MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS NOVEMBER 2019 ABOUT This guide was prepared by the Australian Council of Superannuation Investors (ACSI) and the Responsible Investment Association Australasia (RIAA) ACSI provides a strong, collective voice on Contributors environmental, social and governance (ESG) issues on behalf of 39 Australian and international asset owners ACSI and RIAA would like to thank the following people and institutional investors. Collectively, they manage and organisations who have contributed to this guide. over $2.2 trillion in assets and own on average 10 per Primary Authors cent of every ASX200 company. Through research, engagement, advocacy and voting advice, ACSI §§ Ausbil Investment Management Limited: Måns supports members in exercising active ownership — Carlsson-Sweeny (Head of ESG Research) strengthening investment outcomes. §§ ACSI: Kate Griffiths (Executive Manager, Public Policy Active ownership allows institutional investors to and Advocacy), Ian McIlwraith (Governance and enhance the long-term value of savings entrusted to Engagement Analyst) them. Working collectively, ACSI members can achieve Working Group material outcomes for their beneficiaries and deliver genuine and permanent improvements to the ESG §§ Ausbil Investment Management Limited: Nicholas practices of the companies in which they invest. Varcoe (ESG Analyst) §§ Australian Super: Sandra Silea (Analyst, ESG and RIAA champions responsible investing and a sustainable Stewardship) financial system in Australia and New Zealand. RIAA is dedicated to ensuring capital is aligned with achieving a §§ KPMG Australia: Dr Meg Brodie (Director, Human healthy society, environment and economy. Rights Service Line Lead) §§ Mercer Investments (Australia) Limited: Timothy With over 260 members managing more than $9 trillion Stamp (Senior Associate, Responsible Investment) in assets globally, RIAA is the largest and most active network of people and organisations engaged in §§ National Australia Bank: Rosemary Bissett (Head of responsible, ethical and impact investing across Sustainability Governance and Risk) Australia and New Zealand. RIAA membership includes §§ QIC: Kate Bromley (Head of Responsible Investment) super funds, fund managers, banks, consultants, researchers, brokers, impact investors, property §§ Responsible Investment Association Australasia: managers, trusts, foundations, faith-based groups, Nicolette Boele (Executive Manager) financial advisers and individuals. §§ Solaris Investment Management Limited: Lisa Domagala (ESG Analyst) §§ Action Sustainability Asia Pacific Pty Ltd : Mark Lyster (Managing Director) Reviewers §§ PRI: Bettina Reinboth (Head of Social Issues) §§ FSC: ESG Working Group Members ACSI and RIAA would like to acknowledge and express their gratitude for the helpful insight and comments from Mark Bland and Luke Geary of Mills Oakley. 1 MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 INTRODUCTION This guide has been prepared by ACSI and RIAA to In addition, the New South Wales government passed provide a framework for investor reporting. It provides modern slavery legislation in 20181, which is based on broad context on matters investors may wish to consider similar reporting requirements as the Commonwealth Act in preparing their modern slavery statements and should but with a different threshold: annual turnover of at least be used in conjunction with the guidance provided by $50 million and at least one employee in NSW. Non- the Australian Border Force (Government Guidance). compliance with the NSW Act can result in fines. This While both supply chains and investments are addressed guide does not address the NSW Act. in this guide, it has been prepared primarily to provide additional information for investors on how they might address their investment activity in their modern slavery statements. This guide offers suggested approaches, and Message from the Modern Slavery Business it is acknowledged that there could be other, equally Engagement Unit, Australian Border Force: appropriate ways to prepare modern slavery statements. Modern slavery can occur in every industry and The Act is focussed on transparency, aiming to inform sector and has severe consequences for victims. external stakeholders what reporting entities do to Investors can play a vital role in combating modern mitigate the risk of slavery and to encourage a ‘race slavery, such as by addressing modern slavery risks to the top amongst businesses competing for market in their investment portfolios. The Australian Border funding and reputational reward’. Of course, investors Force welcomes multi-stakeholder collaboration will want to comply with the Act and they will need to within and across high risk industries and sectors seek advice from an appropriately qualified professional to provide guidance on implementing the Modern in this respect. In addition to mere compliance, this Slavery Act, including to develop tools and resources guide encourages investors to consider how they can to support compliance. This best-practice guidance develop their capacity to identify, manage, address complements the Australian Government’s official and remediate modern slavery risks and impacts. The guidance and will support investors to meet their exercise will be significant and needs to be appropriately obligations under the Modern Slavery Act. We staged over time. Reducing the risk of modern slavery (or encourage investors to read and apply this guidance eradication of modern slavery as per the UN Sustainable to develop their capacity to identify, manage and Development Goals) will be a lengthy and iterative remediate modern slavery risks and impacts. process where investors can play a role. Ultimately, it is up to each reporting entity to decide how it reports (subject to addressing the mandatory criteria). ACSI and RIAA’s guide is not legal advice and should not be relied upon as such. Each entity should seek its own legal advice on their obligations under the Act from appropriately qualified professionals. In addition, this guide does not address the obligations entities, directors or trustees might need to take into account under applicable laws. Although the Act sets out remediation processes for reporting, given the nature of remediation, it is outwith the scope of this guide. 1 https://www.parliament.nsw.gov.au/bills/Pages/bill-details.aspx?pk=3488 MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 2 BACKGROUND The Commonwealth Modern Slavery Act 2018 (Act) was 5. Describe how the reporting entity assesses the passed by the Australian Parliament on 29 November effectiveness of such actions (section 16(1)(e)); 2018 and entered into force on 1 January 2019. The first reporting period is the first period following 1 July 2019. 6. Describe the process of consultation with: For most entities, this will be 1 July 2019 to 30 June a. Any entities that the reporting entity owns 2020, with the first modern slavery statements due on or controls; 31 December 2020 (or 30 June 2021 for reporting b. In the case of a joint statement, entities giving entities with a calendar year financial year). the statement (section 16(1)(f)); The Act reporting threshold requires entities based, or 7. Include any other information that the reporting operating, in Australia which have an annual consolidated entity considers relevant (section 16(1)(g)); and revenue of more than $100 million to report annually on modern slavery. Other entities based or operating in 8. Provide detail on approval of the statement Australia may report voluntarily. (section 16(2)). These entities must report on the risks of modern slavery Where an entity does not comply with the requirement in their operations and supply chains, the actions taken to to provide a modern slavery statement, the Minister may assess and address those risks, and how they address the request an explanation and/or require remedial action effectiveness of those actions. The Act defines modern (essentially asking the entity to comply). Where non- slavery to include eight types of serious exploitation — compliance continues, the Minister can publish the name trafficking in persons, slavery, servitude, forced marriage, of the non-compliant entity and details about its dealings forced labour, debt bondage, deceptive recruiting for with the entity in relation to explanations and remedial labour or services and the worst forms of child labour action sought. (situations where children are subjected to slavery or similar practices, or engaged in hazardous work). The Act contains a reporting requirement, as opposed to, for example prescribing particular action to address Reports will be made public via an online database. modern slavery risk. While the Act sets out certain criteria that need to be included in a modern slavery The Act sets out mandatory criteria for modern slavery statement, the guidance is broad, and allows flexibility statements. A modern slavery statement must: for entities to take an approach that is appropriate for them. The Government expects that reporting 1. Identify the entity that is reporting (section 16(1)(a)); entities’ statements will improve in quality and demonstrate progress over time as entities increase their 2. Describe the structure, operations and supply chains understanding of modern slavery. In terms of investment of the reporting entity (section 16(1)(b)); activity, Government Guidance provides that investment activity would form part of modern slavery reports. This, 3. Describe the risks of modern slavery practices in the combined with the fact that the Act specifies mandatory operations and supply chains of the reporting entity, reporting elements, makes the Act relatively unique in an and any entities that the reporting entity owns or international comparison. controls (section 16(1)(c)); The Government Guidance provides that internally 4. Describe the actions taken by the reporting entity managed investment activity may be considered part of (and owned or controlled entities) to assess and ‘operations’ and externally managed investment activity address those risks, including due diligence and part of ‘supply chains’. Given the requirement to report remediation processes (section 16(1)(d)); on the risks of modern slavery in both operations and supply chains, this distinction is relevant only in providing context for the action to address the risk (see sections 2 and 3 below for further information). 3 MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 The Act builds on the UK Modern Slavery Act, which was How the reporting entity might be affected by enacted in 2015. However, in the UK there are very few reputational risk or financial risk is a secondary issue that, precedents when it comes to reporting on investment while important to investors (and will often intersect with activities and portfolios. In addition, the Government risk to people), is not part of the mandatory criteria. Guidance is intentionally broad, to allow entities to adopt the approach most appropriate to them. Risk-based approach refers to prioritising the risks for focus by a reporting entity, which again, is based Definitions2 on risks to people. Where there is significant risk to people, investors may wish to consider where they can Due diligence refers to taking steps within the business be most effective, which may include where they have to look for the human rights risk (in this case modern most leverage. slavery risk) to people and taking appropriate steps to manage those risks. Due diligence captures modern Operations and supply chains: please see ‘Describe slavery risk assessment and associated risk controls. the structure, operations and supply chains of the reporting entity’. Risk - the concept of ‘risk’ refers to the risk to people, rather than risk to the entity itself. In other words, for investors reporting on the risk of modern slavery in portfolios and taking a risk-based approach on engagements, this does not relate to risk to a portfolio or risk to the business, but risk to people. This relates to severity of modern slavery practices, likelihood of them occurring as well as the extent of the risk in terms of the number of people affected and over what time period, etc. 2 These are not legal definitions but definitions for the purpose of this guide MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 4 MODERN SLAVERY STATEMENTS – MANDATORY REQUIREMENTS The Act specifies that modern slavery statements must Practical Tips include certain information. Each mandatory reporting requirement is set out below, with a summary of the  his is a straightforward requirement, and it is reasonable T Government Guidance, generally followed by some to suggest that entities would include reporting entities practical observations and a hypothetical example. in their modern slavery statements in a similar way to While each mandatory requirement is separated below, how they are set out in annual reports, websites or other in practice they will be interlinked and each element of public documents. Consider whether any subsidiaries an entity’s modern slavery statement can build on the meet the reporting threshold, (or, separately, the lower previous. Therefore, it may not be necessary for modern threshold set out in the NSW Act) and whether it is slavery statements to adopt the same format as this appropriate and efficient to prepare a joint modern guide (i.e. separating each reporting requirement). Rather, slavery statement (see also section 6 on joint statements). information may be better presented as a whole. In any Government Guidance indicates that reporting entities event, a modern slavery statement should reflect each should also describe how risks of modern slavery entity’s own operations and supply chains, and entities practices may be present in the operations and supply should cross-check that their modern slavery statements chains of entities that are controlled by a reporting entity. contain each of the mandatory elements, seeking appropriate legal advice. Hypothetical Example 1. IDENTIFY THE ENTITY THAT IS REPORTING  his modern slavery statement is prepared and issued T Government Guidance by Huge and Sustainable Returns Super Limited as Trustee of Huge and Sustainable Returns Super. This  learly identify the reporting entity covered by the C modern slavery statement also includes reporting from modern slavery statement. This might include the name Huge and Sustainable Returns Management Limited, as of the entity, logos, and logos of any relevant brands or administrator of Huge and Sustainable Returns Super divisions. It might also include the registered address, which is also a reporting entity. Huge and Sustainable where the entity is incorporated and an Australian Returns Super Limited and Huge and Sustainable Returns Company Number. Management Limited are referred to throughout the document as ‘HSR Super’ or the ‘Fund’, ‘We’, ‘us’ or ‘Our’.  (See also section 2 in relation to how subsidiaries that do not meet the reporting threshold might be included.) 5 MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 2. DESCRIBE THE STRUCTURE, OPERATIONS AND SUPPLY CHAINS OF THE REPORTING ENTITY Government Guidance  he Government Guidance asks entities to describe three aspects, being structure, operations and supply chains. The table T below provides a summary. STRUCTURE, OPERATIONS AND SUPPLY CHAINS Structure §§ The general structure of the entity (e.g. is it a public company, partnership or trust). If the entity is part of a larger group, explain the general structure of the overall group (both upstream and downstream from the entity). §§ Explain whether the entity owns or controls other entities. If so, explain what the subsidiaries do and where they are located. §§ Identify any trading names or brand names associated with the entity and child entities. §§ Provide the entity’s Australian Company Number, registered office or other public identifying information. Operations §§ Explain the nature and types of activities undertaken by the entity and any owned or controlled entities. §§ If the entity’s activities involve investments, explain the type and nature of the entity’s investments. §§ Identify the countries or regions where the entity’s operations (including investments) are located or take place. §§ Provide facts and figures about the entity’s operations, such as the total number of employees. In the context of investments, this could also include total funds under management, asset classes, sectors and number of beneficiaries. §§ Explain in general terms the type of investment activity the entity undertakes. Supply Chains §§ Identify the countries or regions where the entity’s suppliers are located. §§ Explain in general terms the type of arrangements the entity has with its suppliers and the way they are structured (e.g. are they short term and changeable or stable longer term). §§ Explain the main types of goods and services procured by the reporting entity. §§ To the extent possible, identify the source countries for these goods and services. §§ Link to any disclosures by the entity about the identity of their suppliers (such as a public supplier list). MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 6 Given the potential magnitude of this exercise, Practical Tips prioritisation is likely to be necessary to ensure the task is effective and manageable. The Government Guidance Structure and Operations refers to principle 17 of the UN Guiding Principles on The information suggested for disclosure as part of Business and Human Rights (Guiding Principles) which the first two elements in the table above, (‘Structure’ suggests focusing on the general areas where modern and ‘Operations’) might be already available and slavery risks are likely to be most significant. Guiding disclosed. For example, if an investor prepares an Annual Principle 24 also suggests focus on the most severe risks. Report, it is likely that the general structure of the This means those that would cause the greatest harm to group, brand names and trading names are included. people, the greatest impact or where the risks are large It may also be that the nature and type of the entity’s scale (with a significant number of people affected). operations (including investment activity) is broadly Investment Activity described in Annual Reports, investment sections of Product Disclosure Statements, website or other public The Act does not define ‘operations’ however the documents. While modern slavery statements will Government Guidance outlines that investment activity need to stand alone (given the requirement to store in should be included in modern slavery reporting. a separate public database), cross references to other ‘Operations’ refer to activities undertaken by the entity publicly available information may be appropriate. to pursue its business objectives and strategy in Australia or overseas, which includes ‘financial investments’. This Supply chains would include goods and services generally is highlighted in the Government Guidance’s section ‘Key supplied to businesses, including to support operations. terms explained: what do ‘structure’, ‘operations’ and ‘supply Supply teams or accounts payable would usually be chains’ mean’ (page 33), which lists a number of examples able to provide a starting point. Suppliers may include of definitions of ‘operations’. Importantly, each individual outsourced suppliers (such as custodians, investment investment is not expected to be disclosed, rather managers, investment advisers and transition managers), disclosure could be on a thematic level (such as by asset other major providers (such as brokers, clearers, research class, sector and/or geography or industry). providers) and other suppliers (such as professional services firms, usual office suppliers for example The Government Guidance indicates that it is reasonable premises, cleaning, catering). to consider that internally managed portfolios and assets may form part of a reporting entity’s ‘operations’ and It is useful to remember that the mandatory element that externally managed portfolios and assets may be is to ‘describe the structure, operations and supply considered part of a reporting entity’s supply chain. For chains’, and a description can take many forms. Such a example, an asset manager that is managing a portfolio description can be relatively high level. It will however for an asset owner may be considered a service provider be important to demonstrate improvement over time to the asset owner and therefore a tier one ‘supplier’. in both understanding the entity’s operations and supply chain, and in the corresponding disclosure. The However, the assets themselves may, in some Government Guidance notes that the Act does not set circumstances, be better considered to be part of the a minimum requirement for how far down the supply asset owner’s 'operations'. As set out above, entities are chain reporting should cover, and suggests that risks encouraged to look to the substance of their investments anywhere in operations and supply chains should be and investment arrangements. considered. In the context of investments, entities are encouraged to look to the substance of their investments Investment organisations can differ widely in terms of and investment arrangements (including relationships size, coverage, types of financial instruments, passive with fund managers) in assessing the risk of modern investments versus active investments, which may slavery to people, with a focus on the areas of greatest be poorly understood by readers of modern slavery risk, regardless of whether the risk is within operations or statements. For instance, the use of external managers, supply chains. particularly in foreign jurisdictions with a higher risk 7 MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 might have an impact on the risk assessment and actions Hypothetical Example taken to address slavery in the portfolio. Also, explaining (at a thematic level) the type of asset classes and sectors HSR Super’s supply chains include those related to of the economy invested in, the size of the holdings and corporate and operational procurement, such as the nature of those holdings (e.g. majority / minority marketing (branded and unbranded goods not for resale), ownership and typical length of holdings) can add cleaning, travel, catering and information technology. valuable context in considering the action available to address risk and also provides context for the rest of the Given our purpose, we have a large investment portfolio modern slavery statement. for the benefit of our members. Our investment portfolio spans Australian and international equity markets, direct Reporting entities, such as an asset owner, may ask a fund property, infrastructure and private equity investments. manager of an externally managed portfolio to report on We invest in more than 30 countries. We have modern slavery risks both as a supplier themselves and investments across a number of sectors including energy, also in relation to the assets being managed. IT, material, financial services property, healthcare and telecommunications. Further information on our Given the need to report on the risks of modern approach to investing is set out in our Annual Report and slavery in both operations and supply chains and the Product Disclosure Statement. We have mandates with Government Guidance to assess risk deep into supply external investment managers to manage xx% of our chains, the distinction between operations and supply investment activity. chains is generally relevant only in providing context for the action to address the risk. The Government Guidance We have identified areas of greatest risk in our also provides that prioritisation is useful and responses operations and supply chains. Research suggests that will be dependent on the severity of risk and the high risk areas for financial services businesses’ supply relationship of the reporting entity to the risk. chains include IT procurement, logistics and property, and building services such as facilities management, utilities, As with other reporting entities, investors should also report cleaning, waste management and security and print on other parts of their supply chains, such as procurement. and promotional goods. Accordingly, we have focused on these areas. We have also sought to understand geographic and sector risk in relation to our investments. In the first instance we have done this by comparing our investments with geographies or sectors known to be of greater risk. We have focused on our investments in Asia, as research shows that the Asia-Pacific region has the largest concentration of people in slavery-like conditions in the world. Where we have investments in that region, we believe the risk to people may be greater. We have also asked our investment managers to report back to us with the relevant information on our externally managed investments. We will report on our progress annually. MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 8 3. DESCRIBE THE RISKS OF MODERN Scoping to identify general areas of modern slavery risk SLAVERY PRACTICES IN THE OPERATIONS AND SUPPLY CHAINS OF THE REPORTING The Government Guidance asks reporting entities to ENTITY, AND ANY ENTITIES THAT THE identify the general types of modern slavery risks that REPORTING ENTITY OWNS OR CONTROLS may be present in their operations or supply chains. This provision requires only that an entity identify how risks of Government Guidance modern slavery may be present. Most likely, every entity will have modern slavery risks in its operations and supply Risk to people chains. Government Guidance suggests that reporting on individual or specific risks is not required. Nonetheless, it  he Government Guidance focuses on risk as it relates T may be appropriate to include more specific information to people, rather than risks to the entity (such as on a voluntary basis in some circumstances (e.g. a case reputational or financial damage). Risk to the business, in study of action taken may add value). other words, how the reporting entity might be affected by reputational risk or financial risk, is a secondary issue The Government Guidance outlines that a scoping that is not part of the mandatory criteria. Nonetheless, exercise will assist in identifying and describing the risks the risks often intersect and associated reputational and of modern slavery. Scoping involves three steps: financial risk is an important consideration for investors. Risk to people incorporates concepts of severity of 1. Identify the broad operations and overall supply chain modern slavery practices, likelihood of occurrence, as structure of the reporting entity at a thematic level. well as the extent of the effect, in terms of the number of Investment and lending portfolios should be included. people affected and over what time period. This will identify the general sectors and industries, types of products and services, countries and entities The potential for the entity to cause, contribute to, or be that are involved in operations and supply chains. To directly linked to modern slavery through its operations the extent possible, this should consider the entire and supply chains is highlighted in the Government scope of the supply chain. Guidance (which makes reference to the Guiding Principles). A brief summary is set out below: 2. Assess which of the sectors, types of products and services, categories of investments, countries and §§ Cause – a risk that the entity’s operations directly entities identified may involve high modern slavery result in modern slavery practices. risks. Some modern slavery risk indicators are set out in the Government Guidance, which is extracted at §§ Contribute – a risk that the entity’s operations and/ attachment 1. or actions in the supply chains may contribute to modern slavery, including acts or omissions that 3. Identify parts of the entity's operations (including facilitate or incentivise modern slavery. investment portfolios) or supply chains over which there is limited visibility and consider whether they §§ Directly linked – risks that the entity’s operations, may involve modern slavery risks. products or services (including financial products and services) may be connected to modern slavery While the Act does not set a minimum requirement for through the activities of another entity with which how far down the supply chain reporting should cover, the entity has a business relationship. the Government Guidance suggests that risks anywhere in operations and supply chains should be considered, including those deep in supply chains. 9 MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 corruption. Countries where the workforce includes a Practical Tips large number of migrant workers, and where third-party employment agencies are widely used, also present The actions outlined above (in particular, Step 1 of a higher risk of forced labour. Other country factors the scoping exercise) are likely to overlap with the that indicate risk include the existence of Economic requirements described in Section 2 (the description of Processing Zones, which are often not bound by national the entity’s structure, operations, including investments, labour laws and therefore cannot be inspected by labour and supply chains). Therefore, this information could officials; and areas with large agricultural sectors, which already be publicly available, for example in an Annual are often found in isolated rural areas that are difficult to Report, website or similar document. Nonetheless, access and inspect. information should be reviewed to assess how it is fit for the modern slavery statement. Each entity should  IAA’s report ‘Investor toolkit – human rights with focus R consider what is an appropriate level of detail, taking on supply chains’ also highlights key risk areas and also into account its particular circumstances. For example, sheds light on how investors can spot red flags by looking investors with a large number of holdings may wish to at industry structures, such as oligopolistic industries assess and disclose on a thematic level; those with more where the main players compete on price and have concentrated holdings may have the ability to provide a transactional relationships with suppliers, industries with greater level of detail. As mentioned above, investors are high pressure or shorter lead times, supply chains where encouraged to look to the substance of their investments workers are often recruited by an agent and more. It and investment arrangements to assess the risk of also highlights some key underlying issues such as living modern slavery to people, with a focus on the areas of wages, freedom of association, grievance mechanisms, greatest risk, regardless of whether the risk is within use of labour hire and includes examples of leading operations or supply chains. However, prioritisation practice such as collaborating with peers, unions, NGOs is also likely to be necessary. Focusing on sectors and and other stakeholders. It specifies which geographical geographic areas where risks to people are likely to be regions are at high risk of slavery. It also includes practical most significant will make the task more manageable and engagement points for investors to use to encourage effective. companies to adopt best practice on human rights risk management.  nce operations and supply chains are identified, assess O which of the products and services, geographic areas or It is reasonable to consider that investments will have countries and entities identified may involve high modern similar risk factors to supply chains, although it may be slavery risks. This can be done by comparing operations important to communicate that the action available to and supply chains to the risk indicators for modern investors may differ from action available in respect of slavery. Where relevant, investors might also wish to suppliers (see section 4 below for further information in highlight that as investee companies’ reporting improves relation to describing the action taken to address and this may promote further insight over time. assess modern slavery risk).  CSI’s research report, ‘Modern slavery risks, rights and A The Global Slavery Index provides a list of higher risk responsibilities’ indicates that high risk areas for financial jurisdictions that may be helpful. services supply chains include IT procurement, logistics and property and building services, such as facilities Other risk indicators are set out in the Government management, utilities, cleaning, waste management Guidance (‘risk indicators for modern slavery’ extracted at and security, and print and promotional goods. High Attachment 1). risk geographies include conflict-affected zones, and countries where there is a weak rule of law or high MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 10 Examples of that may be helpful to disclose in response Entities may have existing processes to draw upon and to this requirement are: update, for example: Human rights risk analysis forms part of our process for integration of environment, social and §§ Process: Processes for ESG integration and how governance factors in our investment process. Our risk modern slavery risk analysis is covered within those, processes include analysis by sector and geography, using e.g. as part of human rights risk analysis. a wide variety of resources, such as external research and indices. We are planning further work to identify whether §§ Methodology: Criteria, risk factors and tools used our assessment processes can be further enhanced to for risk assessment, such as analysis by sector, by assess modern slavery risk more specifically, and how we geography and what information sources have been can extend these processes into our supply chain. used for such analysis (for example, proprietary research, external research providers, engagements, Entities that have progressed their mapping and identified indices and more). This could also include any key some areas of risk may consider reporting along the lines assumptions that have been made. below. As with all businesses, we recognise that there will be risk of modern slavery in our operations and supply §§ Output: A high level description of areas of the chain, for example: portfolio subject to high risk (this is an important step for requirement four, see below). §§ Product and services risks in our supply chain for cleaning, travel, catering and information technology; Hypothetical Example §§ Sector and industry risks with investments in construction and health services;  t HSR Super, we take the risk of modern slavery A seriously and we do not want to be complicit in §§ Product and services risks with our investments in the perpetuating modern slavery. Nonetheless, the reality is apparel industry; and that forced labour, and related practices, likely exist in the operations or supply chains of most businesses and in §§ Geographic risks, in particular with our investments in every region of the world. emerging markets.  ccordingly, we have mapped our supply chains A  e are committed to taking action to address modern W and investment portfolio to establish a baseline slavery risk. The action we are taking is set out below. for identifying risk. We have xx suppliers across xx countries. We have xx investments, across xx countries and xx sectors. In some instances, we hold as little/ great as xx% of the investment. Across emerging markets and high-risk sectors sectors we recognise that the risk of modern slavery is generally greater. As set out above, we have identified that our investments in Asia have greater modern slavery risk, and we are prioritising our action accordingly. We will report back next year on our progress. As our investee companies’ reporting improves over time, we expect to have further insight on risk identification. 11 MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 4. DESCRIBE THE ACTIONS TAKEN BY THE §§ Develop a specific action plan with a reasonable REPORTING ENTITY (AND OWNED OR timeframe; CONTROLLED ENTITIES) TO ASSESS AND §§ Assign responsibility for assessing and addressing risk ADDRESS THOSE RISKS, INCLUDING DUE and brief the board on the requirements of the Act DILIGENCE AND REMEDIATION PROCESSES and the action being taken; Government Guidance §§ Make sure there is a mechanism for people to safely report modern slavery risks (employee  he Government Guidance recognises that many entities T hotline or similar); have complex operations and supply chains, meaning §§ Build partnerships with business peers, civil society it would be impossible to immediately assess and act groups and industry bodies to improve understanding to respond to modern slavery risks in every part of an of modern slavery risks; entity’s operations and supply chains. §§ Make the entity’s policies on modern slavery  he Guiding Principles suggest that organisations start T publicly available; by focusing on assessing general areas of operations and §§ Review and improve existing policies and supply chains where modern slavery risks are likely to be procedures, including supplier codes of conduct, most significant. For example, high risk goods or services, grievance mechanisms and sourcing policies. Clearly sectors or certain geographic locations and high-risk communicate expectations to suppliers by ensuring sectors (as outlined in section 3 of this guide). modern slavery risk is addressed in contracts or pre- qualification mechanisms;  onsider prioritising which risks to respond to first. The C Government Guidance suggests a focus on the most §§ Improve staff and management awareness of modern severe risks that would cause the greatest harm to people, slavery risks; including those risks with the greatest impact (severity) §§ Review and improve existing policies and or scale (number of people involved) or where a delay in procedures, including supplier codes of conduct, response would mean that remediation is not possible. grievance mechanisms and sourcing policies. Clearly communicate expectations to suppliers by ensuring  he Government Guidance acknowledges that supply T modern slavery risk is addressed in contracts or pre- chains are long and complex and that the complex and qualification mechanisms; changeable structure of investment portfolios means that investors may have limited relationships with their §§ Address practices that may be present in the entity’s investees. The Government Guidance suggests the operations and supply chains that may lead to modern following actions could be considered to assess and slavery, such as charging recruitment fees for workers, address risk. While not all of these actions will be feasible tying workers’ accommodation to their employment for all entities, consider which may be appropriate. For status, sham contracting, unmanageable lead times example: and purchasing practices, unlawful wage deductions or underpayment; §§ Review existing information about the entity’s §§ Update project and contract management systems operations and supply chains, such as Human and plans to address modern slavery, including Rights Impact Assessments, Environmental and templates, procurement strategies and other Social Impact Assessments and Work Health and documents; and Safety Assessments; §§ Engage with investees directly or collectively to §§ Develop tools and policies to monitor high risk encourage modern slavery risks to be addressed. suppliers and mitigate associated risks; §§ Bring together key departments from the entity to assess risk such as Procurement, Sourcing, Risk, Finance, Human Resources, and Legal; MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 12 Practical Tips Investors will naturally have differing exposures via different asset classes, and differing levels of control The requirement to report on action taken is closely across these classes. Investors are likely to have more related to the identification of risk (outlined at Section 3 time and more transparency relating to their larger of this guide). This section of the entity’s modern slavery and more direct holdings, as well as more leverage. As statement could therefore make the link between the such, investors might consider addressing this in their risk assessment and how the actions taken to assess and modern slavery statement by discussing their differing address risk are prioritised. levels of control or leverage by asset class, their size or investment type. At a framework level, consider referring to the entity’s policy measures that are in place. These could  hile the key focus of the Act for investors is about W include a specific human rights policy, risk assessment due diligence and, where appropriate, engagement of procedures, employee and/or supplier codes of conduct, investee companies, investors may also want to cover relevant provisions in standard supply contracts. It due diligence on the source of investments in this could also include reference to employee-training and section. Disclosure can be at a process level, rather than employee-reporting mechanisms (such as a whistle specific detail – of course it remains appropriate that blower phone line). each investor’s confidential information is protected. The Guiding Principles also highlight leverage as a key Examples of what could be disclosed are: role for investors. §§ Processes for ESG engagements, for instance high-  everage for investors typically means engagement, L level ESG engagement plans, ESG engagement which in turn may help investors to make better informed objectives and ESG engagement policies and how investment decisions. These engagements can relate to they relate to modern slavery in particular. direct engagements with investees, and collaborative engagements (with other investors or other stakeholders) §§ Links between risk assessment (as outlined in section with investees. 3 above) and prioritisation of engagement activities and engagement objectives.  ctions can also include other risk mitigation actions, such A as advocacy, joining relevant risk control frameworks that §§ Actual engagement activities undertaken (individual focus on a particular sector or a country or pushing for and/or collaborative ones). These could include: more disclosure, which may go beyond legal compliance. In other words, there are many ways that investors can o Industry-level engagements. address risk and each investor may wish to consider what is feasible and appropriate for them. o Company-specific engagements including objectives (such as raising awareness, influencing  any investors have portfolios with a large number of M corporate behaviour or other). portfolio constituents, sometimes spread across various o Case studies or high-level statistics (it is up to the asset classes. A ‘risk-based approach’ (based on risks reporting entity to decide how much detail goes to people, Guiding Principle 17), could be the basis into this reporting). for prioritisation of responses, including engagement activities and active management broadly. §§ Other remediation strategies or risk control frameworks, such as screens or partnerships with In terms of a risk-based approach, the extent of due other stakeholders that the investor might have. diligence could be guided by the level of risk and level of influence (which in turn depends on ownership structure, asset class, size of holding, corporate access and more). As an example, this is similar to how some retailers have risk-segmented their suppliers, based on the level of risk and level of influence. 13 MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 Any limitations to action should also be clearly  e are signatories to the Australian Asset Owner W explained – for example, some investors with passive Stewardship Code. We disclose against the provisions of holdings or investors with small holdings may not have the Code, which includes providing an overview of how significant influence. we discharge our stewardship responsibilities, links to our policies, and our approach to engagement with our  his section could also reference ongoing action. For T investee companies. example, ACSI members could reference the work done by ACSI to engage with investees on their behalf. Our investment portfolio includes investments in equities across the world. In respect of Australian equities, we are members of the Australian Council of Superannuation Hypothetical Example Investors (ACSI). ACSI undertakes a year-round program of research, engagement, advocacy and voting advice  n external facing policy statement is recognised A in relation to companies in the ASX300. ACSI seeks to in the Guiding Principles as best practice. We have influence companies through constructive engagement developed our approach to human rights (including our with their boards about material ESG issues, with the aim commitments and governance) into a policy statement, of promoting long term shareholder value and minimising which can be found at . risk. ACSI encourages listed companies to consider their practices as they relate to human rights, including actively  he following aspects of our governance framework are T engaging with employees, customers, supply chains and relevant to our commitment to human rights: other relevant stakeholders to understand and assess human-rights impacts. ACSI’s engagement program §§ Our Code of Conduct requires each person working for includes human rights in supply chains and sustainability the Fund to respect and work to uphold human rights. reporting disclosure. §§ Our supplier contracts require suppliers to respect We have identified that our investments in Asia have and work to uphold human rights, in relation to a greater risk of modern slavery. Accordingly, we have child labour, inhumane treatment of employees, prioritised our Asian investments for further action. In forced or compulsory labour, freedom of association, particular, we have prioritised the relevant contractual living wage, workplace health and safety and arrangements for review to identify areas that may require community interaction. revision. We have also identified a program of engagement with investees, so we can further understand the level of §§ Our employee training covers the identification of risk, and identify any action required. human rights-related risk and how employees can report suspected breaches of our requirements. Investors with international engagement agreements may wish to describe them here. §§ Employees are encouraged to use our employee hotline, which allows anonymous disclosure. We will continue to assess the effectiveness of our actions and from there, identify future actions for §§ Reports from our employee hotline are collated and prioritisation. Further information on how we assess the reported to the board. effectiveness of our actions is set out below. We intend to focus on embedding our standards consistently across §§ In terms of our investment activity, our existing our operations and supply chains, as well as improving due diligence and risk management policies require our ability to identify, manage, address and remediate thorough assessment prior to investing. We will review modern slavery risks and impacts. our existing processes to ensure material modern slavery risk is incorporated into our assessment. MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 14 5. DESCRIBE HOW THE REPORTING Practical Tips ENTITY ASSESSES THE EFFECTIVENESS OF SUCH ACTIONS  his provision asks entities to explain how they assess T the effectiveness of their actions, rather than to disclose Government Guidance whether or not action is effective. This part of the modern slavery report will again build directly from the  he Government Guidance outlines that entities should T previous part (being a description of action taken by the explain what they are doing to check whether their reporting entity to address the risk of modern slavery). actions are effective to assess and address modern slavery risk. The Government Guidance highlights that Entities might wish to consider disclosing how they assess: the Act requires reporting entities to explain how the effectiveness of an entity’s actions are assessed; not to §§ Outcomes from ESG management in general and/or determine whether an entity’s action are effective. This how these relate to engagements on modern slavery, is an important consideration for all reporting entities, including case studies on engagement. including investors. §§ Progress on objectives set out in the ESG The Government Guidance acknowledges that engagement plan. understanding and assessing effectiveness can be difficult, and offers a range of ways to do this including: §§ Activities to raise awareness such as training of staff, stakeholder awareness. §§ Implementing a process to regularly review actions taken. §§ Relevant changes to portfolio risk. §§ Regularly reviewing risk management processes to ensure they are up to date – for example does the Hypothetical Example entity’s risk management processes incorporate modern slavery risk and identify high risk geographies  t HSR Super, we recognise that it will take time, and A and/or industries for investment? efforts globally to address modern slavery. In practice, this means that change will be incremental. However §§ Incorporating relevant metrics and checks in the collectively, incremental change will drive global awareness internal audit processes, for example does internal and improvement. That’s one of the reasons why we’re audit review supplier due diligence processes? committed to taking the action set out in this report, and also to assessing the effectiveness of our actions. §§ Reviewing relevant reports from reporting hotlines.  e regularly assess the effectiveness of our engagement W §§ Working with suppliers to check how they are activities and, in accordance with our escalation policy progressing action put in place to address modern consider whether escalation is appropriate. slavery risks.  ll employees receive Code of Conduct training upon A §§ Reviewing relevant staff training. appointment and we ask all continuing employees to review our Code of Conduct regularly. We monitor  he Government Guidance also asks entities to consider T compliance with this training requirement. We also whether it is appropriate to set key performance encourage staff to report any concerns through our indicators and gives some examples of key performance employee hotline. Reports from the employee hotline are indicators that might be considered. aggregated and reported to the board. 15 MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019  ur internal audit team regularly assesses compliance O 7. ANY OTHER INFORMATION THAT THE with all our policies and procedures, including checking REPORTING ENTITY CONSIDERS RELEVANT compliance with our supply processes. Internal audit reports directly to the risk committee. Government Guidance Our current activity is focused on assessing modern The Government Guidance outlines that there is no need slavery risk and our frameworks to address risk. From to include information under this provision if the entity there, we intend to identify further relevant actions which considers that its responses to the other six criteria are we anticipate may include incorporating relevant indicators sufficient. The Government Guidance suggests that in KPIs, partnering with NGOs and ensuring all our supply entities may wish to consider including the following: contracts include appropriate modern slavery clauses. §§ Advocacy activity, including supporting the 6. DESCRIBE THE PROCESS OF development of legislation, participation in external CONSULTATION WITH: forums to improve awareness; A. ANY ENTITIES THAT THE REPORTING ENTITY OWNS OR CONTROLS; §§ Partnerships with civil society; and B. IN THE CASE OF A JOINT STATEMENT, ENTITIES GIVING THE STATEMENT. §§ Contribution to addressing the root causes or structural factors that contribute to modern slavery This section should describe the entities covered by the such as poverty, forced migration, poor education. statement (for example relevant subsidiaries that meet the reporting threshold). Where owned or controlled entities operate separately across different sectors, Practical Tips more engagement across entities might be required, in particular where entities are not wholly owned. While there may be no need to include additional information, if entities wish to do so, they should.  here entities are wholly owned, and run largely as a W Consider whether any additional information should go corporate group with common practices and reporting in a separate section, or whether it is best integrated lines, consultation may not need to be so detailed. It will through the statement where appropriate. For example, however be important to consult the relevant people advocacy activity may be better placed in the information across the organisation to ensure information is complete addressing the entity’s action taken in respect of modern and correct. The boards and company secretary of slavery risk. relevant subsidiaries should also be aware of preparation of the modern slavery statement and have an opportunity to participate in the process. Hypothetical Example  his modern slavery statement is made by HSR Super, T and its subsidiaries, (include names of subsidiaries if relevant). In preparing this modern slavery statement, relevant directors and officers of all the entities making the statement were consulted and provided with an opportunity to review the statement prior to its approval. MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 16 8. DETAIL ON APPROVAL ON THE STATEMENT The Government Guidance notes that generally for a company, the principal governing body is the board, and Government Guidance a director needs to sign the statement. For a trust, the principal governing body may be the board of trustees, in The Act provides for two specific requirements for which case one of the trustees on the board should sign approval, being: the statement. §§ The statement must be approved by the principal Accordingly, for many entities, the board will need to governing body of the reporting entity; and approve the statement and one director will need to sign the statement. §§ The statement must be signed by a responsible member of the reporting entity (in most cases, this For joint statements, table three in chapter 7 of the will be a member of the principal governing body). Government Guidance provides information on approval requirements and processes. Principal governing body means the body or group of members that is responsible for the governance of the entity. 17 MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 USEFUL REFERENCES §§ The Australian Government's Website: §§ ACSI research Modern Slavery Risks Rights and https://www.homeaffairs.gov.au/about-us/our- Responsibilities: portfolios/criminal-justice/people-smuggling-human- https://www.acsi.org.au/images/stories/ trafficking/modern-slavery ACSIDocuments/generalresearchpublic/ACSI- Modern-Slavery-Report.Feb19.pdf This website includes information from the Modern Slavery Business Engagement Unit, how to contact This report aims to increase the Australian business the Unit, along with the Government Guidance for community’s understanding of modern slavery reporting entities. risks in their operations and supply chains, and to help prepare businesses to meet new regulatory §§ RIAA’s Investor toolkit – human rights with focus requirements for transparent public disclosure. on supply chains: https://www.responsibleinvestment.org/wp-content/ §§ Finance Against Slavery and Trafficking (FAST) uploads/2018/08/HRWG-Investor-Tool-Kit.pdf https://www.fastinitiative.org This tool assists investors in identifying human rights Unlocking Potential: A Blueprint for Mobilizing Finance risk, including modern slavery and provides practical Against Slavery and Trafficking is the final report of engagement ideas for investors. It also contains a the Liechtenstein Initiative for a Financial Sector list of other useful resources and tools available to Commission on Modern Slavery and Human investors. Trafficking, which has now formed Finance Against Slavery and Trafficking (FAST). The Blueprint provides §§ Global Slavery Index: a shared collective-action framework that different https://www.globalslaveryindex.org/ financial sector actors can implement in their own ways and at their own speeds. The FAST Goals This tool provides background information about the provides a framework for the whole financial sector global issue of modern slavery and can also assist and professional service providers to demonstrate investors in risk assessing by geography and product. their commitment to accelerating action to end modern slavery and human trafficking. The FAST §§ Guiding Principles on Business and Human Rights: Implementation Toolkit, comprising practical tools https://www.business-humanrights.org/en/un- and initiatives, including workflows and diagnostic guiding-principles tools, will help financial sector actors in implementing the Blueprint. These are a set of guidelines for States and companies to prevent, address and remedy human rights abuses committed in business operations. The guidelines are directly quoted in the draft guidance for reporting entities. MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 18 ATTACHMENT ONE: GOVERNMENT GUIDANCE APPENDIX 1 TABLE SIX: RISK INDICATORS FOR MODERN SLAVERY This table sets out indicators that can be used to help identify modern slavery risks in the entity’s operations and supply chains. This table also sets out direct indicators that may indicate a person is in a situation of modern slavery. TYPE OF RISK INDICATORS Sector and §§ Use of unskilled, temporary or seasonal labour. industry risks §§ Use of short-term contracts and outsourcing. Certain sectors §§ Use of foreign workers or temporary or unskilled labour to carry out functions which are not and industries may immediately visible because the work is undertaken at night time or in remote locations, such have high modern as security or cleaning. slavery risks §§ Use of child labour in hazardous conditions, such as underground, with dangerous machinery because of their or tools, in unhealthy environments (including where they are exposed to physical or sexual characteristics, abuse), or for long hours. products and processes §§ Recruitment strategies by suppliers, their agents or labour hire agencies target specific individuals and groups from marginalised or disadvantaged communities. §§ The sector involves direct engagement with children, including through orphanage tourism and other forms of ‘voluntourism’ (including through companies’ social investment and corporate social responsibility programs). Product and §§ Cost requirements or delivery timeframes might require suppliers to engage in excessive services risks working hours, make cost savings on labour hire or rapidly increase workforce size. §§ The development of the product or delivery of the services has been reported as involving Certain products labour exploitation by international organisations or NGOs. and services may have high modern §§ Children are often used in the development of the product or delivery of the service, such as slavery risks carpet weaving. because of the way §§ The product or components of the product are made in countries where there is a high risk of they are produced, labour exploitation reported by international organisations or NGOs. provided or used §§ The services are provided in countries where there is a high risk of labour exploitation reported by international organisations or NGOs. §§ The product is made from materials or using services reported to involve a high risk of labour exploitation by international organisations or NGOs. 19 MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 Geographic risks §§ The country has not ratified international conventions relevant to modern slavery, such as: the International Convention to Suppress the Slave Trade and Slavery (1926); ILO Convention (No. Some countries 29) concerning Forced or Compulsory Labour (1930); the Supplementary Convention on the may have higher Abolition of Slavery, the Slave Trade and Practices similar to Slavery (1956); the Protocol to risks of modern Supress, Prevent and Punish Trafficking in Persons, Especially Women and Children (2000); ILO slavery, including Convention (No. 182) concerning the Prohibition and Immediate Action for the Elimination of due to poor the Worst Forms of Child Labour (1999). governance, §§ The country is reported to have a high prevalence of modern slavery or labour rights violations, weak rule of law, other human rights violations and/or child labour by international organisations or NGOs. conflict, migration flows and socio- §§ The country has inadequate protections for workers, including no or weak capacity to economic factors effectively monitor workplace standards and enforce compliance with national standards. like poverty. §§ Law enforcement agencies are reported to be hostile to workers in at risk industries. A number of organisations §§ The country forces parts of the population to work for development purposes, for example to issue public assist in construction or agriculture. reports evaluating §§ The country is reported to have weak rule of law by international organisations or NGOs, governance, including due to corruption, conflict and/or political instability. corruption and rule of law in countries §§ The country has a high prevalence of people who are vulnerable to exploitation because they around the world. are impoverished, displaced or subject to severe discrimination. You can use these reports to identify higher risk countries. Entity risks §§ Entity has previously been reported as noncompliant with human rights or labour standards, including by media or NGO sources. Some entities may §§ Entity’s procurement and sourcing processes appear poorly managed or inefficient. have particular modern slavery §§ Entity has complex or opaque supply chains. risks because §§ Workers appear to have little information about workplace entitlements and protections and they have poor there is a general lack of information about workplace standards. governance structures, a record §§ Audit results for the entity appear unreliable or conflict with other sources of information of treating workers about the supplier, such as NGO reports. poorly or a track §§ Staff recruitment costs by labour hire companies or recruiters are not covered by the company, record of human meaning that recruitment expenses such as travel may be improperly imposed on workers. rights violations. §§ Entity provides residential care for children overseas. MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 20 Indicators of The suspected victim or victims are: modern slavery §§ living at the workplace, or another place owned/controlled by their employer A combination of §§ underpaid or not paid at all these signs may §§ required to work excessive hours indicate a person is in a situation of §§ confined or isolated in the workplace or only leave at odd times modern slavery §§ guarded at work or in their accommodation and that further investigation and §§ isolated in remote locations that are difficult to access and/or restricted from contacting or assessment is interacting with people outside the workplace (for example, their phones are confiscated or required. You should they are supervised when in public) also consider that §§ managed by an intermediary or third party who ‘holds’ or ‘invests’ their money for them some groups may be at higher risk §§ subject to different or less favourable working conditions than other workers because of their of being impacted country of origin, gender or other factors by modern slavery, §§ unable to terminate their employment at any time such as women and migrant workers. §§ appear to be servicing a debt to an employer or a third party (such as a recruitment agent) For example, §§ appear to be subjected to, or threatened with, violence, emotional, sexual, verbal or physical women can be abuse and/or degrading treatment in connection with their employment disproportionately impacted by §§ appear to be subjected to intimidation, such as threats to their family or close relations in modern slavery connection with their employment due to structural §§ appear to have false travel or personal documents and/or are not allowed access to these disadvantages documents because they are being held by an employer or third party including lack of access to education. §§ appear to have been deceived about the conditions of their employment §§ are not provided with contracts in a language and format that they can easily understand §§ are not informed of, or do not appear able to understand the terms and conditions of their employment §§ are not provided with any protective equipment, training or means to refuse to participate in dangerous work practices, or refuse to handle known toxic materials or hazards §§ do not have permission to work because they are from another country or appear to be working in breach of visa requirements. 21 MODERN SLAVERY REPORTING – GUIDE FOR INVESTORS: NOVEMBER 2019 Australian Council of Superannuation Investors Level 23 / 150 Lonsdale Street Melbourne VIC 3000 Australia P: +61 3 8677 3890 E: info@acsi.org.au W: www.acsi.org.au Responsible Investment Association Australasia Level 3 / 478 George Street Sydney NSW 2000 Australia P: +61 2 8228 8100 E: info@responsibleinvestment.org W: www.responsibleinvestment.org