“Accountability sits with us so that progress can be felt by all.” Alistair Field, CEO & Managing Director, Sims Limited
Corporate Social Governance. Sustainability. Environmental Social Governance. Regardless of the title, each of these addresses the critical need for businesses to ensure they act lawfully and uphold the highest standards of human rights, fair and safe labor, ethics and environmental stewardship as responsible corporate citizens.
At Sims Lifecyle Services (SLS) and our parent company Sims Limited, we aim to achieve these through our 2025 Sustainability Goals, which includes United Nations Sustainability Goal 8- Decent Work and Economic Growth. Key to this is upholding human rights to create a safe and fair workplace for our employees and those of our suppliers. This might sound basic, but sadly, slavery is not confined to history books. Modern slavery exists in many forms for an estimated 40 million people globally, including the 24.9 million people trapped in forced labor. That number includes people being controlled by an employer or forced to work against their will, those in debt bondage and those bought and sold as property. (1) No country is immune, which is why many governments, including Australia and the United Kingdom (UK), require companies to complete due diligence and publicly report on modern slavery in their operations and supply chains.
Sims Limited’s UK operations has published a modern slavery statement since 2018. In 2020 Sims Limited filed our first statement addressing both the UK and Australian Modern Slavery Acts, detailing how we’re combating this today and what we plan to do in the future.
All employees are trained on the polices aimed to combat modern slavery. The Sims Code of Conduct defines commitments we have towards human rights, a safe and healthy workplace, competitive renumeration, and the responsibilities of our employees, directors and executives to upholding these in the workplace. It also details the various ways employees can confidentially report breaches to the code. Our Human Rights Governance policy details our commitment to the prohibition and elimination of child, forced and compulsory labour and discrimination, and ensures freedom of association, decent and safe working conditions, a living wage and fair terms of employment.
In FY21 Sims Limited launched an employee campaign to increase awareness of the existence and scope of modern slavery and how it could manifest in our business. Because employees in procurement, human resources and site management are more likely to encounter modern slavery, targeted content was also created specifically for them. High risk supplier industries and geographies are particularly vulnerable to modern slavery, and, at the same time, more challenging to manage. We embedded a Supplier Code of Conduct in our standard terms and conditions and existing high-risk supplier agreements.
At SLS we are proud of the vigorous due diligence undertaken by our global subcontractor management team. Our current process includes regular on-site audits supplemented by annual desktop audits. Audits always included working conditions, child labor and compensation, and were recently expanded to include risks such as sourcing of employees and conditions of employment. We also updated the on-site audit checklist to include visible signs of modern slavery, like on-site sleeping quarters, unnecessary restrictions on freedom of movement such as locked emergency exits and signs of abuse, including being unable to make eye contact or speak freely.
During COVID-19, as human rights abuses escalated globally but were increasingly difficult to monitor, SLS ensured our robust subcontractor audits continued. In addition to the 26 on-site visits undertaken in FY21, 192 vendors were audited remotely, covering 68% of our active subcontractors. The remaining vendors underwent desktop reviews and quarterly review meetings.
Subcontractor management is a priority for 2022. We’re broadening the human rights sections of our subcontractor auditing process and strengthening our management of temporary labour providers. This will ensure that we understand how they protect human rights and prevent abuses in their supply chain by auditing records, updating contracts and providing targeted ethics and compliance training and support where needed.
More broadly, we’ll be strengthening our public commitment to UNSDGs by joining over 15,000 CEOs and signing the UN Global Compact, whose ten principles support the advancement of human rights, labor, environment and anti-corruption in global business. Through a combination of due diligence and accountability we will continue to ensure modern slavery is not used in our supply chain. And we’ll be transparent with our clients, shareholders and communities every step of the way.