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What is modern slavery?

Many people think of slavery as a blight on people’s human rights from the distant past. Unlikely as it seems, slavery still exists in many parts of the world today, especially in modern workplaces.

Modern slavery is not just about poor working conditions or underpaying workers – although these practices are common in all forms of slavery.

For Modern Slavery to occur, workers must have been coerced, threatened or deceived to deprive them of their human rights through practices such as human trafficking, forced labor or servitude[1].

So what is being done to overcome modern slavery?

In Australia, the Federal Government has introduced the Modern Slavery Act 2018 (the Act) which requires some organisations like us to explain how they respect human rights in their business dealings.

Specifically, these organisations need to develop a Modern Slavery Statement to:

  • assess the risk of slavery in their operations and supply chains, and
  • document what actions they are taking to address those risks through a register of modern slavery statements[2].

The government believes this will help to improve workers’ human rights while providing organisations with benefits such as increased profitability and investor confidence[3]. 

How is CPS dealing with modern slavery?

We have developed a Modern Slavery Statement which outlines how we meet the requirements of the Modern Slavery Act 2018. You can view our Modern Slavery Statement here.

Or you can read some of the key points of our Statement below:

Our supply chains

We rely on third party suppliers to provide products and services to our members.

To ensure we invest responsibly, avoid modern slavery risks and reduce poor work practices in our supply chains, we use an Investment Governance Framework which is overseen by the Investment Committee.

Our Chief Investment Officer is responsible for overseeing our investment strategy by external investment managers both here and overseas to ensure our members’ superannuation is invested in high quality, ethical investments.

Club Plus Super uses environmental, social and corporate governance (ESG) guidelines when we are looking to secure a potential investment. Our investment managers assess not just the opportunities of a particular investment, but also the risks.

These risks could include climate change, resource scarcity, renewable energy and pollution, as well as workplace practices such as modern slavery, social inclusion, and safety.  You can read more about our responsible investing here.

We also engage Australian and internationally accredited contractors who provide fund administration, custodial and professional advisory services, as well as marketing, information technology, facilities and office management and supply services.

Risks in our operations and supply chains

Club Plus Super is committed to human rights. We use policies and processes to help us identify, assess and mitigate risks of modern slavery, such as our:

  • Responsible Investment Policy
  • Code of Conduct
  • Outsourcing policy
  • Risk Management Framework and more.

We regularly conduct high-level assessments of our operations and supply chains to identify where there could be a risk of CPS causing, contributing to, or being directly linked (through its supply chains) to modern slavery.

Actions to assess and address those risks

In 2019/20, we introduced a modern slavery program to address the risk of modern slavery in our operations and supply chains. We took various actions including:

  1. Awareness training for all directors, staff and providers about the risks of modern slavery.
  2. Policies and guidelines changed to reflect modern slavery and our Code of Conduct.
  3. A modern slavery risk survey was sent to investment managers to help identify and mitigate risks of modern slavery when choosing investments.
  4. Incorporating modern slavery considerations into our investing processes.
  5. Conducting due diligence on our products and services to identify areas of risk of modern slavery.
  6. Identify and take action if any suppliers’ activities may have contributed to modern slavery practices.

How did we do?

In this first year of our program, we focused on raising awareness about modern slavery risks internally and with our suppliers, we developed a modern slavery framework and arranged mandatory training for our directors and staff. We also assessed the effectiveness of our framework and are taking a ‘continuous improvement’ approach to our modern slavery program. We will take a risk-based approach to managing our highest risk areas.

What else do you need to know?

We continue to work with other organisations to improve awareness of modern slavery risks by sharing resources and developing practices to reduce the risk of modern slavery with our investment activities. This includes working with ACSI, a leading advocate for ESG awareness and responsible investment practices within Australian listed companies.

Want to know more?

Read our Club Plus Super’s Modern Slavery Statement.