Slavery and Human Trafficking Statement Australia
This Modern Slavery Statement is a joint statement on behalf of SGS Australia Pty Ltd and the Australian related entities mentioned below (“SGS Reporting Entities”) for the financial year ending 31 December 2019.
- SGS Australia Pty Ltd (ACN 000 964 278)
- SGS Scientific Services Pty Ltd (ACN 008 736 221); and
- SGS Systems and Services Certification Pty Ltd (ACN 060 156 014)
This is our first Modern Slavery Statement. It sets out what SGS Australia did in 2019 to ensure that slavery and human trafficking did not take place in our supply chains or in any part of our business. It also sets out the SGS Group’s actions and our current plans.
The Modern Slavery Statement was developed by the SGS Reporting Entities in consultation with each of the wholly owned subsidiaries of SGS Australia (collectively referred to as “SGS Australia”). All SGS Australia entities are subject to SGS Australia policies and systems and are also part of the wider SGS Group arrangements. The contents of this Modern Slavery Statement are, accordingly, applicable to all SGS Australia entities.
Group Structure, Operations and Supply Chain
SGS is the world’s leading inspection, verification, testing and certification company. With more than 89,000 employees, SGS operates a network of over 2,600 offices and laboratories in more than 125 countries, helping to ensure quality and integrity of products and systems.
SGS SA is the ultimate parent company of SGS Australia and the SGS Group.
SGS draws on the services of global, regional and national suppliers. As a responsible major purchaser, SGS ensure that goods and services are sourced sustainably and that our suppliers respect human rights. Our Procurement Policy details the key principles, criteria and guidelines for all contracting activity and supplier selection across the Group. It also defines supplier requirements associated with quality, value, efficiency and human rights. SGS Australia’s supply chain is quite diverse and geographically dispersed, and through structured sourcing processes, we select the best option for SGS while continuing to support local suppliers that meet our business and sustainability requirements. Over 75% of our annual spend goes on regional and local suppliers, which demonstrates our dedication to supporting the communities in which we operate.
The SGS Group has recently published its SGS 2019 Sustainability Report, which reports on the environmental and societal impacts of our business activities using our Value to Society (V2S) model. Our Sustainability Ambition 2020 is to deliver measurable sustainable value to society. Ensuring human rights are a working reality across our operations and our supply chain is a fundamental part of this ambition.
Modern Slavery Risks Identification
Through the SGS Group’s Risk Management and Governance, Risk and Compliance framework, we are integrating sustainability risks directly into our management process. With this mechanism, the different business lines, functions and affiliates can identify and assess potential sustainability risks from both our direct operations and our supply chain and report the corresponding mitigation actions associated with them.
In parallel, we run a desk annual macro risk assessment of potential sustainability risks in the countries where we operate. This macro risk assessment provides an objective double check of the risk evaluations made by the different business lines, functions and affiliates.
Through this process, we have assessed the risks of modern slavery for SGS Australia, both in our operations and in our supply chain, and including forced and bonded labour, human trafficking, descent-based slavery, servitude and child slavery. The assessment concluded that the residual risk (which considers our mitigation programs described in this statement) is very low.
Modern Slavery Avoidance and Risk Management Mechanisms
Human Rights Policy
SGS SA’s Human Rights Committee is chaired by our Chief Executive Officer and oversees compliance with all human rights in all affiliates of the SGS Group. It has implemented a publicly available Human Rights Policy, which mandates SGS affiliates to protect and respect human rights, including whilst selecting and managing employees, suppliers and business partners.
Our Code of Integrity – Our Employees and Representatives
For many years the entire SGS Group has operated under a publicly available Code of Integrity applicable to all employees, consultants, joint-venture partners, agents, subcontractors and anyone acting on behalf of, or representing, SGS. This Code contains a clear prohibition on child labour and forced labour, breach of which will result in disciplinary proceedings or termination of contracts.
All new employees are trained in the Code of Integrity upon joining SGS and all existing employees and contractors undertake annual refresher courses.
Our Supplier Code of Conduct
SGS has a Supplier Code of Conduct that is publicly available and sets out SGS’s requirement that all suppliers and their suppliers operate a zero-tolerance approach to modern slavery and that non-compliance can result in the termination of our relationship with any supplier. SGS Australia continues to require acceptance and compliance to our Supplier Code of Conduct as part of the engagement and onboarding of any Suppliers to our supply base.
Our Supplier Due Diligence Process
In 2017 the SGS Group began to implement a new procurement system and rationalise our supplier base which in 2018 allowed us to mandate a more detailed self-assessment questionnaire to obtain information from certain new and existing suppliers to enable us to give each an ethical risk rating. In 2019 SGS Australia continued this process by submitting self-assessment questionnaires to targeted Suppliers based on spend and risk. Working with the SGS Group in the assessment of the questionnaires there were no violations identified.
SGS runs an annual Integrity training, which addresses many areas of ethics, trust and human rights and restates the mechanisms by which one can report concerns. It includes topics such as child labour, forced labour, freedom of association and discrimination, working hours, and health and safety. The training is conducted by eLearning and is mandatory to all employees.
Further, the SGS Group is looking for ways to provide human rights training to our suppliers.
For many years SGS SA has had an established Integrity Helpline available to employees and suppliers to enable confidential and anonymous reporting of possible legal and policy violations without recrimination. Reports can also be made directly to the Compliance function in Switzerland or Australia. Details are contained in the Code of Integrity, the Human Rights Policy, the Supplier Code of Conduct, on our internal and external websites and in our integrity training. We remind our staff of the Helpline by which they can report issues involving modern slavery and we highlight the recommended means of escalating perceived issues.
We put mitigation and remediation actions in place whenever a breach of our Code of Integrity is identified through our Integrity Helpline. In addition, we work with high risk suppliers identified through our supplier assessment processes, to develop mitigation and remediation actions.
Effectiveness of Our Mechanisms
SGS Australia did not detect any violations of the Modern Slavery Act within our supply chain or business in 2019. We shall continue to review our operations and supply chain and report on the progress of all modern slavery avoidance initiatives in our Modern Slavery Statement next year.
Further, the SGS Group is committed to the transparent reporting of all our human rights commitments and performance through our Annual Report and our Corporate Sustainability Report.
SGS is currently working on the definition and deployment of various improvements to our human rights mechanisms. In particular, we are working on updating our Integrity training, by integrating intelligence and cases compiled through our integrity helpline and compliance departments during previous years.
In addition, SGS plans to further enhance its due diligence and is evaluating means to better understand exposure to human rights risks at local level and to ensure that adequate mitigation plans are in place.
This Statement is made pursuant to the Modern Slavery Act 2018 (Cth) and has been approved by the Board of Directors of SGS Australia.
On behalf of the Board (signature of Yvonne Dickson, Managing Director)