SUPPLIERS Human rights and modern slavery
Golden Mine Projects has long been concerned with protecting the human rights of persons associated in its operations and supply chain. While Golden Mine Projects is confident that its employment practises eliminate the risk of modern slavery practises within its Australian operations, it acknowledges that there is a risk that our actions in our supply chains may contribute to modern slavery practises, such as by setting cost targets that can only be met by using exploited labour. Furthermore, through the operations of our business partners, including our supply chain, we may be directly related to modern slavery practises.
This position is influenced by a number of risk variables, including sector-based risks, product/service risks, geographic and jurisdictional risks, and specific entity risks.
With a current international focus on modern slavery practises, which is reinforced by legislation in certain jurisdictions (for example, the United Kingdom and Australia), Golden Mine Projects is attempting to improve its understanding of its supplier base in order to ensure that we only procure from businesses whose products and services have been ethically sourced and are free of forced labour.
A multidisciplinary, integrated team from our supply chain, legal, and sustainable development functions informs our strategy and approach for identifying and eliminating modern slavery practises in our supply chain.
Our Supply Chain team is now focusing on the following to ensure compliance with Australia's Modern Slavery Act (2018):
Together with fellow companies, Golden Mine Projects has crafted a Toolkit against Modern Slavery. This toolkit includes a brochure on understanding modern slavery, a set of frequently asked questions, and a Human Rights Supplier Self-Evaluation Questionnaire (SEQ).
Major suppliers for Golden Mine Projects' mines in Australia have received this toolkit, aiding them in detecting potential violations of human rights. Suppliers are mandated to fill out the SEQ, which is aimed at pinpointing risks related to modern slavery, encouraging joint initiatives between suppliers and companies to mitigate those risks, enhancing transparency in the supply chain, and highlighting areas needing deeper scrutiny. This SEQ has also been incorporated into tender protocols for the Australian sector.
If needed, Golden Mine Projects pledges to help its suppliers rectify any violations. Terminating a supplier's contract would only be deemed as a final measure.
Although the SAQ provides crucial insights, it shouldn't be the exclusive gauge for assessing a supplier's risk in relation to modern slavery compliance. We utilize a cloud-based platform that evaluates supplier human rights risks by gathering data from various sources, including the SAQ, aiming to adjust the scores from the supplier's self-assessment.
Australia-based procurement and contract staff from Golden Mine Projects have undergone training on identifying and addressing modern slavery risks within the supply chain. The ongoing development of this training aligns with Golden Mine Projects' commitment in this area.
Each month, all primary suppliers (those providing goods or services directly to Golden Mine Projects) undergo a screening through a third-party system. This system checks for government affiliations, any recorded violations, regulatory actions, and adverse media exposure based on various criteria such as human rights, labor practices, regulatory issues, and more.
After the initial supplier evaluation, any potential or current risk is presented for discussion and evaluation. Screening outcomes are shared monthly with local leadership and every quarter with the Board’s Audit Committee.
In Australia, a comprehensive analysis has been conducted on expenditure to pinpoint categories with a higher potential risk of human rights violations or modern slavery. This data is then combined with additional risk assessments related to geographical areas and workforce structure to prioritize our due diligence efforts.
Beyond the online human rights self-assessment and third-party evaluations, potential suppliers might be asked to permit third-party access to their operational sites or factories to review worker conditions.
This request can extend to other suppliers in the chain and aims to ensure that Golden Mine Projects is confident in their labor practices and adherence to basic human rights. If the audit uncovers concerns, suppliers will have an adequate chance to address them.