Modern Slavery Statement - FY2019-2020
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Contents Introduction 3 Family and Disability Services 9 Our approach 3 Joint venture partnerships 10 Key areas of focus for 2019/20 3 Our supply chains 11 Key areas of focus for 2020/21 3 Modern slavery risks 13 About UnitingCare 4 Due diligence and remediation 15 Our values 4 Operational due diligence 15 Our mission 5 Supply chain due diligence 16 Policies 6 Grievances and remediation processes 16 Our operations 8 Training 16 Blue Care and ARRCS 8 Effectiveness measures 17 Hospitals 8 Modern Slavery Statement FY2019–2020 2
Introduction UnitingCare opposes Key areas of focus for 2019/20 exploitative practises that • Conducting a scoping exercise to map our supply chains and operations, assess our risks violate an individual’s dignity of modern slavery and identify measurable and human rights in all forms. actions to address these risks. • Maturing our supply chain risk assurance As an outreach of the Uniting Church, our mechanisms by introducing a Supplier Code of mission is to improve the health and wellbeing Conduct, contractual provisions for adherence of individuals, families and communities as we with modern slavery laws and supplier risk speak out for fairness and justice, and care with assessment tools. compassion, innovation and wisdom. UnitingCare • Implementing a Human Rights Policy to is committed to act in a way that upholds the strengthen our approach on preventing intrinsic worth and dignity of every person at modern slavery risks. every stage of life and in every circumstance • Developing and implementing a Modern of life regardless of race, age, gender, beliefs or Slavery Action Plan FY2019-20 to direct economic status. our efforts to eradicate modern slavery in This statement is submitted as a joint statement connection to UnitingCare. in accordance with the Modern Slavery Act 2018 (Cth). It is submitted by UnitingCare Key areas of focus for 2020/21 Queensland on behalf of itself and UnitingCare • Assessing risks of modern slavery associated Community, UnitingCare Health and Blue Care with new and recontracted suppliers, and which represent The Uniting Church in Australia expanding the use of our supplier risk Property Trust (Q.) and UnitingCare’s associated management tools to ensure procurement entity Australian Regional and Remote and supplier due diligence. Community Services Ltd (ARRCS). It describes the steps taken by UnitingCare (including ARRCS) • Development of UnitingCare’s Modern to prevent, detect and respond to modern Slavery Strategic Roadmap. slavery risks in our operations or supply chain • Building supplier capacity to respond to during the financial year ending 30 June 2020. modern slavery through awareness-raising The modern slavery risks and impacts associated and training. with UnitingCare’s joint venture, Leap In! are • Providing training for staff to recognise, not included in this Statement. UnitingCare prevent and respond to concerns of does, however, have joint venture governance modern slavery, both in our operations processes that involve regular engagement and and supply chain. oversight of key risks. • Increasing collaboration within our networks, and with our partners, to strengthen our Our approach response to modern slavery. Our first statement was developed in consultation with UnitingCare’s business units and support functions. In early 2019, we established a taskforce to oversee and implement our modern slavery assessment and prevention strategy. Work was overseen, sponsored and endorsed by UnitingCare’s Executives and approved by the UnitingCare Queensland Board. Modern Slavery Statement FY2019–2020 3
About UnitingCare UnitingCare Queensland was established by UnitingCare is the health and the Queensland Synod of the Uniting Church in community services arm of the Australia, and is governed by the UnitingCare Queensland Board with certain matters reserved Uniting Church of Australia in for the Queensland Synod. Queensland. We are committed UnitingCare employs approximately 17,000 people to empowering and improving and is supported by 9,600 dedicated volunteers. ARRCS employs approximately 718 people and the health and wellbeing of is supported by 68 dedicated volunteers. As one vulnerable individuals and of Queensland's largest employers, UnitingCare proudly represents some well known brands and those in need to live life in all services that engage daily with people from all walks of life across Queensland and the Northern its fullness. Territory. In addition to our family and disability services provided by UnitingCare, our family of brands includes: Blue Care; Lifeline; The Wesley Hospital; St Andrew's War Memorial Hospital; Buderim Private Hospital; St Stephen's Hospital; and ARRCS. Our Values We believe the following values are fundamental to the work we do and the way we work together: Compassion Respect Through our understanding and We accept and honour diversity, empathy for others we bring uniqueness and the contribution holistic care, hope and inspiration. of others. Justice Working Together We commit to focus on the We value and appreciate needs of the people we serve the richness of individual and to work for a fair, just and contributions, partnerships sustainable society. and teamwork. Leading through Learning Our culture encourages innovation and supports learning. Modern Slavery Statement FY2019–2020 4
Our mission Our mission is expressed in seven mission practices: Our mission is to improve the health and wellbeing of individuals, families and We demonstrate the worth and dignity of every person communities as we: We walk together with First Peoples reach out to people in need; We participate in God’s healing power to the whole person speak out for fairness and We cultivate practices centred justice; and on people and relationships care with We value reflective action compassion, innovation and wisdom. We are faithful stewards of the resources entrusted to us We stand up for what is fair and just Modern Slavery Statement FY2019–2020 5
Policies Our commitment to mitigating the effects of modern slavery is upheld by our frameworks, policies and procedures. These include but are not limited to UnitingCare’s: • Risk Management Framework: which adopts • Recruitment Policy: which describes the a risk-based approach to our operational agency practice verification processes required and supply chain risk management planning, before employment agencies will be retained key decision making and observance of to source employees both permanently and compliance obligations. on short term contracts. This requires that there is an adherence to our Code of Conduct • Code of conduct: which outlines the and compliance with relevant legislative principles of expected behaviour and conduct requirements. of UnitingCare employees, volunteers and contractors. The Code is aligned with legal, • Investment Management Strategy: which professional, social and ethical expectations, outlines our ethical investment principles, and the values of UnitingCare. These as guided by the Queensland Synod’s Ethical expectations extend to the principles that Investment Policy. This Policy prohibits our underpin a legal and ethical rejection of participation in investments that cause social modern slavery. injury for activities that denigrate personal dignity, inhibit human rights, exploit people • Human Rights Policy: which outlines our financially and/or damage human health. commitment to ensuring our actions and decisions are consistent with respecting and • Procurement and Supplier Contract upholding the human rights of all persons. Management Policy: which provides for our This includes a person’s right to protection socially responsible and ethical procurement from slavery. Under this Policy, we also seek to practices. Procedures and associated tools establish relationships with entities that share and systems are being progressively updated the same principles as UnitingCare. to improve due diligence and remediation practices to and management of modern • Whistleblowing Policy: which supports our slavery risks. people to observe high standards of good governance and ethical behaviour, and feel • Supplier Code of Conduct: which outlines supported to safely disclose matters which our expectation that our suppliers will act in a may be inconsistent with modern slavery laws. manner that is consistent with the principles UnitingCare also has a whistleblower integrity for socially responsible, sustainable and ethical hotline which is accessible by our employees, business practices and that these principles volunteers, contractors, consultants, suppliers are adopted throughout their supply chains. and their relatives, dependents or spouse. Modern Slavery Statement FY2019–2020 6
Our operations Our services extend to all walks of life across Queensland and the Northern Territory and are managed operationally through three business streams; Aged Care and Community Services (Blue Care and ARRCS); Hospitals (UnitingCare Hospitals) and Family and Disability Services (UnitingCare). During the course of the financial year ending Lifeline and our Family and Disability 30 June 2020, we supported more than 600,000 Services. We operate in the Northern Territory people across 460 locations to live life in all its through Australian Regional and Remote fullness. UnitingCare operates in Queensland Community Services. through Blue Care, The Wesley Hospital, We also have joint venture for Leap in! St Stephen’s Hospital, St Andrew’s War Memorial Australia Limited between UnitingCare and Hospital, Buderim Private Hospital, Blue Care, Uniting (NSW/ACT). Operations overview: Aged Care and Community Services 8,900 employees and 1242 volunteers Provides in-home care, residential aged care, disability services, independent and supported retirement living, 57 aged care facilities with private hospital services through Blue Care and ARRCS. 3,785 residential beds 66,000 community clients Hospitals 4,300 employees and 626 volunteers Provides a comprehensive range of private medical services through The Wesley Hospital, St Stephen’s Hospital, St Andrew’s War Memorial 4 hospitals with 1065 beds Hospital, Buderim Private Hospital. Operates the Helena Goldie project in conjunction with UnitingWorld in 144,000 admissions the Solomon Islands to teach nursing students and to provide equipment. Modern Slavery Statement FY2019–2020 8
Family and Disability Exported 7,400 tonnes of clothing Services donated to Lifeline to overseas communities Papua New Guinea, Provides supported independent Vanuatu, Fiji and Dubai living, foster and kinship care, family and children’s counselling, early education, crisis support, allied health and retail of donated goods through 2,600 employees and 7,600 volunteers UnitingCare Family and Disability Services and Lifeline. 188 Family and disability facilities 128 Lifeline stores and 11 warehouses 383,000 people receiving care Outsourced operations IT support and systems maintenance for UnitingCare are delivered through a Managed Service Provider from Bangalore and Chennai in India, Manilla in the Philippines as well as Brisbane. UnitingCare Procurement Typically, our high value high risk expenditure UnitingCare’s procurement and contract spend is centrally managed through a category management activities are delivered management approach. We also leverage the through a centre-led procurement benefits and opportunities of collaborating with operating model in partnership with other organisations. business units and support functions. 5+47+2622A Figure 1: Percent of spend by Approximately 10,000 suppliers business area $600m total spend 5% 22% 75% of total spend is through long term supply arrangements with approximately 200 suppliers 47% 26% 17 suppliers engaged through UnitingCare Hub network 47% Uniting Care Hospitals 3 suppliers engaged through 26% Blue Care Queensland Government standing 22% Support Functions offer arrangements 5% Family and Disability Services Modern Slavery Statement FY2019–2020 9
UnitingCare Chaplaincy 7 marriage ceremonies performed Provides counselling and wellbeing services and marriage ceremonies. Leap in! Australia Limited 34 employees Provides NDIS plan management via a digital-based platform. 4,000 customers Modern Slavery Statement FY2019–2020 10
Our supply chains UnitingCare manages approximately 10,000 suppliers with a total spend in excess of $600 million. 11+51+38A Our supply chains are diverse, with goods and Figure 2: Spend by category services being purchased from both domestic suppliers in remote regional and metro areas as well as international suppliers in the Asia- Pacific region, North, South and Central America, 11% Europe, the Middle East and Africa. Our spend categories 38% The purchase of medical goods, services and equipment is our largest category of spend 51% making up 51% of our spend (~ $310 m). Spend within the medical category comprises the following sub-categories: • Prosthetics ~ 34% • Medical Equipment ~ 27% • Medical Services ~ 20% 51% Medical • Medical Consumables ~ 14% 38% Non-medical 11% Tail spend • Pharmaceuticals ~ 4% • Other ~ 1% The non-medical category makes up 38% of our spend (~ $230m) and comprises the following Modern slavery is the sub-categories: antithesis of our mission to • Professional Services ~ 32% ensure people “live life in all • Facilities Management ~ 25% • Information Technology ~ 23% its fullness”. We are committed • Food and Beverage ~ 5% to taking meaningful actions • General Equipment and Supplies ~ 4% to ensure modern slavery and • • Transport ~ 3% Utilities ~ 3% human trafficking does not • Fleet ~ 3% exist in our organisation and • Marketing and Advertising ~2% supply chain. Modern Slavery Statement FY2019–2020 11
Modern Slavery Statement FY2019–2020 12
Modern slavery risks The practises which constitute modern slavery include trafficking persons, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruiting for labour or services and child labour. During the financial year ending 30 June 2020, an organisation-wide risk assessment was Identified risk areas undertaken for modern slavery risks both within Through the risk assessment, UnitingCare UnitingCare and in our supply chains. Our focus identified a number of key modern slavery risks centred on risks that may cause, contribute and/ within our operations and supply chains. These or be directly linked to modern slavery practices included 14% being assessed as high risk, 39% with the management of identified risks treated as medium and 47% as low. These have been according to our Risk Management Framework. prioritised according to the severity of the potential impact and likelihood of the risk. The process we undertook included: Figure 3: UnitingCare Modern Slavery Operations Risk Management • Within our treasury, fundraising, Mission and overseas crisis support operations there is a low risk exposure that UnitingCare may cause, 1. Modern contribute and/or be directly linked to modern Slavery risk slavery practices through the bequests and 5. Reporting, scoping and donations we receive or investments we hold, escalating context exercise. workers we engage overseas through external and providing assurance of agencies or chaplaincy services such as forced controls marriage officiation. These were largely UnitingCare assessed as low risk due to the stringency and 2.Enterprise- Modern wide ident- rigor of our due diligence, engagement terms Slavery Risk ification and and governing policies and procedures. 4.Develop- Management assessment ment of action of key risks • Procurement: some medium or high risks were plans, mitigation identified for HealthCare, Strategic Properties strategies and and Technology procurement activities ownership 3.Evaluation, operating outside UnitingCare’s centralised treatment and procurement arrangements. prioritisation key risks Modern Slavery Statement FY2019–2020 13
Supply chain • Offshore vendors: Asia-Pacific, North America Supply chain scoping exercise and Europe are all subject to contemporary UnitingCare conducted an initial scoping forms of modern slavery. Our high-risk spend exercise to provide a starting point to categories, operating mainly from these better understand our suppliers and regions include: develop due diligence systems and processes for ongoing management - Medical consumables and equipment of modern slavery risks across our - ICT hardware supply chain. - furniture Based on spend and assumed modern - building, construction and facilities slavery risk, a sample of suppliers were management engaged to participate in the exercise - cleaning services and products and complete a detailed online - food and beverage self-assessment. - apparel Key findings included: - waste management. • A high proportion of suppliers operate • Additional risk assessment is underway with globally and source products and regard to the preference for specific goods services from diverse geographic or services purchased directly by our health locations with 40% operating in high- service partners and clients who are not risk countries and regions. within our procurement control environment, • A high proportion of suppliers outsource to determine if modern slavery risk had been manufacturing and/or distribution appropriately considered. This activity is and do not have codes of conduct or included in our operational risk actions plans modern slavery clauses in contracts to manage any risk exposure. which increases risk of modern slavery • Risk were also identified for purchases infringements. made directly by our clients under their • The majority of suppliers do not identify funding arrangements. Arrangements with modern slavery as a risk in operations or these suppliers are often short-term or one supply chains however more than half off and include high-risk industries including source high risk commodities from high gardening services, hairdressing services, risk locations. equipment supply and furniture. • The verification and monitoring of supplier modern slavery risk levels was low. • Overall, suppliers scored lowest in risk management, training and reporting categories which increases risk within operations and supply chain. These findings informed our approach to modern slavery risk management and our Modern Slavery Action Plan. Modern Slavery Statement FY2019–2020 14
Due diligence and remediation Actions taken to assess and address modern slavery risks Operational risks were identified as part of Operational due diligence the scoping exercise and risk assessments The steps we have taken to assess and mitigate were managed through existing internal risk risks within our operations include: frameworks, policies and procedures, including • establishing a modern slavery taskforce with due diligence processes and the external representation from all key business areas and regulation assurance. Improvements are underway to leverage the UnitingCare Modern support functions. Slavery training and awareness program. • a scoping exercise to map our supply chains and operations, and assess our risks of In business streams that operate outside the modern slavery. centralised procurement function’s supplier network, risk action plans are under development • the development and implementation of our to mitigate this risk exposure. Active Risk Actions Modern Slavery Action Plan FY2019-21. Plans include contemporary risk assessment • the review and improvement of existing tools, leveraging the existing procurement team policies and procedures, including the Code of procedure relating to due diligence, contract Conduct, Procurement and Supplier Contract clauses and third party-software solution to Management Policy, Whistleblowing Policy assess high risk suppliers. and grievance mechanisms. As part of our Risk Action Plan mitigation • the development of new policies and strategies, we will seek to ensure relevant staff procedures, including the Supplier Code of are aware of them as a part of training. Conduct (Supplier Code) and the Human Rights Policy and Procedure. • the review of training and education programs, including onboarding. • the completion of risk assessments with key stakeholders from across UnitingCare’s operations. Modern Slavery Statement FY2019–2020 15
Supply chain due diligence Grievances and remediation The steps we have taken to assess and mitigate processes modern slavery risks have focused on maturing UnitingCare is committed to the protection and our supply chain assurance program through the respect of human rights across our business and implementation of a Supplier Code, contractual supply chain. Where we identify that UnitingCare provisions for adherence with modern slavery has caused or contributed to adverse impacts laws and the implementation of supplier risk such as modern slavery, we will seek to address assessment tools. Due to the large number of human rights grievances in line with relevant our suppliers, efforts were focused on strategic policies and procedures. suppliers that present an elevated risk of exposure. UnitingCare has a number of mechanisms for The Supplier Code is communicated to suppliers as employees and third parties to anonymously part of our tender process and is incorporated into report suspected or actual illegal activity or our due diligence process. Activities undertaken breaches of UnitingCare policies, including under as part of this process help us to identify potential our staff and Supplier Code, Whistleblowing areas of risk, and, where identified, the supplier will Policy and Human Rights Policy. be referred for further due diligence with impact on UnitingCare’s procurement decisions. Employees and third parties have access to our Integrity Hotline which is operated by an To assist with our due diligence assessments, independent third-party or can raise concerns via we have implemented a third-party software our website. UnitingCare supports anonymous solution that assists with category, supplier, reporting through these means. and product level risks assessments. Where a potential risk is evaluated as high, Where risks are identified in our supply chain, supplier assessment questionnaires can be UnitingCare’s preferred approach is to work with undertaken in the system to facilitate a more suppliers to develop a corrective action plan detailed assessment. with agreed timeframes rather than terminating supplier arrangements. High risk suppliers are monitored and reported on an ongoing basis through the third-party software solution. The alerts feature reports Training on any publicly available potential adverse Internal and external awareness of the existence information which we assess and respond to of modern slavery and how to spot the signs has as required. been facilitated. Management have participated New and renewed supply agreements include in modern slavery workshops for the oversight modern slavery and Supplier Code clauses. This and management of modern slavery risks. requires, amongst other things, that suppliers The development of formalised modern slavery and their third-party suppliers, adhere to the training will be a key focus for UnitingCare’s principles in the Supplier Code, implement due next reporting period to enable strengthened diligence processes and take reasonable steps to recognition, prevention and responses to modern minimise modern slavery risk in their operations slavery risks. or supply chain. The Supplier Code has been communicated We will continue to explore opportunities to key stakeholders and to new and renewed with our suppliers to improve how we identify, contracted suppliers to ensure understanding assess and mitigate modern slavery risks within and participation in reducing risk of modern our supply chain and build them into policies, slavery. Our top 20 high-risk strategic suppliers procedures and training. were also provided with a modern slavery education module. Expanding our supplier education and engagement activities will be a key focus for UnitingCare’s next reporting period. Modern Slavery Statement FY2019–2020 16
Effectiveness measures Our Mission at UnitingCare drives our response to modern slavery. The key principles underlying our response include: Worth and Dignity: We act in a way that upholds Metrics used to monitor our progress include: the intrinsic worth and dignity of every person • the number of modern slavery risk mitigation at every stage of life and in every circumstance actions overdue of life, regardless of race, age, gender, beliefs or economic status. When we make decisions, • the percentage of contracts that include we consider and document its impact on modern slavery clauses human rights. • the percentage of supplier meetings that Fairness and Justice: We stand up for and incorporate discussions on progress with speak out for a society characterised by love, addressing modern slavery risks in their compassion, equality, justice, belonging and operations and supply chain. reconciliation so that all people, at every stage of life, can experience ‘life in all its fullness’ • the number of supplier audits and the number (John 10:10). This includes acting in a way that of open and closed findings responds to the needs of the most vulnerable in • the number of actions taken to work with society and seeking to promote the human rights of all people. suppliers to improve their capacity to respond to modern slavery risks. Stewardship: We act in ways that promote faithful stewardship of our people, financial, • the number of whistleblowing alerts raised property and other resources. This is aimed at during the year enabling our core mission including promoting • the number of human rights complaints raised environmental and social sustainability and during the year witnessing to the vision of life in all its fullness. • the proportion or number of complaints UnitingCare’s focus for the first reporting resolved by a grievance mechanism period was on embedding reviews and indicators into governance and reporting processes • the number of modern slavery training to help us monitor the effectiveness of our and awareness-raising programs delivered actions to prevent, detect and respond to to suppliers modern slavery risks and identify opportunities for improvements. Throughout the financial year ending 30 June 2021, UnitingCare will establish a new set of measures, aligned with our strategic roadmap, that will ensure actions we take have a positive social impact and support the delivery of our mission. This statement was approved by the UnitingCare Queensland Board. Nigel Alexander Chair of Board UnitingCare Queensland Modern Slavery Statement FY2019–2020 17
Telephone 07 3253 4000 Address Level 5 192 Ann Street Brisbane QLD Australia 4000 Mailing address GPO Box 45, Brisbane QLD 4001 Email contact@ucareqld.com.au unitingcareqld.com.au
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