Purpose
CHOICE (the Australian Consumers' Association) is not a reporting entity under the Modern Slavery Act 2018 (Cth) (the Act). While we are not obliged to report under the Act , we take a zero-tolerance approach to slavery and human trafficking. We are committed to ensuring that they do not take place in our supply chains.
This Modern Slavery Statement is intended to inform stakeholders of the risks of modern slavery in CHOICE's supply chains and operations, and assist stakeholders with their due diligence processes as required by the Act.
Defining modern slavery
1. The Act aims to address practices that constitute the use of coercion, threats or deception to exploit victims and undermine their freedom.
2. Practices that constitute modern slavery can include:
- human trafficking;
- slavery;
- servitude;
- forced labour;
- debt bondage;
- forced marriage; and
- child labour.
3. While CHOICE does not condone other practices that may be harmful to workers, such as sub-standard working conditions and underpayment, these areas are not generally included within the definition of modern slavery.
CHOICE's operations
CHOICE is a not-for-profit organisation with the purpose of working towards fair, just and safe markets that meet the needs of Australian consumers. We do this through campaigning, investigative journalism, testing and reviewing products and services, and producing information and tools to assist people to make choices and exercise their rights. We consider the sectors in which we operate and the associated supply chains to be at low risk of slavery.
CHOICE's operations are mainly based in Sydney. We employ approximately 160 staff who all normally work within Australia. During 2021–22 some work was performed by team members who were employed by a supplier based in Manila, Philippines.
We undertook an initial process review in 2022 to ensure we were compliant with the Act. No breaches of the Act were identified or reported during the year.
CHOICE's supply chains
CHOICE procures the following goods and services:
- Goods: systems software and hardware, appliances and electronics, general office supplies, publications and office equipment.
- Services: office cleaning, printing services, digital marketing services, insurance, legal services, consulting services, internet and telephone services, professional memberships, third party offshore employment services and travel services.
CHOICE has several regular suppliers from whom most services are sourced. Some other supplier arrangements are one-off in nature. Most suppliers of services to CHOICE are based in Australia. The main exception to this was a supplier based in the Philippines who employed two web developers who worked alongside CHOICE staff during 2021–22.
Supply chain risks
As at the date of this Statement, CHOICE has conducted a preliminary audit of its supply chain, encompassing those categories of goods and services identified above, with a focus on ascertaining sector/industry risks, product/services risks, geographic risks and entity risks within our supply chains.
The results from the preliminary audit are as follows:
a) Sector and Industry risk – CHOICE has identified the office cleaning sector as one that has a high risk of exploitation, including modern slavery risks. CHOICE has taken action on this as set out below.
b) Product and Services risk – CHOICE has identified its electronics products as products with a high risk of modern slavery practices. This risk only relates to computer equipment used by CHOICE.
c) Geographic risks – CHOICE had a supplier in 2021-22 that operates partly from the Philippines. Given that the Philippines has a lower rating than Australia under the Global Slavery Index we made a number of enquiries to assess modern slavery risks.
d) Entity risks – CHOICE have not identified any organisation with whom we obtain goods or services that have any particular modern slavery risk.
CHOICE is in the process of compiling and reviewing a full list of suppliers, to assist with identifying any further risks. This will be reviewed on a regular basis.
Actions to address supply chain risks
CHOICE is in the initial stage of identifying and remediating modern slavery risks within its operations and supply chain. As at the date of the Statement, CHOICE's primary focus is identifying and remediating supply chain issues that pose the highest risks in respect of modern slavery.
Actions to address supply chain risks are as follows:
Action 1 – Enquiries with Philippines entity: This entity is an employer of professional services staff and provided professional support to CHOICE in the form of two software developers who worked alongside CHOICE employees. We verified that this entity has taken steps in regards to modern slavery practices including by having established an Anti-Modern Slavery Governance Committee, trained staff regarding modern slavery, internally audited their practices for modern slavery risks and taken steps in recruitment process to ensure that candidates' documentation is returned.
Action 2 – Enquiries with office cleaning company: CHOICE made enquiries with the provider of office cleaning services regarding their modern slavery protocols and were satisfied with the responses, which included confirmation that:
- the entity has a modern slavery statement and policies and procedures to address modern slavery risks
- it provides targeted modern slavery training for both managerial and non-managerial staff
- it has established a steering committee to address modern slavery risks.
Action 3 – Confirming modern slavery statements for electronics suppliers: CHOICE confirmed that major suppliers of computer equipment have published modern slavery statements.
In 2022–23, CHOICE will implement mandatory awareness training for relevant staff on modern slavery risks and the objectives of the Act.
Assessing effectiveness of actions taken
Given that CHOICE is in the initial stage of implementing measures to identify and remediate modern slavery risks within its supply chains and operations, we have not yet implemented a formal system to assess the effectiveness of the actions taken to date.
CHOICE will continue to take actions to identify and address modern slavery risks and will report on further actions and our assessment of their effectiveness in our 2022–23 Modern Slavery Statement.
Other relevant considerations
CHOICE has also assessed its own employment and hiring practices and notes the following:
- Use of temporary visas: CHOICE is an approved business sponsor for the purpose of employing individuals when we are unable to find staff in the local market. CHOICE ensures that all legislative requirements (in respect of employment law obligations and immigration law obligations) are met in regards employing visa holders.
Further information
If you require further information in regard to any aspect of this Statement, our Director, Commercial and Finance is the appointed individual at CHOICE responsible for overseeing our approach to preventing modern slavery. They may be contacted at modernslavery@choice.com.au.
Any employee, supplier or stakeholder wishing to report modern slavery may do so using the process in our Whistleblower Policy.
Date of Statement: 23 September 2022
Stock images: Getty, unless otherwise stated.
