Compliance Framework
Compliance Driver
Modern Slavery Act 2018 (Cth)
Classification
Level 1
University-wide concern. Impacts on reputation and funding.
Associated Legislation
Associated Standards
None
Associated Codes
None
Associated Information
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Administrative Information
Administrative Body
Department of Home Affairs
Administrative Name
Ms Stephanie Foster, Secretary Department Home Affairs
Administrative Address
Administrative Phone
Administrative Email
Administrative Website
https://www.homeaffairs.gov.au/
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General Introduction
VC Compliance Delegate
Karma Auden, Chief Financial Officer
Compliance Coordinator
Fiona Harrison, Head Strategic Procurement
Business Units Impacted
Overview
This Act requires entities based, or operating, in Australia, which have an annual consolidated revenue of more than $100 million, to report annually on the risks of modern slavery in their operations and supply chains, and actions to address those risks. Other entities based, or operating, in Australia may report voluntarily.
The Commonwealth is required to report on behalf of non-corporate Commonwealth entities, and the reporting requirements also apply to Commonwealth corporate entities and companies with an annual consolidated revenue of more than $100 million.
Reports are kept by the Minister in a public repository known as the Modern Slavery Statements Register. Statements on the register may be accessed by the public, free of charge, on the internet.Compliance Obligations
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Identify, describe and control Modern Slavery risk within UNE’s supply chain
Description
UNE as an Australian entity with >$100m revenue, is required to identify areas of potential exposure to modern slavery practices, in engagement of contractors/labour and in other parts of its supply chain. Risk of exposure is increased when sourcing goods or suppliers from some countries in the Asia Pacific region and may be higher when operations are conducted overseas.
- Undertake a periodic (at least annual) overall assessment of the supply chain to determine the risk of suppliers and contractors and their supply chains engaging in practices which support Modern Slavery.
- Review individual suppliers for Modern Slavery Risk during procurement and contract extension processes.
- Ensure agreement templates require supplier assurance regarding their supply chains being low risk of supporting modern slavery practice.
- Establish controls (contract terms, supplier credential checking etc) to help reduce modern slavery related risk.
- Identify potential suppliers who might be at risk of Modern Slavery practices on a register to avoid engaging them or there subsidiaries.
Guidance regarding risk assessment of supply chains is available via the Home Affairs website.
Where risk of Modern Slavery practice exists, make recommendations for changes to practice and alternative suppliers and action approved changes.
Impacts
Responsible Manager
Fiona Harrison, Head Strategic Procurement
Coordinating Officer
Fiona Harrison, Head Strategic Procurement
Coordinating Unit
Procurement
Oversight Committee/Group
Audit and Risk Committee
Business Units Impacted
Obligation Framework
Associated Legislation
None
Associated Standard
None
Associated Code
None
Associated Information
None
Management Tools
Rule
None
Policy
Procurement Policy
Protocol
None
Procedure
None
Guideline
None
Other Websites
Modern Slavery Reporting Entity Guidelines
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Modern Slavery Statement
Description
The University is obligated to provide an annual statement regarding its practice and activities to control the risk of modern slavery practice in its organisation by or before 30 June of the year following the 'reporting period'.
The Statement should be consistent with the Guidelines for Reporting Entities issued by the Department of Home Affairs.
Impacts
Responsible Manager
Radha Thomas, Director Governance and University Secretary
Coordinating Officer
Alicia Zikan, Head Records Policy and Governance
Coordinating Unit
Office of the Director Governance and University Secretary
Oversight Committee/Group
Audit and Risk Committee
Business Units Impacted
Obligation Framework
Associated Legislation
None
Associated Standard
None
Associated Code
None
Associated Information
None
Management Tools
Rule
None
Policy
None
Protocol
None
Procedure
None
Guideline
None
Other Websites
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Review UNE Controlled Entity Risk relating to Modern Slavery Practices
Description
UNE is responsible for reporting on the risk of the UNE Group, including the potential exposure to modern slavery risks of its Controlled Entities.
UNE to request at least annually that each of its Controlled Entities provide an outline of how they managing Modern Slavery risks in their supply chains – including in employment practices; in contracts, in investment practices, assessment of ethics of suppliers during procurement of goods and services, and in other areas of operational which may give rise to such risks.
Impacts
Responsible Manager
Ilias Dimopoulos, Head of Finance
Coordinating Officer
Kim Lawrence, Company Secretary (Controlled Entities)
Coordinating Unit
Office of the Chief Financial Officer
Oversight Committee/Group
Audit and Risk Committee
Business Units Impacted
Obligation Framework
Associated Legislation
None
Associated Standard
None
Associated Code
None
Associated Information
None
Management Tools
Rule
Controlled Entity Rule and Guidelines
Policy
None
Protocol
None
Procedure
None
Guideline
None
Other Websites
Compliance Overview