Modern slavery statement

1. Purpose and scope

This statement sets out the steps Corpshore Australia, the Australia and New Zealand division of Corpshore Solutions Corporation, takes to address modern slavery risk in its operations and supply chains. It supports our code of ethics, and it is written to be read alongside that and our whistleblowing policy, which give the routes to raise a concern.

This is a voluntary statement. The Modern Slavery Act 2018 (Cth) requires a statement from entities with consolidated revenue of at least AUD 100 million in a reporting period. We are below that threshold, so we are not a reporting entity and this statement is not lodged on the Modern Slavery Statements Register. We publish it because the expectation should not depend on the threshold. It is prepared with reference to the Act rather than in compliance with it, and it has not been through the approval and signature process that section 13 requires of a registered statement.

We use modern slavery in the sense given by section 4 of the Act, which covers trafficking in persons, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruiting for labour or services, and the worst forms of child labour. Earlier versions of this statement discussed only forced labour and child labour, which is the narrower pairing used by Canadian law and does not match the Australian definition.

2. Our commitment

We do not tolerate forced labour, child labour, human trafficking or any form of modern slavery in our own operations or in the operations of those we do business with. We are committed to acting ethically and with integrity, to respecting the human rights of the people who work in our operations and supply chains, and to improving our practices over time. This commitment is set by our leadership and reflected in our code of ethics, our whistleblowing policy and the way we recruit our people and select our suppliers. We treat respect for human rights as a condition of doing business with us, not an optional extra.

3. Our business and supply chains

We provide business process outsourcing, information technology outsourcing and artificial-intelligence delivery services for Australian and New Zealand clients. Work is delivered by teams in Australia and New Zealand and by the group's delivery hubs in the Philippines, Vietnam, Uzbekistan, Malaysia and Fiji. Our supply chain is largely professional services and technology, including the hosting and business-application providers named in our privacy policy, together with the goods and services needed to run offices and equip our people.

3a. Where our modern slavery risk actually sits

The Act asks about risk in our operations as well as our supply chains, and we should be direct about the operations part rather than describing risk in the abstract.

Our own operations. The group employs people in countries with documented modern slavery risk, particularly around the recruitment of migrant workers. Uzbekistan and Malaysia in particular have recognised exposure to recruitment-fee debt bondage, and workers recruited through intermediaries anywhere are more vulnerable than those hired directly. We therefore hold our own hubs to the same standard we set for suppliers: people are recruited directly wherever possible, no worker is charged a fee to obtain work with us, identity documents are never retained, and wages meet or exceed the lawful minimum in the country of employment. We regard recruitment-fee debt bondage as the single most plausible way modern slavery could touch our operations, which is why it is named here rather than left to a general commitment.

Our supply chain. Our direct exposure to the highest-risk sectors is limited by the nature of the work, but risk can exist in the deeper tiers of any supply chain, including in the manufacture of the computing hardware our people use and in some categories of facilities and support services. Risk is typically higher in lower tiers, in certain geographies and sectors, and where workers are recruited through intermediaries or are otherwise in a vulnerable position. We focus attention where risk is most likely to arise rather than treating every supplier the same.

4. How we assess and address risk

We take a risk-based approach proportionate to our size and activity. Our measures include:

• Policies. This statement, our code of ethics and our whistleblowing policy set out the standards we expect of ourselves and of those we work with.
• Our people. In Australia we recruit and employ in accordance with the Fair Work Act 2009 (Cth), including the National Employment Standards, the national minimum wage and any applicable modern award, and with work health and safety law. In New Zealand the equivalents are the Employment Relations Act 2000 and the Health and Safety at Work Act 2015. In the delivery hubs we apply the local employment and workplace-safety law, and the recruitment standards set out above. We pay lawful wages and we do not use forced labour or child labour anywhere.
• Our suppliers. We expect our suppliers to comply with applicable labour and human-rights law and to prohibit forced and child labour in their own operations and supply chains. Where a supplier presents a higher risk, we seek assurances and we prefer suppliers who can demonstrate responsible practice.
• Due diligence and remediation. We consider human-rights risk when we select and review significant suppliers, and where we identify a concern we address it, which may include working with a supplier to correct it or, where necessary, ending the relationship.

5. Raising a concern

Anyone who has a concern about forced labour, child labour or other human-rights abuse in our operations or supply chains can raise it through our whistleblowing policy, including by email to info@corpshore.solutions. We do not tolerate retaliation against anyone who raises such a concern in good faith.

5a. Remediation and support for affected people

If we were to find that forced labour or child labour had occurred in our operations or supply chains, our priority would be the affected people. We would act to stop the harm, work with the supplier on a corrective plan with clear timelines, and, where appropriate, seek to support the remediation of the harm to the people affected rather than simply ending the relationship, since an abrupt exit can leave workers worse off. Where a supplier is unwilling or unable to correct the problem, we would end the relationship. We are not aware of any modern slavery in our operations or supply chains, and we have not had to take remediation measures in the period covered by this statement.

6. Training and awareness

We raise awareness of forced-labour and child-labour risk among the people responsible for recruitment and for engaging suppliers, so that they can recognise warning signs and know how to respond and escalate. We aim to build this awareness into how those people work, so that human-rights risk is considered as a normal part of hiring and of selecting and managing suppliers rather than as a separate exercise.

6a. What we ask of our suppliers

We expect the organisations we buy from to share our standards. In practice this means complying with applicable labour, employment and human-rights law; prohibiting forced labour, bonded labour, child labour and human trafficking in their own operations; not charging workers recruitment fees that can lead to debt bondage; respecting freedom of association and lawful working hours and wages; and passing comparable expectations down their own supply chains. Where a significant supplier presents a higher risk, we may ask for further information or assurances, and we prefer to work with suppliers who can demonstrate responsible practice and who engage openly if a problem is found.

7. Assessing effectiveness

We review the effectiveness of our approach over time, taking account of any concerns raised, changes in our supply chain, and developments in the law and in good practice. Because our programme is developing, we focus first on the areas of greatest risk and on building human-rights considerations into recruitment and supplier management, and we intend to strengthen our due diligence, including any use of indicators to gauge effectiveness, as our operations grow. We are transparent that this is an evolving effort rather than a finished one.

8. Consultation within the group

Corpshore Australia is a division rather than a separate legal entity, and it does not own or control any other entity. Consultation therefore runs upward: the commitments here are set with Corpshore Solutions Corporation, our parent, and applied consistently across the delivery hubs that serve Australian and New Zealand clients. A reporting entity lodging a statement under the Act must describe this process under section 16(1)(f), and we describe it here for the same reason even though we do not lodge.

9. Governance

This statement is made on behalf of Corpshore Australia as a division of Corpshore Solutions Corporation. Our leadership is responsible for the commitments in it and for the resources needed to act on them, and it is reviewed and updated as our operations and the law evolve. The date at the top of this page shows when it was last revised.

Being a voluntary statement, it has not been approved by a principal governing body or signed by a responsible member in the way section 13 of the Act requires of a statement lodged on the register. If we become a reporting entity, or choose to lodge voluntarily under section 14, that approval and signature will be obtained first and recorded here.

Questions about this statement, or concerns about modern slavery in our operations or supply chains, can be sent to info@corpshore.solutions, and can also be raised through our whistleblowing policy.