Modern Slavery Statement 2024
This statement covers the following topics:
1. Message from our GESB Chair and CEO
Modern slavery can affect people in any country. It can occur in any sector or industry, at any point in a supply chain. According to the latest Global Estimates of Modern Slavery, there were more than 50 million victims of modern slavery worldwide in 2021, an increase of around 10 million people compared to 2016 estimates1. This means one in every 150 people worldwide is a victim of modern slavery, according to the World Economic Forum2.
According to Walk Free, on any given day in 2021, there were 41,000 individuals living in modern slavery within Australia3.
With around 247,000 members and approximately $40 billion in funds under management (as at 30 June 2024), we are the largest superannuation fund based in Western Australia. We have investments across a wide range of industries both globally and within Australia and engaged approximately 40 service providers in 2023/24.
We strongly believe we have a responsibility to our members, stakeholders, and the broader community to address the risks of modern slavery, a significant global human rights issue. To achieve this aim, we established a modern slavery working group in 2021 with representatives from all key functions across our business.
We have voluntarily prepared this Modern Slavery Statement, which relates to the 2023/24 financial year. Our statement outlines the steps we have taken to identify, assess, and address the risks of modern slavery in our supply chains and operations, including our investments.
In our third year, we continued to expand our understanding and refine how we manage our exposure to modern slavery risks. Some of our initiatives included:
- Embedding modern slavery risk into our risk assessment for all new and existing projects and contracts, as well as part of the ongoing contract review
- Carrying out a more comprehensive evaluation of countries and financial markets into our modern slavery risk assessment for suppliers and investments
- Inserting modern slavery clauses in new contracts with key service providers and new investment managers appointed under a mandate
- Continuing to increase staff awareness around the issue of modern slavery through compliance training
There is always more work to be done to address the issue of modern slavery. We remain committed to continuous improvement and will share more details as our work progresses.
Jo Gaines - Chair
Ben Palmer - Chief Executive Officer
2. Introduction
About GESB
The Government Employees Superannuation Board (GESB) is a statutory authority established by the Government of Western Australia (WA) in accordance with the State Superannuation Act 2000 (SSA). Our purpose is to help members achieve a quality retirement. In carrying out our functions, we are required to act in the best interests of our members and ensure that members and employers are fully informed of their rights and obligations under the SSA. As a statutory authority, our GESB Board has powers and functions under the SSA and is accountable to the WA Treasurer; we are regulated by the WA State Government, not the Australian Government.
GESB also owns and/or controls some entities, such as investment trusts where we are the sole beneficiary, whose only purpose is to hold investments of the Fund, with details of these controlled entities found in our annual reports. Our office is located in Perth and employed 75 staff as at 30 June 2024. None of our staff are employed by any of these aforementioned investment vehicles, including trusts; all investment decisions related to these entities are made by external investment managers appointed by GESB.
Learn more about our purpose, values and history as an organisation.
Our schemes are consistent with superannuation national standards where practicable
Western Australia is a signatory to the ‘National Superannuation Standards’ Heads of Government Agreement (HoGA) with the Commonwealth. Under this agreement, the State Government is committed to conform to the Commonwealth’s Retirement Incomes Policy to the best of its endeavours.
Broadly, this means that the governance and superannuation benefits we provide through our schemes are consistent with national standards. These standards include rules around preservation and protection of benefits, vesting of benefits, member disclosures, and adequate prudential and supervisory arrangements.
This is our third Modern Slavery Statement
This statement outlines the work we have completed so far in identifying modern slavery risks in our operations, supply chains and investments.
Although we are not a 'reporting entity' under the Australian Modern Slavery Act 2018 (Cth), we have voluntarily prepared this statement in line with our responsibility to members and stakeholders to manage modern slavery risks. We are committed to identifying modern slavery risks within our operations and supply chains, to avoid directly or indirectly contributing to modern slavery.
Our Board acknowledges the need to maintain high standards of ethical conduct for our Directors, management, and staff. The decision to prepare this voluntary statement also aligns with two of our core values, ‘sustainable performance’ and ‘act with integrity’, as well as our overall social responsibility goals. We are committed to regularly reviewing and updating our Modern Slavery Statement to share our continued work in this area.
What is ‘modern slavery’?
Modern slavery is defined in the Modern Slavery Act 2018 (Cth) as a group of practices which are considered major violations of human rights and serious crimes. These include people-trafficking, slavery, slavery-like practices (including forced labour and forced marriage) and the worst forms of child labour (including using children for prostitution or hazardous work).
Modern slavery can affect any country or industry, at any point in a supply chain.
3. Our structure, operations and supply chain
By examining our structure, operations and supply chain, we aim to understand our exposure to modern slavery risks. With an enhanced understanding, we can then determine appropriate action to help address this significant global human rights issue.
GESB's risk of modern slavery practices
We consider modern slavery risks across the following areas of our operations and supply chain:
Procurement and outsourcing
- Administration services
- IT services
- Member insurance
Our procurement and outsourcing activity complies with the Western Australian Procurement Rules. Under these procurement rules, any service provider who fail to meet their obligations under the Australian Modern Slavery Act 2018 (Cth) will be barred from access to the Western Australian Government's procurement contracts on goods, services and public works.
Investments
- Supply chain – investment managers
- Operations – custodian and asset consultant
Our investment approach adheres to the Prudential Guidelines for Investments issued by the WA Treasurer.
Internal operations
- Supply chain – business services suppliers
- Supply chain - professional services
- Employees
Our employment and remuneration policies comply with the Western Australian Public Sector General Agreement and our governing legislation. Our supply chain operations (business service and professional services) relate to procurement and outsourcing activity, therefore also comply with the Western Australian Procurement Rules.
3.1 Our structure
As a Western Australian statutory authority, we operate within the State Government’s policy framework. The WA Treasurer, as our responsible minister, administers the legislation which underpins our operations.
Our statutory framework is largely derived from the State Superannuation Act 2000 (SSA) and the State Superannuation Regulations 2001. Our functions under the SSA are to:
- Manage the Government Employees Superannuation Fund
- Administer our members’ super schemes
- Provide information, advice and assistance to the WA Treasurer on matters relating to super
- Provide or facilitate the provision of products and services to members of super schemes administered under the SSA or any other relevant law and employers in the WA public sector
- Perform any other functions required under relevant law
Our Board is accountable to the WA Treasurer for all matters relating to our operations. The Board comprises a Chair, three Employer Directors and three Member Directors.
The Chair is appointed by the Governor of Western Australia on the WA Treasurer's nomination after consultation with representative unions. The Employer Directors are also appointed by the Governor, with Member Directors appointed through elections conducted by UnionsWA.
Our Board operates within a corporate governance policy framework that incorporates legislative and regulatory requirements aligned to industry best practice, and the Australian Securities Exchange governance principles.
This framework reflects our operating environment as a WA Government authority within the financial services market. We operate within the State’s Integrity Framework.
3.2 Our operations
Our business comprises five main functions:
- Investments
- Finance
- People and Business Services
- Superannuation Services
- Strategy and Member Experience
Our main areas of operation include providing superannuation and retirement products and services and making financial investments on behalf of our members.
We manage superannuation accounts and investments for over 247,000 current and former WA public sector employees. We deliver cost-effective and trusted products, including insurance, and services to our members, employers, and the State of WA.
We manage an investment portfolio of approximately $40 billion. Of this, 92% ($37 billion) is managed for members in market-linked schemes, where members bear the investment risk, and $3 billion is managed for the State to support its defined benefit liabilities (information as at 30 June 2024).
Our people
As at 30 June 2024, GESB employed 75 staff, almost all of whom are based in Western Australia. As a Western Australian statutory authority, our staff are engaged under the Public Sector Management Act 1994 (WA). Our remuneration policy complies with this and other governing legislation such as the SSA to ensure fair work conditions for GESB staff, and the fair appointment of Board members.
Our schemes
We administer a number of schemes established under the SSA. These include our superannuation schemes:
- GESB Super: Our current default fund, which has been in place since April 2007. This is a taxed accumulation scheme
- West State Super: This served as the default fund from July 1992 to April 2007 and is a market-linked untaxed accumulation scheme
- Gold State Super: This scheme was available for individuals who chose to join before December 1995. It operates as a defined benefit scheme, determined by applying a fixed formula
We have three Pension schemes, also underpinned by the SSA:
- Retirement Income Pension: This has been open to new members since April 2003 and can be categorised as:
(i) Retirement Income Allocated Pension: An allocated pension that enables retiring members to keep their funds with GESB in a concessionally taxed environment, while receiving flexible periodic payments.
(ii) Transition to Retirement Pension: A retirement income stream allowing members that have reached Commonwealth preservation age to access their super while still working.
- Retirement Income (RI) Term Allocated Pension: A market-linked income stream closed to new members in September 2007, that provides members with a regular income stream for a certain period of time
In accordance with the SSA, the GESB Board formulates and implements an investment strategy for the fund to achieve prudent diversification and deliver returns meeting investment objectives. Our investment framework operates in accordance with Prudential Guidelines for Investments issued by the WA Treasurer.
We also administer other defined benefit schemes such as the State Pension Scheme (including Provident Account), the Judges’ Pension Scheme (WA), and the Parliamentary Pension Scheme (WA) that are not established under the SSA but are underpinned by other legislation. Our schemes are regulated by the WA State Government rather than the Australian Government.
3.3 Our supply chain
3.3.1 Service providers (other than investment managers)
To help us deliver high-quality, efficient and effective services to members, we use third party service providers for most of our key activities. We expect our service providers to operate ethically and responsibly. We achieve oversight and governance through formal contractual agreements and independent external reviews.
Our procurement processes
As a State Government agency, we comply with the SSA and the Western Australian Procurement Rules 2021 (WA Procurement Rules).
The WA Procurement rules streamline the State’s approach to procurement and:
- Promote the delivery of added sustainable economic, social and environmental benefits for Western Australians
- Reduce barriers to small and medium business participation
- Strengthen integrity measures to promote ethical and accountable practices
- Allow for coordinated whole-of-government procurement leadership, with localised accountability and decision making
Under these procurement rules, any service provider which fails to meet their obligations under the Australian Modern Slavery Act 2018 (Cth) will be barred from access to the Western Australian Government’s procurement contracts on goods, services and public works.
Our service providers in 2023/24
During 2023/24, we sourced goods and services from approximately 40 service providers.
We recognise the potential risks of modern slavery, especially in relation to our outsourced providers. While some of these providers are based overseas, they have local offices, and we engage with them through their Australian-based staff. This approach aligns with our preferences and policies.
To further reduce the risk of modern slavery, we prioritise collaborating with Australian-based staff from international providers and maintaining communication with local offices whenever possible. This practice improves the traceability of our supply chain. We have also put in place provisions to support this preference. Our service providers operate mainly within the sector of professional services, including information technology, industrial, and consumer discretionary sectors.
3.3.2 Investment managers
We invest our funds across a wide range of local and international investment markets, asset classes and strategies. This includes investments in cash, fixed income, public and private equity, property, infrastructure and hedge fund strategies. This means we invest across a range of industries and businesses that operate all over the world, that may be exposed to the risks of modern slavery.
How we work with investment managers
The vast majority of our investments are externally managed. Our investment managers buy and sell assets on our behalf. For example, our investment managers for Australian Shares work within our risk guidelines to decide which companies to buy and sell Shares in, and then place orders for those Shares.
This approach means we can use the skills of a range of investment managers from around the world and benefit from diversification in investment style. It allows us to maintain a balance of assets across a range of investment managers, which helps us to achieve our investment goals over the long term.
When investments are made by our investment managers, it is their role to incorporate modern slavery risk into investment decisions. Modern slavery risk is usually considered alongside other environmental, social and governance (ESG) risks. The approach taken by each investment manager will vary based on the characteristics of the investment and the investment style adopted.
Ongoing engagement with our investment managers helps us understand how modern slavery risk is factored into their investment process, as well as any actions taken to engage with the investee company to address any issues identified.
The appointment of investment managers
We appoint a diversified group of external investment managers to invest our funds. To avoid a concentrated exposure to a particular investment manager or investment style, we typically appoint multiple investment managers in each asset class. Learn more about our investment managers.
The WA Treasurer is responsible for approving investment managers in accordance with the WA Treasurer’s Prudential Guidelines for Investments. These guidelines also detail the kinds of investments permitted.
We regularly review our choice of investment managers. We understand their risk and return profiles and ensure they meet our expectations.
4. Examining the risks of modern slavery practices
Modern slavery risk is primarily about risk to people. Regardless of the size, scale, location or industry, the operations and supply chain of any business can contribute to modern slavery practices.
Conditions favourable to facilitating modern slavery could be maintained directly through business operations or employment conditions, or indirectly through its actions or inactions which could facilitate or incentivise modern slavery. A business's operations, products or services could also be connected to modern slavery through the activities carried out by their service providers.
For this reason, we are committed to understanding the modern slavery risks that may exist within our operations, supply chains and investments – and how we can address these.
4.1 The risks of modern slavery in our internal operations
Our workforce allows us to deliver on both our purpose and mission. Our purpose is to help our members achieve a quality retirement, and our mission is to responsibly manage our members’ retirement savings, deliver strong long-term investment returns, and offer relevant support so members can make informed decisions. Our staff have a range of specialised financial services, public sector and administrative skills.
One of our strategic objectives is to create a positive and supportive organisational culture, underpinned by strong values. This creates an environment where our staff approach every aspect of work ethically and adopt policies that allow us to operate transparently.
Although we currently hold investments in 52 countries through our investment managers and custodian, we do not operate in any foreign countries or jurisdictions.
Based on our assessment of the above, we consider the risk of modern slavery within our internal operations to be low.
4.2 The risks of modern slavery in our supply chain and procurement processes
We have subscriptions and contractual relationships with a range of businesses that offer different products or services to support staff development and our delivery of superannuation products and investments, on behalf of our members. These are mostly professional and administrative services, including legal, consulting and accounting.
To understand the potential risks of modern slavery in our supply chain, we conduct risk assessments of our service providers. This process involved gathering information from a range of sources, including the supplier’s Modern Slavery Statement or questionnaire responses and websites. Our risk assessments consider the evaluation of four categories:
- Sector and industry risk the supplier operates in
- Product and services produced or supplied by the company
- Countries the supplier operates or has a footprint in
- Supply chain models or channels susceptible to Modern Slavery
These categories align with the risk screening tool developed by the Australian Government to assess the risks of existing or new procurement contracts.
All new suppliers are risk assessed before a contract is entered into and reassessed as part of the ongoing contract review. Risk assessment criteria helps determine the frequency of future risk reviews for all suppliers.
The results of the assessments are recorded in our risk and compliance monitoring and reporting system, so any modern slavery risk can be managed, monitored, and reported on. Our modern slavery risk assessment sits alongside other assessments undertaken on our suppliers, including privacy, information security, anti-money laundering, critical supply chains, market risk, and other ethical conduct elements.
Although earlier risk reviews might be triggered, modern slavery risk assessments are ongoing for all service providers within scope.
Our Risk and Compliance team maintain oversight of the supplier risk assessment to ensure consistency is applied.
We explain more about our approach and our assessment for supply chain risks in section 5.
4.3 The risks of modern slavery in our investment activities
Our investment managers and underlying investments are an important part of our supply chain:
- We invest members’ super across a range of different asset classes and sectors, both within Australia and internationally
- We invest in over 50 countries with assets in many sectors including energy, information technology, materials, financial services, and healthcare
- Our external investment managers are appointed for specific mandates to implement investment strategies and select underlying investments within asset classes
- As at 30 June 2024, our assets were managed under 47 different mandates by 37 investment managers
- Our external investment managers are located both within Australia and overseas, and have their own operations and supply chains
We recognise the scope of our investment allocation has the potential for exposure to modern slavery risks.
Industries and countries most affected by modern slavery
One way to determine our exposure is to identify the sectors and countries where modern slavery conditions are more likely.
We recognise that the risk of modern slavery is higher in certain countries, due to many factors including conflict and weak governance. Walk Free’s Global Slavery Index identified the ten countries with the highest prevalence of modern slavery.
As of June 30, 2024, our overall investment exposure in these countries is limited to just three of the ten listed: Saudi Arabia, Russia4 and the United Arab Emirates (UAE), with exposure remaining very low by constituting less than 0.1% of our portfolio. Sectors with an increased risk of modern slavery practices typically involve unskilled or temporary labour, poor employee health and safety practices and/or material issues in supply chain management. Examples of high-risk sectors include hospitality, agriculture, cleaning and construction. Given our investment approach considers the broader share market, we will have exposure to companies within these sectors.
Within our unlisted property portfolio, we have exposure to property assets including retail (such as shopping centres), industrial (such as warehouses) and office properties. Essential to the property management of these assets is cleaning and security services, both of which are identified as high-risk industries for modern slavery, given the prevalence of temporary or unskilled labour. While the above helps to identify the risk and prioritise our efforts, we acknowledge that modern slavery exists in every country, and across many sectors in which we invest.
The importance of environmental, social and governance (ESG) factors
As part of our due diligence, we review each investment manager’s investment approach to understand how they integrate ESG considerations into their investment decisions. This is carried out in conjunction with our asset consultant.
Some issues our investment managers consider as part of their investment approach include human rights, modern slavery, child labour, and supply chain management.
The growing importance of ESG means it is now an integral part of our operational due diligence process. We aim to understand the ability of our investment managers to deliver the necessary operational standards and capabilities.
ESG is broader than what we invest in, covering culture and workplace behaviour as well. When reviewing our investment manager’s operational functions, the people, policies and processes adopted by the investment manager should also be considered.
Determining the risks associated with investments made on our behalf
Where useful for our assessment, we will circulate a due diligence questionnaire prepared by the Financial Services Council to our external investment managers.
These questionnaires aim to help us better understand our investment managers’ modern slavery reporting obligations, governance and due diligence processes, operational and supply chain risk assessment outcomes and, importantly, the modern slavery risks associated with their investment activities. This statement describes our latest assessment of our investment managers' approach.
Our ongoing commitment to addressing modern slavery risks
We continue to work with our external investment managers, ensuring that modern slavery risk is considered alongside other ESG risks when integrating ESG into investment decisions.
Our investment team meets with our investment managers regularly, providing an opportunity to discuss ESG issues more broadly and/or to discuss any issues raised by the investment managers related to specific investments. Modern slavery forms part of these discussions.
Find out more about our approach to ESG, including human rights and labour related risks.
5. Our actions to assess and address the risks
Our Working Group against Modern Slavery (WGAMS) was established in 2021 and is comprised of representatives across all key functions of our business, including our Executive Leadership team (ELT). The WGAMS oversees the assessment and implementation of our modern slavery reporting requirements, in the interest of achieving better practices concerning governance.
In the past financial year, our working group met six times to discuss and advance the actions listed in our previous statement, and to oversee this year's risk assessment. The outcomes of our work are summarised in the sections below.
Understanding the risks of modern slavery in our supply chain
In 2023/24, we continued to enhance the way we incorporate modern slavery risk into our overall risk management process. Our assessment continues to be based on four categories including the products and service, industries, geographic location and complexity in the supply chain. For each category, each supplier is rated either low, medium, or high risk to help inform an overall score.
This year, we improved our assessment of modern slavery risks in our supply chain by conducting a more thorough evaluation of risks in specific countries and the financial markets in which we invest. This assessment incorporates information from suppliers, along with guidance from government agencies, global financial action task forces, and research organisations.
As a result of our reviews conducted in the last 12 months, we have determined a low to medium risk rating for our suppliers. This is based on detailed assessments conducted across 30 suppliers excluding subscription and cloud service providers. This captures the onboarding of new suppliers as well as periodic review of existing suppliers.
In making this assessment, we observe the following:
- All suppliers were procured under the WA Procurement Rules, either through a State Common Use Arrangement (CUA) or an agency-led Standing Offer
- Apart from cloud services or subscriptions, the majority of suppliers and contractors we procure goods and services from have an Australian presence
Those suppliers assessed as medium risk were mostly attributed to the global footprint of the supply chain or the global span of our service providers. Offshoring is one of the main factors contributing to this risk. For these suppliers, there are controls and policies in place to help mitigate this, such as protective clauses around offshoring arrangements. To date, we have not identified any suppliers as high risk. Typically, we do not engage with suppliers that have complex supply chains and/or business operations within countries that are sanctioned or have a high prevalence of modern slavery risk.
An education session was run for staff to support the rollout of the enhancements to our assessment. The session provided a high-level process overview emphasising the importance of the assessment. Ad hoc training sessions were also conducted for procurement staff and those managing relationships with our key suppliers.
Understanding the risks of modern slavery in our investment portfolio
In the previous reporting period, we carried out a high-level assessment to highlight where modern slavery risks may exist across our International Shares and Australian Shares asset classes. The assessment flagged exposures to countries and industries where there may be elevated modern slavery risk, which included air freight and logistics companies, food retailers, restaurants, and companies in emerging markets.
While the assessment provided useful insight into where modern slavery risk may exist across our International Shares and Australian Shares asset classes, it reinforced the role of our investment managers in incorporating both ESG and modern slavery risk into their investment process.
In 2023/24, we circulated a modern slavery questionnaire to the majority of our investment managers across all asset classes, to help assess their practices. This questionnaire is supplementary to our due diligence as part of the ongoing monitoring of our investment managers. Their response helps us to determine to what extent modern slavery is incorporated into their processes.
Our assessment shows the majority of our investment managers have established good governance practices and have adequate controls in place to identify and assess modern slavery risks within their business operations. Some practices were more mature than others with, for example, established remediation processes. However, we would expect this to improve over time. For our investments, the assessment focused on the investment manager’s process and approach to identify, assess and manage modern slavery risk factoring in the industry and country-level exposure. Based on responses, the majority of the investment managers demonstrated sufficient and, in some cases, leading practices. There were also some investment managers where opportunities for improvement were identified. Actions will be taken over the next 12 months to engage with these investment managers.
For our unlisted property portfolio, we understand the risk of modern slavery extends to the indirect workforce employed through their supply chain, particularly the cleaning industry which the Australian Government has identified as high-risk. Globally, the industry is also considered a high-risk sector for modern slavery, with labour exploitation well-documented. With around 140 000 people employed around the country, the workforce includes vulnerable members of the community who are more likely to subjected to exploitation.5 According to the Australasian Centre for Corporate Responsibility, 85% of the cleaning workforce in CBD office buildings and in retail malls are international students or temporary workers.6
To help manage this risk, four out of five of our Australian property investment managers are active members of the Cleaning Accountability Framework (CAF). CAF partners directly with the Australian Human Rights Commission and the Australian Government’s Fair Work Ombudsman alongside property owners, building managers and cleaning contractors. They uncover and remediate labour rights violations, and consistently assess modern slavery risks within the supply chain. CAF ensures conditions for decent work are in place ranging from procurement to fair policies, procedures, training and job security. They liaise directly with all stakeholders to ensure that common exploitative practices are not present, such as withholding wages, immigration-related coercion, and dangerous working conditions; and work to ensure all cleaners have the right to work that’s fairly paid, safe and secure by lifting labour standards across the supply chain.
Understanding the risks of modern slavery outside of our operations and supply chain
We acknowledge that our operations could be connected to modern slavery through the companies we have indirect relationships with outside of our direct suppliers.
For example, our Perth office is partly owned and managed by Mirvac. However, our tenancy agreement is with a third party, not Mirvac. In managing our building, Mirvac employs contract cleaning services, an industry that carries high risks of modern slavery in Australia due to its reliance on low-wage, temporary and migrant labour. In recognition of this exposure, we have taken steps to understand how Mirvac is addressing modern slavery risks.
In 2023, Mirvac became members of the Cleaning Accountability Framework (CAF), which allows it to select properties to be assessed for ethical labour practices. This also provides an opportunity for Mirvac to be a part of ongoing discussions with all stakeholders (including union representing cleaners) to raise issues and contribute to the remediation of each issue through action.
Our policies support our practices
We have several policies in place to ensure we adopt good governance and operate in a responsible manner, including addressing the risks of modern slavery.
These policies are covered as part of our induction of new staff and reinforced through regular training and information sessions:
Our Risk Management Strategy facilitates the management of all risks that may adversely impact our members, staff, assets, operations and outsourced service providers.
Our Governance Framework includes an outline of the structures, activities, instruments and monitoring arrangements that have been adopted to comply with legislation and other obligations.
Our Environmental, Social and Governance (ESG) and Responsible Investment Policy describes how we incorporate ESG factors into investment decisions. This includes climate change, human and labour rights, and modern slavery. Learn more about our responsible investing approach.
We have a Code of Conduct that sets standards for ethical and accountable behaviours in our workplace.
Our Integrity Framework has many benefits including managing identified integrity risks, promoting integrity, preventing misconduct and corruption, and informing stakeholders about our approach to integrity.
Our Whistleblowing Policy facilitates public interest disclosures by our staff, contractors or members of the public, which can be made anonymously to our Public Interest Disclosure Officer.
Our Dignity at Work Policy reinforces the expectation for all staff to model appropriate workplace behaviours and take care that their actions do not harm or exclude others.
Our Workplace Inclusion Network promotes and supports diversity and inclusion in our workforce, representative of the members and community we serve.
Further support for our modern slavery risk management practices
In support of our Risk management strategy, we have an established Anti-money Laundering and Counter Terrorism Financing (AML/CTF) Program.
This program:
- Complies with the requirements of the Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) Act 2006 as regulated by the Australian Transaction Reports and Analysis Centre (AUSTRAC)
- Includes transaction monitoring, ongoing customer due diligence controls for members sanctions and reporting of suspicious matters, and cross border monetary movements for membersresiding in foreign countries
- Considers the risks we face in relation to money laundering and terrorism financing, which are critical in identifying and addressing ongoing modern slavery risks, given the nature, size and complexity of GESB, and our reliance on third-party service providers
- Includes employee due diligence which involves activities associated with assessing and managing the integrity risk of our employees
This program is independently reviewed every two years, with activities reported to our Board quarterly.
6. How we assess the effectiveness of our actions
Our working group tracks the effectiveness of the actions we have taken to manage the risks associated with modern slavery in both our internal operations and supply chain.
During the previous financial year, we focused on creating and implementing processes to assess modern slavery risks. In this third reporting period, we agreed on our actions to assess risks for the 2023/24 reporting period. The progress of these actions are as follows:
Here’s our progress in 2023/24 in terms of actions taken.
Supply chain and procurement
- We continue to consider the use of modern slavery clauses in our procurement processes, embedding these clauses into contracts where practicable. As of August 2024, State Government procurement processes included a modern slavery clause as part of the general conditions of the contract
- The modern slavery risk assessment includes suppliers reviewed in the last 12 months with the exception of online subscriptions as they fall outside the scope
- The risk assessments for 2023/24 include those suppliers assessed in the previous reporting period
Operations and governance
- We meet regularly to consider matters relating to the modern slavery risks of our operations and supply chains, the working group met six times during 2023/34 reporting period and reviewed the working group chart
- We continue to keep the Board updated on the working group’s actions and findings. Our Risk and Compliance team provides quarterly reports that cover project and procurement risk assessments, as well as Country and Modern Slavery Risk Assessments
- We are currently updating procedures to reflect enhancements to the way we assess modern slavery risk, related to our suppliers, and the countries they operate in, as well as countries our investments are located in
- We believe our third Modern Slavery Statement aligns with the requirements of the Modern Slavery Act 2018 (Cth) and better practice guidance
- We continue to educate staff on modern slavery risks and compliance obligations, through all-staff information sessions and the requirement to complete an ESG module in ongoing compliance training
- As part of our compliance program, we regularly review our policies. Where relevant, we aim include human rights considerations, particularly in our human resources practices aligned with Public Sector Standards and the Code of Ethics
Investments
- We continue to explore opportunities to collaborate on ESG issues, including investor groups focused on companies' human rights practices
- We continue to enhance our approach to assessing modern slavery risks in our investments and report on our progress. Responses to our questionnaire show improvement in our investment manager’s processes and understanding of modern slavery risks
Agreed actions for 2024/25
In the 24/25 financial year, we are seeking to expand our approach and refine our procedures.
We will continue to evolve our approach with a focus in the following areas:
Supply chain and procurement
- Continue to consider the use of modern slavery clauses in our procurement processes
- Review risk assessments for all suppliers that have already been assessed as part of regular contract reviews
Operations and governance
- Meet regularly to consider matters relating to the modern slavery risks of our operations and supply chains
- Continue to report the working group’s actions and findings to the Board
- Maintain a Modern Slavery Statement with information that aligns with the requirements of the Modern Slavery Act 2018 (Cth) and better practice guidance
- Continue to educate our staff on modern slavery risks and compliance obligations
- As part of our compliance program, continue new and ongoing reviews of our policies and procedures to ensure our approach embeds human rights
Investments
- Deepen our understanding of modern slavery risks through maintaining awareness of industry best practice and efforts undertaken by collaborative investor groups
- Continue to enhance our considerations of modern slavery risks in our investments through our engagement with our investment managers and reporting on their engagement activities around human rights issues
- Engage with investment managers, where there were opportunities for improvement identified
We recognise that our review and assessment of our actions to identify and address our modern slavery risks in our operations and supply chain will be an ongoing and evolving process.
1 Walk Free Foundation, Global Estimates of Modern Slavery: Forced Labour and Forced Marriage, available at www.walkfree.org/reports/global-estimates-of-modern-slavery-2022.
2 World Economic Forum, Modern slavery is increasing – 1 in every 150 people are victims, available at https://www.weforum.org/stories/2022/09/global-modern-slavery-trafficking
3 Walk Free Foundation, Modern Slavery in Australia, available at https://www.walkfree.org/global-slavery-index/country-studies/australia.
4 Following the reporting period, we sold the remaining Russian security although maintain a small exposed to the Russian Ruble resulting from the transaction.
5 Skills One, Clean as a Whistle, available at https://www.skillsone.com.au/vidgallery/clean-as-a-whistle.
6 The Australasian Centre for Corporate Responsibility, Cleaning up their Act?: Modern Slavery Due Diligence in the Australian Property Sector, available at https://www.accr.org.au/research/cleaning-up-their-act.
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