STATEMENT ON MODERN SLAVERY - For the period to 30 June 2020
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STATEMENT ON MODERN SLAVERY For the period to 30 June 2020
Spark New Zealand Statement on Modern Slavery 2020
Modern Slavery Act
Statement 2020
This is the inaugural modern slavery statement made on behalf
of Spark New Zealand Limited (“Spark” and together with its
subsidiaries, the “Spark Group”) for the period from 1 July 2019 Contents
to 30 June 2020. It has been prepared pursuant to the requirements
Our business 3
of the Australian Modern Slavery Act 2018.
Our operations 4
This report was approved by the Spark New Zealand Board
on 29 March 2021. Our people 5
Our supply chain 7
Effectiveness of
Spark’s approach 9
Justine Smyth, CNZM
Chair
Spark New Zealand Limited (NZX: SPK, ASX: SPK)
Spark is committed to upholding human rights – both within our own
operations and throughout our supply chain. This means the fair and
respectful treatment of all our people, and a focus on providing
fulfilling and rewarding employment. It means complying fully with
the law, but also going above and beyond compliance – acting
professionally, ethically, and responsibly as we deliver customer
outcomes, contribute to the community, and create shareholder
value. It means sourcing our products and services from suppliers
that provide safe working conditions, treat workers with respect and
dignity and conduct business in an environmentally and socially
responsible manner.
We are committed to taking meaningful action to identify, mitigate
and manage any modern slavery risks – and to continuously
improving our approach.
2Spark New Zealand Statement on Modern Slavery 2020
Our business
Spark’s purpose is to help all of The Spark Group Corporate Governance and
Spark New Zealand Limited is the parent risk management
New Zealand win big in a digital
entity of the Spark Group. Spark is publicly Our approach to managing modern slavery
world. We are New Zealand’s listed, and our issued shares are quoted risks is supported by our high standards of
largest telecommunications and on the New Zealand Stock Exchange (NZX) operational performance, corporate
digital services provider. Our and Australian Securities Exchange (ASX). governance and risk management.
customers range from consumers Spark is a reporting entity for the The Board regularly reviews and assesses
and households to large purposes of the Modern Slavery Act Spark’s governance structures and processes
(Commonwealth) 2018 and our statement to ensure that they are consistent with
enterprises, and our services
covers the Spark Group of entities. international best practice, in both form and
include mobile and broadband As at 30 June 2020 the Spark Group substance. Spark’s corporate policies apply at
connectivity, cloud connectivity comprised 30 controlled entities. a group level and our governance structures
and IT services. Spark New Zealand Trading Limited is the ensure the Spark Group of entities adhere to
main trading entity within the Spark Group expected standards of conduct. Copies of,
and is the parent company of many of and details about, Spark’s corporate
Spark’s operating subsidiaries. governance policies, practices and processes
can be found on our website at: https://
Spark Finance Limited is the finance company
www.sparknz.co.nz/about/governance
for the Spark Group and raises debt funding
in New Zealand and internationally. The Our managing risk policy and framework
majority of these funds are then advanced to helps people to manage uncertainty and
other members of the Spark Group in order challenges as they pursue Spark’s strategy
to assist in funding the group’s operations. and business objectives. The policy, overseen
Spark Finance is listed on the NZDX as SPF. by the Audit and Risk Management
Committee (ARMC), confirms the objectives
A complete list of the controlled entities in
for identifying and managing risks that can
the Spark Group as at 30 June 2020
impact Spark’s organisational performance.
(including ownership percentages and
principal activity information) is available The policy and framework are benchmarked
in the Spark Annual Report 2020 on to COSO ERM 2017 (COSO), a leading
page 111. practice risk management standard. Spark has
used this standard since July 2018 when we
More information on our financial
transitioned to the Agile Operating Model.
performance and business strategy may
be found on our corporate website at For more information on our risk
https://investors.sparknz.co.nz/ management processes, see Spark’s Annual
Investor-Centre/ Report 2020, pages 46-48 and page 112.
Our corporate structure
Spark New Zealand
Limited
Spark New Zealand Spark Finance Spark Group
Trading Limited Limited Entities (15)
Spark New Zealand Trading
Entities (12)
3Spark New Zealand Statement on Modern Slavery 2020
Our operations
Spark provides a broad range Spark provides a broad range of The Spark Foundation is the charitable arm
telecommunications and digital services. of Spark and has a mission to ensure no
of telecommunications and
Through the Spark, Skinny and BigPipe New Zealander is left behind in a digital
digital services. world. It seeks to achieve this by
brands we provide mobile and broadband
connectivity, digital services and devices, accelerating equitable access and
to consumers and households, and to some capabilities through giving, advocacy
small businesses. and targeted investment opportunities.
Through our Spark Business, CCL, Digital How we mitigate modern slavery
Island, Qrious and Leaven Brands we risks in our operations
provide a range of digital services to Our approach to corporate governance,
business customers, from small to medium- as outlined above, alongside our values,
sized enterprises through to government Code of Ethics, Supplier Code of Conduct,
departments and large enterprises. These and Whistleblowing procedures (all detailed
include cloud connectivity, IT services, data below) assist us to mitigate the risks of
analytics and data-powered marketing, modern slavery in our operations. We strive
cyber security, procurement and business for a culture where Spark people are
transformation services. Our Telegistics committed to doing the right thing, to using
business assists our channel partners company policies (such as the Code of Ethics)
across New Zealand with supply chain to help inform and determine what the right
and distribution solutions. thing is, and to feel safe raising the alarm if
Spark owns a 50% shareholding in a network they have concerns.
construction business Connect 8. For the In addition, we have checks and balances in
purposes of this report, Connect 8 is treated place in specific areas. For example, our
as a supplier of network construction services wholesale business checks all requests for
to Spark, and has signed up to our Supplier roaming relationships against the UN, US, UK
Code of Conduct (see below). and NZ MFAT sanctions lists and regularly
Through our Wholesale business we monitor these for changes. It also checks and
resell telecommunications services within monitors the ownership of all new and
New Zealand and provide International existing carrier partners – and will turn down
Mobile Roaming connectivity to the requests for roaming agreements where we
customers of offshore telecommunications believe it is appropriate to do so.
carriers. We have relationships with more
than 370 of these carriers globally.
We are building businesses in emerging
growth areas: we have a nationwide
Internet of Things (IoT) network and
platforms; through Spark Health we deliver
a tailored suite of telco and IT services for
the health sector and are developing a
Digital Health Platform; and we have a
sports streaming and production service,
Spark Sport. Our emerging technology
business Mattr creates solutions for
verifiable data and digital trust.
4Spark New Zealand Statement on Modern Slavery 2020
Our people
Our direct workforce Our indirect workforce
As at 30 June 2020, Spark directly employed We have an indirect workforce of almost
5,224 people, with more than 99% of these 3,000 with the majority of these located in
people located in New Zealand. New Zealand, but approximately 500 people
We employ people with a broad range of located offshore. We recognise our indirect
skillsets, ranging from customer service to workforce could potentially face higher risks
engineering to professional services. of modern slavery than those employed
directly by Spark, and we have checks
Spark meets all the requirements of New
and balances in place to mitigate this.
Zealand employment law for our NZ-based
direct workforce, and in many cases goes Our indirect workforce in New Zealand
above and beyond statutory requirements. is a diverse mix of agency contractors,
Our Hiring Policy ensures that right to work consultancy firms, independent contractors,
checks are undertaken and work cannot and people employed by our Business Hubs
commence without valid documentation. Our – which operate under a licencing model.
remuneration structure ensures that all staff It includes people such as cleaners and
are paid rates at or above the minimum wage, security staff who work in Spark buildings.
with governance provided by our Human Our New Zealand-based indirect employees
Resources & Compensation Committee. are all protected by New Zealand labour laws
Spark has a diverse workforce and has a and are governed by a range of different
strong diversity and inclusion programme to contractual arrangements depending on
ensure our people feel valued, respected and the type of work they do and where we
confident to bring their whole self to work. We have employed them. Our independent
use an open employee feedback tool which contractors and agency staff who contract
enables our people to make their voice heard, directly to Spark are all engaged in line with
and other internal communication tools to our hiring process in terms of right to work
ensure openness and transparency regarding and rates of pay.
the way we work. Spark people undertake Of our people located offshore, the majority
compliance training on a range of topics are in Manilla, where we contract with an
including Ways of Working. offshore partner to run customer care centres
Spark employs interns across our business to service our customer base in New Zealand.
in a broad range of areas. Where it is a formal We require our partner in Manilla to make
internship, we have a policy of paying our formal commitments around its mitigation of
interns the minimum wage (rather than modern slavery risk. Our partner has
requiring them to give their time for free), confirmed that it adheres to fair pay practices,
and we ensure they are given meaningful including paying employees for all time
career opportunities. Around one in five worked, and that all its employees,
of these interns is engaged through contractors and suppliers must comply fully
programmes such as the First Foundation1 with its Equal Employment Opportunity Policy
as part of our focus on diversity and inclusion. and applicable employment laws. We also
First Foundation interns are supported with outsource some IT Services work to contract
scholarships, work experience and mentoring. staff at two different IT services businesses,
Occasionally we have people who volunteer both headquartered in India. The number of
their time in order to gain work experience or contractors from these businesses who are
knowledge in a particular area – for example working with Spark fluctuates depending on
our Agile transformation. These are short-term the work required, but at 30 June 2020 it was
arrangements and we will continue to a little over 100 people, with around two
monitor this practice to ensure it is always thirds based in New Zealand and a third
beneficial for the volunteer. offshore in India or Australia. Both
1 See http://www.firstfoundation.org.nz/ for more information
5Spark New Zealand Statement on Modern Slavery 2020
Our people (cont.)
organisations have signed up to our Supplier • Conduct themselves in a professional
Code of Conduct. manner that upholds and strengthens the
image and reputation of Spark
Our retail network
New Zealand;
As at 30 June 2020, Spark operated 66 retail
stores and 24 business hubs, providing • Deal fairly and honestly with Spark
connectivity and digital solutions to small-to- New Zealand’s people, professional
medium enterprises. These are located advisors, customers, and suppliers;
throughout New Zealand. We also have • Not enter into transactions or make
dealership arrangements with major retail promises on behalf of Spark New Zealand
chains across New Zealand to sell Spark that we are unable or do not intend to
products and services. honour;
Spark owns all our retail stores, and the • Undertake their duties with care and
people working in our stores have a diligence;
contract directly with Spark. • Value individuals’ differences and treat
Our business hubs are operated by third- people with respect in accordance with
party licensees. In this model we understand Spark New Zealand’s Equal Employment
the need to ensure the rights of Hub Opportunities and Anti-Harassment and
employees are upheld, and we do this by Discrimination Policies.
requiring that the terms of employment The full Code of Ethics may be found here:
between the licensee and the staff member https://www.sparknz.co.nz/about/
must “comply with all statutory and legal governance/
requirements”. We have recently revised the
licence agreement, under which licensees Grievance mechanisms
must now offer employment on terms We have a range of avenues for our people
substantially consistent with a template to pursue if they are concerned about Spark
agreement provided by Spark (being a fit-for or people within Spark not living up to our
purpose agreement that meets minimum values or our Code of Ethics – including any
legal requirements). instances where our business or our people
are instigating or allowing modern slavery
Our values and Code of Ethics practices.
Our values are the cornerstones of our
culture. Our four values are: Whistleblowing policy
Spark encourages all Spark people to report
• Tūhono: we connect
any issues or concerns they have about
• Māia: we are bold compliance issues or serious wrongdoings.
• Whakamana: we empower If people are not comfortable reporting an
• Matomato: we succeed together issue to their people leader, they can use
Spark’s Honesty Box process, an online
Our Code of Ethics sets the standards we
reporting tool that enables investigation of
expect of our people when it comes to how
any concerns raised by specialist staff while
they do business. Included in the document
maintaining the confidentiality of the reporter.
are the behaviours expected of Spark people,
We also provide avenues where people can
which include the expectation they will:
raise concerns without providing any
• Undertake their duties in accordance with information about their identity at all.
Spark New Zealand’s values;
Spark works with submitters to ensure they
• Conduct themselves in a way that do not suffer any adverse treatment as a
demonstrates that their honesty and result of any reports made in good faith.
integrity is beyond question;
6Spark New Zealand Statement on Modern Slavery 2020
Our supply chain
About our supply chain Spark’s biggest categories of spend include:
Our business relies on more than 2,000 local • The purchase of equipment and services
and global suppliers. Each year we spend for our customers (primarily business
over $2 billion to support our business and customers) either when Spark is acting
meet our customers’ needs. Our supply chain as a reseller or a provider of managed
is complex, as our direct suppliers often have services. This includes items such as
suppliers of their own – who themselves rely mobile devices, IT equipment services
on other suppliers and so on. and support;
Through our supply chain we source a large • Goods and services sold to Spark for the
number of products and services from New purposes of maintaining and providing
Zealand and around the globe. Of our total telecommunication networks; and
spend, approximately 90% is with our top 100
• Goods and services sold to Spark to
suppliers – and in this report we have chosen
enable our IT environment.
to focus on data for those top 100 suppliers.
The remainder is spent on a range of services
Around 65% of our spend is with suppliers
such as marketing, corporate services,
offshore and 35% with NZ-based suppliers.
content rights, electricity, travel, freight
Approximately 6% of spend is with suppliers
and courier, office supplies, and leasing.
based in countries identified as having
higher-risk of non-compliance with human Managing modern slavery risks in our
rights or modern slavery requirements2, and supply chain
around 2% with suppliers in medium-risk Spark is committed to sourcing our products
countries. However, we recognise the need to and services from suppliers that provide
go beyond the location of a supplier’s head safe working conditions, treat workers with
office when it comes to mitigating the risks of respect and dignity and conduct business in
modern slavery, because the manufacture of an environmentally and socially responsible
many of our products will be in a different manner. Our Supplier Code of Conduct
location to the supplier’s head office. The (the Code) sets out the minimum standards
global nature of our supply chain means we we expect from our suppliers across labour
must constantly monitor and review our and human rights, health and safety,
approach to reduce the risks of modern environmental sustainability, and ethical
slavery, and we require our suppliers to be business practices.
accountable for their own supply chain. This Section 3.1 of the Code sets out our
sub tier accountability is integrated into our approach to Labour and Human Rights.
Supplier Code of Conduct (see below). This requires that our suppliers ensure
Most of our electronics and network workers are treated in a manner consistent
components spend is with large, with international human rights standards,
multinational companies who supply us with including the UN Universal Declaration of
finished products. We do not manufacture Human Rights, UN Convention on the Rights
our own products. Instead, we work with of the Child, and the International Labour
original design manufacturers (ODM) to Organisation Core Conventions.
produce Spark-branded devices. The goods See www.sparknz.co.nz/suppliers for
we procure are manufactured across the more detail.
world. Source locations include USA, China,
The Supplier Code of Conduct was
South Korea, United Kingdom, and Sweden.
introduced in FY18. To embed the Code, we
The services we procure are predominantly
worked with our top 100 suppliers by
provided in New Zealand, Australia, India and
contract value to ensure they were signed up
the Philippines.
2 High risk countries as defined by guidance in the United Nations Environment Programme Finance Initiative. This
was cross-checked with other more recent data sources to ensure we’ve identified the most important geographies.
7Spark New Zealand Statement on Modern Slavery 2020
Our supply chain (cont.)
to the Code or could demonstrate they are with suppliers that are managed in our
adhering to an existing equivalent code of framework. Our Code enables us to suspend
practice. We also used the Code as a basis or cancel a non-compliant supplier’s supply
for four comprehensive, paper-based audits of any goods or services to Spark, including
of large, offshore-based suppliers. These suspending the payment of any associated
were significant suppliers operating in high invoices, until that non-compliance is
risk and medium risk locations. The remedied to Spark’s satisfaction. It also
assessments, which were validated through enables us to terminate any or all of the
evidence provided and assertions by supplier’s contracts with Spark.
Supplier Management, showed all four The arrival of COVID-19 in FY20 restricted our
suppliers were adhering with the Code. ability to carry out audits on compliance with
We endeavour to ensure all new suppliers the Code. Instead, our focus in FY20 was on
sign up to the Code as part of their incorporating environmental, social and
onboarding process. We do have a small ethical considerations into our supplier
number of legacy or non-standard processes selection processes. We have also matured
which do not yet require a supplier must sign our approach and now include a scored
the Code, and we will be working to remove section in our Request for Proposal (RFP)
and/or update those early in FY22. After this process where we seek information from
time, signing up to the Code will be fully suppliers on their non-financial performance
integrated into our procurement processes and credentials.
across all spend categories. In FY20 the only While our initial focus has been on our top
suppliers who did not sign up to Spark’s 100 suppliers, we are conscious there may be
Code were either global suppliers that have suppliers who do not sit in this category who
their own code of conduct which Spark also bring risks of modern slavery due to the
deemed equivalent to the Spark Code, or nature of their business – for example, those
suppliers deemed low risk based on the that employ migrant labour. In the remainder
services provided and the nature of the of FY21 (to 30 June) and in FY22 we will
supplier – for example if the business is investigate how we can more effectively
subscribing to a piece of software for a monitor and mitigate any modern slavery
short period of time, and there is no request risks within this part of our supply chain.
for proposal (RFP) process involved in
Our Supplier Code of Conduct is
selecting it.
underpinned by our Spark Value
If we become aware that a supplier is Management Policy, which sets out
unable to meet the requirements of the detailed guidelines for Spark people
Code, we work with them to implement who are engaging suppliers – including
our process of remediation plans and the requirement to source and procure
timeframes. We have ongoing conversations goods and services ethically and responsibly.
We also require suppliers to sign up to
Spark’s Supplier Health and Safety Policy.
8Spark New Zealand Statement on Modern Slavery 2020
Effectiveness of Spark’s approach
Spark is committed to identifying, We have strong foundations in place to There have been recent instances of modern
do this, by way of an established operating slavery in New Zealand and we recognise the
monitoring, and measuring the
model to monitor achievements against need to raise awareness of slavery risks
risks of modern slavery in our our objectives. This includes strong risk amongst our people, many of whom may
operations and supply chain. and issues management, along with assume “that doesn’t happen here”.
processes to ensure we adapt and respond To fully assess our effectiveness in this area,
to planned and unplanned challenges where we will need to benchmark ourselves against
necessary We are focused on maintaining other, similar, organisations and evaluate our
and enhancing this awareness across Spark strengths and weaknesses. We will be doing
and its supply chain and have people and further evaluation of our approach, and will
processes align to deliver this. We are a identify actions for improvement, in the
values and purpose-driven business, with remainder of FY21 and through FY22.
a strategic focus on building a diverse and
One of our first steps will be to back up
inclusive culture, a track record of strong
our Supplier Code of Conduct with regular
corporate governance, and a Code of Ethics
audits of our direct suppliers, to ensure
and a Supplier Code of Conduct – both of
we are assessing for modern slavery risks
which are deeply embedded in our relevant
effectively and we will be planning for this
business systems and processes. These
in the remainder of FY21 and implementing
are all underpinned by a culture that
it in FY22.
encourages our people to speak up if they
are uncomfortable or concerned about We also recognise that while our Supplier
anything they see. Code requires our suppliers to provide
assurance there are no instances of modern
As a publicly listed, consumer-facing and
slavery in their own supply chains, best
high-profile (within New Zealand) business,
practice is to identify modern slavery risks
we are subject to a healthy level of scrutiny
beyond our immediate supplier relationships.
from our stakeholders. Our shares are held
We will be investigating possible avenues
by a geographically diverse shareholder
for assessing risk in this sub tier in the
base who hold us to account on issues of
coming months.
sustainability and social responsibility.
Sustainability is a key pillar of our business
strategy, and we have been continuously
improving and expanding our disclosure
on our non-financial performance in the past
few years. Our Annual Report for FY20 was
prepared in accordance with the International
Framework and the GRI Core Option.
We are a New Zealand-based company with
the vast majority of our operations, people
and customers located in New Zealand and
subject to New Zealand’s strong labour,
employment, and anti-corruption legislation.
This means we have a lower risk of modern
slavery in our operations than we would
otherwise, but we cannot be complacent.
9spark.co.nz
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