STATEMENT ON MODERN SLAVERY - Spark
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STATEMENT ON MODERN SLAVERY
Spark New Zealand Statement on Modern Slavery 2021
Modern Slavery Act
Statement 2021
This modern slavery statement is made on behalf of Spark New
Zealand Limited (“Spark” and together with its subsidiaries, the
“Spark Group”) for the period from 1 July 2020 to 30 June 2021. Contents
It has been prepared pursuant to the requirements of the Australian
Our business 3
Modern Slavery Act 2018.
Our operations 4
This report was approved by the Spark New Zealand Board on
17 August 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 2021
Our businesses
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 on risks is supported by our high standards of
largest telecommunications and the New Zealand Stock Exchange (NZX) and operational performance, corporate
digital services provider. Our Australian Securities Exchange (ASX). governance, and risk management.
customers range from consumers Spark is a reporting entity for the purposes of The Board regularly reviews and assesses
and households to large the Modern Slavery Act 2018. Spark Spark’s governance structures and processes
engaged and consulted with the relevant to ensure that they are consistent with
enterprises, and our services
companies we own or control (the Spark international best practice, in both form and
include mobile and broadband Group) in the development of this statement. substance. Spark corporate policies apply at a
connectivity, cloud connectivity As at 30 June 2021 the Spark Group group level and our governance structures
and IT services. comprised 29 controlled entities. ensure the Spark Group of entities adhere to
Spark New Zealand Trading Limited is the expected standards of conduct. Copies of,
main trading entity within the Spark Group and details about, Spark’s corporate
and is the parent company of many of Spark’s governance policies, practices and processes
operating subsidiaries. can be found on our website at:
www.sparknz.co.nz/about/governance
Spark Finance Limited is the finance company
for the Spark Group and raises debt funding Our managing risk policy and framework
in New Zealand and Internationally. The helps people to manage uncertainty and
majority of these funds are then advanced to challenges as they pursue Spark’s strategy
other members of the Spark Group in order and business objectives. The policy, overseen
to assist in funding the group’s operations. by the Audit and Risk Management
Spark Finance is listed on the NZDX as SPF. Committee (ARMC), confirms the objectives
for identifying and managing risks that can
More information on significant subsidiaries
impact Spark’s organisational performance.
and controlled entities in the Spark Group as
at 30 June 2021 (including ownership The policy and framework are benchmarked
percentages and principal activity to COSO ERM 2017 (COSO), a leading
information) is available in the Spark Annual practice risk management standard. Spark has
Report on pages 103 & 117. used this standard since July 2018 when we
transitioned to the Agile Operating Model.
More information on our financial
performance and business strategy may be For more information on our risk
found on our corporate website at management processes, see the Spark
investors.sparknz.co.nz/Investor-Centre Annual Report 2021, pages 52 to 54.
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 2021
Our operations
Spark provides a broad range Through the Spark, Skinny and BigPipe The Spark Foundation is the charitable arm
brands we provide mobile and broadband of Spark and has a mission to ensure no
of telecommunications and
connectivity, digital services and devices, New Zealander is left behind in a digital
digital services. to consumers and households, and to some world. It seeks to achieve this by
small businesses. accelerating equitable access and
Through our Spark, CCL, Digital Island, capabilities through giving, advocacy
Qrious and Leaven Brands we provide a and targeted investment opportunities.
range of digital services to How we mitigate modern slavery risks in
business customers, from small to medium- our operations
sized enterprises through to government Our approach to corporate governance,
departments and large enterprises. These as outlined above, alongside our values,
include cloud connectivity, IT services, data Code of Ethics, Supplier Code of Conduct,
analytics and data-powered marketing, and Whistleblowing procedures (all detailed
cyber security, procurement and business below) assist us to mitigate the risks of
transformation services. Our Telegistics modern slavery in our operations. We strive
business assists our channel partners for a culture where Spark people are
across New Zealand with supply chain committed to doing the right thing, to using
and distribution solutions. company policies (such as the Code of Ethics)
Spark owns a 50% shareholding in a network to help inform and determine what the right
construction business Connect 8. For the thing is, and to feel safe raising the alarm if
purposes of this report, Connect 8 is treated they have concerns.
as a supplier of network construction services In addition, we have checks and balances in
to Spark, and has signed up to our Supplier place in specific areas. For example, our
Code of Conduct (see below). wholesale business checks all requests for
Through our Wholesale business we roaming relationships against the UN, US, UK
resell telecommunications services within and NZ MFAT sanctions lists and regularly
New Zealand and provide International monitor these for changes. It also checks and
Mobile Roaming connectivity to the monitors the ownership of all new and
customers of offshore telecommunications existing carrier partners – and will turn down
carriers. We have relationships with more requests for roaming agreements where we
than 370 of these carriers globally. believe it is appropriate to do so.
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 2021
Our people
Our direct workforce experience or knowledge in a particular area
As at 30 June 2021, Spark directly employed – for example our Agile transformation. These
5,083 people, with more than 99% of these are short-term arrangements and we will
people located in New Zealand. continue to monitor this practice to ensure it
We employ people with a broad range of is always beneficial for the volunteer.
skillsets, ranging from customer service to Our indirect workforce
engineering to professional services. We have an indirect workforce of almost
Spark meets all the requirements of New 3,000 with the majority of these located in
Zealand employment law for our NZ-based New Zealand and approximately 500 people
direct workforce, and in many cases goes located offshore. We recognise our indirect
above and beyond statutory requirements. workforce could potentially face higher risks
Our Hiring People Policy ensures that “right to of modern slavery than those employed
work” checks are undertaken, and work directly by Spark, and we have checks and
cannot commence without valid balances in place to mitigate this.
documentation. Our remuneration framework Our indirect workforce in New Zealand is a
and practices in most cases ensures that all diverse mix of agency contractors,
employees are paid rates above the consultancy firms, independent contractors,
minimum wage, with governance provided and people employed by our Business Hubs
by our Human Resources and Compensation - which operate under a licencing model. It
Committee. includes people such as cleaners and security
Spark has a diverse workforce and has a staff who work in Spark buildings.
strong diversity and inclusion programme Our New Zealand-based indirect employees
to ensure our people feel valued, respected, are all protected by New Zealand labour laws
and confident to bring their whole selves to and are governed by a range of different
work. We use an open employee feedback contractual arrangements depending on the
tool which enables our people to share their type of work they do and where we have
views and ideas, and other internal engaged them. Our independent contractors
communication tools to ensure openness and and agency staff who contract directly to
transparency regarding the way we work. Spark are all engaged in accordance with our
Spark people undertake compliance training own employment hiring process in terms of
on a range of topics including (but not limited proof of right to work and rates of pay.
to) our Code of Ethics, health and safety,
Of our people located offshore, the majority
security and privacy, and our policies around
are in Manilla, where we contract with an
discrimination, bullying, diversity and
offshore partner to run customer care centres
inclusion and harassment.
to service our customer base in New Zealand.
Spark employs interns across our business in We require our partner in Manilla to make
a range of areas. We have a general policy of formal commitments around its mitigation of
paying our interns at least the minimum wage modern slavery risk. Our partner has
(rather than requiring them to give their time confirmed that it adheres to fair pay practices,
for free), and we ensure they are given including paying employees for all time
meaningful career opportunities. Around one worked, and that all its employees,
in five of these interns are engaged through contractors and suppliers must comply fully
programmes such as the First Foundation as with its Equal Employment Opportunity Policy
part of our focus on diversity and inclusion. and applicable employment laws. We also
These interns are supported with outsource some IT Services work to contract
scholarships, work experience and staff at two different IT services businesses,
mentoring. Occasionally we have people that both headquartered in India. The number of
volunteer their time in order to gain work contractors from these businesses who are
1 See http://www.firstfoundation.org.nz/ for more information.
5Spark New Zealand Statement on Modern Slavery 2021
Our people (cont.)
working with Spark fluctuates depending on • Conduct themselves in a way that
the work required, but at 30 June 2021 it was demonstrates that their honesty and
a little over 100 people, with around two integrity is beyond question;
thirds based in New Zealand and a third • Conduct themselves in a professional
offshore in India or Australia. Both manner that upholds and strengthens the
organisations have signed up to our Supplier image and reputation of Spark New
Code of Conduct. Zealand;
Our retail network • Deal fairly and honestly with Spark New
We operate 65 retail stores and 24 Business Zealand’s people, professional advisors,
Hubs (providing connectivity and digital customers, and suppliers;
solutions to small-to-medium enterprises) – • Not enter into transactions or make
and these are located throughout promises on behalf of Spark New Zealand
New Zealand. We also have dealership that we are unable or do not intend to
arrangements with major retail chains across honour;
New Zealand to sell Spark products and
• Undertake their duties with care and
services.
diligence;
Spark owns all of its retail stores, and all the
• Value individuals’ differences and treat
people working in Spark stores have an
people with respect in accordance with
employment agreement directly with Spark.
Spark New Zealand’s Equal Employment
Our Business Hubs are operated by third- Opportunities and Anti-Harassment and
party licensees. In this model we understand Discrimination Policies.
the need to ensure the rights of Hub
The full Code of Ethics may be found here:
employees are upheld, and we do this by
www.sparknz.co.nz/about/governance
requiring within the licence terms that the
terms of employment between the licensee Grievance mechanisms
and the staff member must “comply with all We have a range of avenues for our people
statutory and legal requirements”. We have to pursue if they are concerned about Spark
recently revised the licence agreement, under or people within Spark not living up to our
which licensees must now offer employment values or our Code of Ethics – including any
on terms substantially consistent with a instances where our business or our people
template agreement provided by Spark are instigating or allowing modern slavery
(being a fit-for purpose agreement that meets practices. These are set out in detail for Spark
minimum legal requirements). people in our whistleblowing process, which
is documented and available to all Spark
Our Values and Code of Ethics
people. We encourage the reporting of any
Our values are the cornerstones of our
concerns our people have about compliance
culture. Our four values are:
issues or serious wrongdoings. Anyone who
• Tūhono: we connect is not comfortable reporting an issue to their
• Māia: we are bold people leader can use Spark’s Honesty Box
• Whakamana: we empower process, an online reporting tool that enables
investigation of any concerns raised by
• Matomato: we succeed together
specialist staff while maintaining the
Our Code of Ethics sets the standards we confidentiality of the reporter. We also
expect of our people when it comes to how provide avenues where people can raise
they do business. Included in the document concerns without providing any information
are the behaviours expected of Spark people, about their identity at all.
which include the expectation they will:
Spark works with submitters to ensure they
• Undertake their duties in accordance with do not suffer any adverse treatment as a
Spark New Zealand’s values; result of any reports made in good faith.
6Spark New Zealand Statement on Modern Slavery 2021
Our supply chain
About our supply chain world. Source locations include USA, China,
Our business relies on more than 2,300 local South Korea, United Kingdom, and Sweden.
and global suppliers. Each year we spend The services we procure are predominantly
around $2 billion to support our business and provided in New Zealand, Australia, India and
meet our customers’ needs. Our supply chain the Philippines.
is complex, as our direct suppliers often have Spark’s biggest categories of spend include:
suppliers of their own – who themselves rely
• The purchase of equipment and services
on other suppliers and so on.
for our customers (primarily business
Through our supply chain we source a large customers) either when Spark is acting as
number of products and services from a reseller or a provider of managed
New Zealand and around the globe. Of our services. This includes items such as
total spend, around 90% is with our top 100 mobile devices, IT equipment services
suppliers – and for this reason, in this report and support;
we have chosen to focus on data for those top
• Goods and services sold to Spark for the
100 suppliers.
purposes of maintaining and providing
Around 65% of our spend with these top 100 telecommunication networks; and
suppliers is with suppliers offshore and 35%
• Goods and services sold to Spark to
with NZ-based suppliers. Approximately 6%
enable our IT environment.
of this spend is with suppliers based in
countries identified as having higher-risk of The remainder is spent on a range of services
non-compliance with human rights or such as marketing, corporate services,
modern slavery requirements2, and around content rights, electricity, travel, freight and
2% with suppliers in medium-risk countries. courier, office supplies, and leasing.
However, we recognise the need to go Managing modern slavery risks in our
beyond the location of a supplier’s head supply chain
office when it comes to mitigating the risks of Spark is committed to sourcing our products
modern slavery, because the manufacture of and services from suppliers that provide safe
many of our products will be in a different working conditions, treat workers with respect
location to the supplier’s head office. The and dignity and conduct business in an
global nature of our supply chain means we environmentally and socially responsible
must constantly monitor and review our manner. Our Supplier Code of Conduct (the
approach to reduce the risks of modern Code) sets out the minimum standards we
slavery (as further outlined below in expect from our suppliers across labour and
“Effectiveness of Spark’s Approach”), and we human rights, health and safety,
require our suppliers to be accountable for environmental sustainability, and ethical
their own supply chain’s compliance with business practices.
modern slavery requirements. This sub tier
Section 3.1 of the Code sets out our
accountability is integrated into our Supplier
approach to Labour and Human Rights. This
Code of Conduct (see below).
requires that our suppliers ensure workers are
Most of our electronics and network treated in a manner consistent with
components spend is with large, 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
we procure are manufactured across the
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 2021
Our supply chain (cont.)
See www.sparknz.co.nz/suppliers for If we become aware that a supplier is
more detail. unable to meet the requirements of the
The Supplier Code of Conduct was Code, we work with them to implement our
introduced in FY18. To embed the Code, we process of remediation plans and timeframes.
worked with our top 100 suppliers by We have ongoing conversations with
contract value to ensure they were signed up suppliers that are managed in our framework.
to the Code or could demonstrate they are Our Code enables us to suspend or cancel
adhering to an existing equivalent code of a non-compliant supplier’s supply of any
practice. We also used the Code as a basis for goods or services to Spark, including
four comprehensive paper-based audits of suspending the payment of any associated
large, offshore-based suppliers. These were invoices, until that non-compliance is
significant suppliers operating in high-risk remedied to Spark’s satisfaction. It also
locations. The assessments, which were enables us to terminate any or all of the
validated through evidence provided and supplier’s contracts with Spark.
assertions by Supplier Management, showed We incorporate environmental, social and
all four suppliers were adhering with the ethical considerations into our supplier
Code. selection processes, including using a scored
We require all new suppliers to sign up to the section in our RFP process where we seek
Code as part of their onboarding process and information from suppliers on their non-
have this process integrated into our financial performance and credentials. While
procurement systems and processes. We do our initial focus for our Supplier Code of
have a small number of legacy or non- Conduct audits and checks has been on our
standard processes which do not yet require top 100 suppliers, we are conscious there
a supplier to sign the Code, and we will be may be suppliers who do not sit in this
working to remove and/or update those early category who also bring risks of modern
in FY22. After this time, signing up to the slavery due to the nature of their business –
Code will be fully integrated into our for example, those that employ migrant
procurement processes across all spend labour. In the coming financial year, we will
categories. investigate how we can more effectively
monitor and mitigate any modern slavery
In FY21 the only suppliers who did not sign
risks within this part of our supply chain.
up to Spark’s Code were either global
suppliers that have their own code of conduct In FY21 we recommenced our auditing of
which Spark deemed equivalent to the Spark suppliers against the Supplier Code of
Code, or suppliers deemed low risk based on Conduct. At the start of FY22 we completed
the services provided and the nature of the audits of a further four suppliers across a
supplier – for example if the business is range of product categories.
subscribing to a piece of software for a short Our Supplier Code of Conduct is
period of time and there is no request for underpinned by our Spark Value
proposal (RFP) process involved in Management Policy, which sets out detailed
selecting it. guidelines for Spark people who are
engaging suppliers – including the
requirement to source and procure 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 2021
Effectiveness of Spark’s approach
Spark is committed to identifying, We have an established operating model to We are a New Zealand-based company with
monitor achievements against our objectives. the vast majority of our operations, people
monitoring, and measuring the
This includes strong risk and issues and customers located in New Zealand and
risks of modern slavery in our management, along with processes to ensure subject to New Zealand’s strong labour,
operations and supply chain. we adapt and respond to planned and employment, and anti-corruption legislation.
unplanned challenges where necessary. We This means we have a lower risk of modern
are focused on maintaining and enhancing slavery in our operations than we would
awareness of modern slavery risks across otherwise, but we cannot be complacent.
Spark and its supply chain, and have people There have been recent instances of modern
and processes align to deliver this. slavery in New Zealand and we recognise the
We are a values and purpose-driven business, need to raise awareness of slavery risks
with a strategic focus on building a diverse amongst our people, many of whom may
and inclusive culture, a track record of strong assume “that doesn’t happen here”.
corporate governance, and a Code of Ethics To fully assess our effectiveness in this area,
and a Supplier Code of Conduct – both of we will need to benchmark ourselves against
which are deeply embedded in our relevant other, similar organisations and evaluate our
business systems and processes. These are all strengths and weaknesses. We will be doing
underpinned by a culture that encourages further evaluation of our approach, and will
our people to speak up if they are identify actions for improvement, in FY22.
uncomfortable or concerned about anything This will include engagement with relevant
they see. companies we own or control to ensure
As a publicly listed, consumer-facing and identification of risk and alignment with the
high-profile (within New Zealand) business, Spark Group approach.
we are subject to a healthy level of scrutiny As first steps we intend to back up our
from our stakeholders. Our shares are held by Supplier Code of Conduct with regular audits
a geographically diverse shareholder base of our direct suppliers, to ensure we are
who hold us to account on issues of assessing for modern slavery risks effectively.
sustainability and social responsibility. As outlined in the “Our Supply Chain” section
Sustainability is a key pillar of our business of this statement, we initiated four further
strategy, and we have been continuously audits of suppliers against the Code in FY21.
improving and expanding our disclosure on These were completed at the start of FY22.
our non-financial performance in the past few We also recognise that while our Supplier
years. Our Annual Report for FY21 was Code requires our suppliers to provide
prepared in accordance with the International assurance there are no instances of modern
Framework and the GRI Core Option, slavery in their own supply chains, best
and we have worked to continuously improve practice is to identify modern slavery risks
our compliance with both frameworks over beyond our immediate supplier relationships.
the past three financial years. We will be investigating possible avenues for
assessing risk in this sub tier in FY22.
9spark.co.nz
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