the Australian Procurement University Network (AUPN), comprising 23 universities.
The UNSW Legal and Compliance Office, with expert assistance from UNSW Law Professor Justine Nolan, has been reviewing contract wording, creating the UNSW Combatting Modern Slavery Policy and training materials for staff. The Legal Office also established and leads a Modern Slavery Working Group which includes representatives from across the University.
What are UNSW’s obligations to comply with the Act?
- The UNSW Combatting Modern Slavery Policy has been drafted and, subject to Management Board approval, will be available for comment through the consultation process run by Governance.
- University Compliance Owners are being selected to manage obligations imposed by the Act to ensure the University develops and implements sufficient internal controls to undertake supplier due diligence, modern slavery risk identification, remediation plans for identified risks, and a process for continual evaluation and improvement.
- Champions, led by the DVC EDI, will work across the University to instil modern slavery awareness in staff.
- UNSW’s first Supplier Charter will be launched. The Supplier Charter will clearly set out the University’s expectations of its suppliers and its commitment to work collaboratively with them in identifying modern slavery risks.
- Creating a Sustainable Procurement Framework and Modern Slavery Focus Plan. These set out a governance structure and identify a pipeline of activities planned for 2020 (to be reported on in UNSW’s first Modern Slavery Statement in 2021).
- Developing a clear list of supply chain risks based on output analysis conducted by Action Sustainability and work done by the AUPN, considering sector wide category and supplier risk.
- Collaborating with the Council of Australian University Directors of Information Technology (CAUDIT) to establish template supply contracts that will allow the monitoring and protection of workers’ rights within information technology and electronics supply chains.
- Ensuring there are accessible mechanisms to report modern slavery risks through UNSW’s existing complaint handling processes.
Further information and training
Over the next few months, the Strategic Procurement team at UNSW will launch an intranet page which provides useful materials to raise awareness about modern slavery. Templates and toolkits will be made available to assist UNSW staff engage with suppliers on monitoring and reporting on modern slavery risks.
If you would like to be part of UNSW’s response to addressing modern slavery, or if you have any questions, we would love to hear from you at modernslavery@groups.unsw.edu.au
UNSW’s first Modern Slavery Statement is due 30 June 2021.
‘Introduction to Modern Slavery’ training will be presented by Elizabeth Grinston (UNSW General Counsel) and Professor Justine Nolan (UNSW Law) on Tuesday 27 October 2020. The UniWide training is available to all staff and will be released for enrolment on UniWide and the HR Learning and Development site soon.
For more information click here.