Downer has developed a plan, overseen by a multi-disciplinary steering group reporting to Downer’s Board, to revise and strengthen our sustainable procurement management framework and incorporate modern slavery requirements.
We have identified the key areas where the Commonwealth’s Modern Slavery Act 2018 and the NSW Modern Slavery Act 2018 may impact Downer, undertaken a gap analysis of our processes, and undertaken high level risk assessments of our workforce and supply chains. From this we have determined that our greatest risk exposure is within our supply chain, but it is focused in our lower spend categories.
Ensuring that slavery and human trafficking is not taking place in Downer’s supply chain, beyond our direct suppliers, remains a challenge. However, we are implementing a risk-based approach and are committed to continuous improvement through the above measures, including engaging with our direct suppliers to educate, assess and encourage continuous improvement in their own capacity to manage modern slavery risks in their subcontractors and broader supply chain.
Downer is a founding member of the Australian Supply Chain Sustainability School, which is an online collaborative library of information on sustainable procurement topics and best practice. We make this resource tool available to our subcontractors and suppliers.
Additionally, Downer has reviewed our own labour practices and supply chain through updates to our existing frameworks, policies and processes to take into consideration modern slavery, in accordance with the Commonwealth’s legislation. Downer welcomes the opportunity to produce its Modern Slavery Statement (prior to 31 March 2021) in accordance with its obligations to report under the legislation. Downer had planned to release its Modern Slavery Statement prior to 31 December 2020; however, the release has been moved back after Home Affairs extended the submission deadline to 31 March 2021 due to the COVID-19 pandemic.
We are taking steps to strengthen our supplier onboarding and monitoring processes to highlight modern slavery risk areas. The processes that we will implement include education of our supply chain to ensure these risks are adequately managed. Where suppliers are found to be non-compliant with our Standards of Business Conduct and contract terms requiring those suppliers to carry out remedial action, we will assist them to improve their processes.