Addressing modern slavery
Swinburne is committed to taking the necessary steps to identify and resolve any form of modern slavery within the University’s operations, our suppliers and partner organisations. We deplore all forms of slavery and forced labour, and we understand the significant role of universities in helping to end modern slavery.
Swinburne's Modern Slavery Statement outlines our commitments and steps taken to resolve any forms of modern slavery within our operations, suppliers and partner organisations.
We are participating in the university sector’s modern slavery program which aims to work collaboratively with our suppliers and peers in the sector to address modern slavery across our supply chains. Our Modern Slavery Statement is also published on the Australian Border Force’s online register.
Understanding our modern slavery risks
Swinburne recognises and supports that freedom from slavery is a fundamental human right. Swinburne relies on the Australian Modern Slavery Act’s definition of modern slavery which includes eight types of serious exploitation:
- trafficking in persons
- slavery
- servitude
- forced marriage
- forced labour
- debt bondage
- deceptive recruiting for labour or services
- and the worst forms of child labour.
The worst forms of child labour mean situations where children are subjected to slavery or similar practices or engaged in hazardous work.
We support the UN Guiding Principles on Business and Human Rights (UN Principles), which are the recognised global standard for preventing and addressing business-related human rights harm.
We recognise our moral obligation to respect human rights and as per the UN Principles we will take action to prevent, mitigate and, where appropriate, remedy modern slavery across our operations, supply chains and in our investments.
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"Our commitment to the elimination of modern slavery is a shared value and priority across our community. Swinburne is committed to contributing to the elimination of modern slavery across the world".
Professor Pascale Quester , Vice Chancellor and President
Our actions to assess and address risks of modern slavery
Swinburne recognises its responsibility to act to prevent, mitigate and, where appropriate, remedy modern slavery in our operations. We also accept our obligation to work collaboratively with our direct and indirect suppliers to address the risks or occurrence of modern slavery across our supply chain.
In 2023, we undertook several actions and contributed significantly to the Australian Universities Procurement Network (AUPN) Anti-Slavery Program’s sector response.
Raising the awareness and understanding of modern slavery
As an educational institution, Swinburne recognises the importance of raising awareness and educating our students and staff on the critical human rights issue of modern slavery.
Throughout 2023, we continued to deliver presentations to senior stakeholders, staff, and students on modern slavery as part of regular Procurement training.
These sessions provided information on the issue of modern slavery and its prevalence, the actions being undertaken by Swinburne, and, importantly, what actions individuals should take to assess and address risks. All members of the Procurement team undertook detailed modern slavery training in 2023 that elevated capability in identifying and acting on risks across Swinburne’s supply chain.
Representatives across Procurement, Legal, Risk and Governance, Research and other operational teams have been engaged on this issue to mobilise cross-university collaboration.
Swinburne's supplier due diligence
To mitigate the risk of modern slavery in key service contracts, the procurement team undertakes the following activities:
- periodic issuing of questionnaires to selected suppliers requesting information to understand risks and actions taken
- tender evaluation requiring suppliers to demonstrate policies, processes, and/or systems to reduce the risk of modern slavery and actions to mitigate or address modern slavery risks
- periodic assessment of wages paid at market rates, including auditing of employee payslips
- executing contracts with obligations specific to reducing labour exploitation and modern slavery.
Swinburne utilised two supply chain transparency and modern slavery risk tools in 2023, solutions from FRDM and Arc Blue (part of Bain & Company), in collaboration with the university sector.
These tools support improved supply chain visibility, undertaking of due diligence actions and providing indicators to measure effectiveness. The results of due diligence during tender processes indicate a wide range of maturity in the modern slavery efforts of the suppliers assessed, and most responses required further information to better understand risks.
In 2023 the FRDM tool continued to identify media alerts relating to suppliers, countries, and industries relevant to Swinburne’s supply chain. These alerts are key for capability uplift. During 2023, recognising where risks might be high across Swinburne’s supply chain, deeper modern slavery reviews were undertaken across key categories.
Cleaning Accountability Framework program support
Swinburne continues to support the Cleaning Accountability Framework’s (CAF) university program. The objective of the CAF is to end labour exploitation and improve work standards through education and advocacy. CAF was successful in obtaining a grant to develop and roll out a program across universities focused on outsourced cleaning and security services. The program will include a compliance framework and assessment methodology, procurement tools (e.g. pricing schedule), and guidance information and resources.
In 2023, Swinburne was one of three universities to participate in the program’s pilot phase. Swinburne’s involvement included testing the CAF tools and templates in the university’s tender for cleaning services (all Melbourne campuses).
Swinburne’s pilot experience will contribute to CAF’s data collation process that will lead to important benchmarking of productivity rates, labour costs, discretionary and non-discretionary costs across the tertiary sector.
Swinburne's contract terms
As a key control, Swinburne’s standard contract templates include clauses addressing modern slavery risk. The terms and conditions outline the supplier’s obligation to investigate modern slavery in its operations and supply chains, assess and address risks, take meaningful actions including due diligence and remediation, and have necessary processes and systems in place.
They also include an obligation for suppliers to include similar clauses in their contracts with suppliers, supporting our intent to create positive impact through the end-to-end supply chain beyond our direct suppliers.
These clauses are embedded in all new supply arrangements and in existing supplier contracts as they are renewed.
Modern Slavery Statement
Collaboration as a university sector
The Australasian University Procurement Network (AUPN), the peak body for strategic procurement across the higher education sector in Australia and New Zealand, is taking an active approach to addressing this critical human rights issue.
Recognising the opportunity for universities to work together to leverage buying power and resources, a working group was established in August 2019 to drive a sector-wide approach. Renamed in 2023 as the AUPN’s Anti-Slavery Program, the vision of the program is to support members to improve supply chain human rights transparency, reduce individual university costs and resources, collaborate on risks and issues for greater impact, and contribute to reporting requirements.
Swinburne’s Director of Procurement, Sustainability and Property Services is Chair of this program, performing an important leadership role in driving outcomes. Working group members contribute their time and effort on a voluntary basis, with each AUPN member university contributing towards the program through a portion of membership fees. This funding goes towards program management, engagement of specialised subject matter expertise, and execution of specific programs.
It is envisaged that both AUPN members and their suppliers will benefit from the improved operational efficiencies of the collaboration and gain improved effectiveness in mitigating risk and improving social performance in supply chains.
The program delivered several key initiatives in 2023.
An Academic Advisory Board was established in July 2020 and refreshed in 2022 with ten academic members from seven universities with experience and expertise in modern slavery.
With an aim to enrich the sector approach, one meeting was held in 2023 that focused on risks and action to address labour exploitation of international students. Key insights were disseminated to universities through communications and guidance materials.
FRDM, implemented in early 2022 as the sector’s modern slavery risk and supply chain transparency tool, was used by thirty-five Australia and New Zealand universities in 2023 to identify risks and take action.
The FRDM solution provided media alerts relevant to the sector’s supply chain and gave visibility to modern slavery risks with direct and sub-tier suppliers. Questionnaires were issued from the tool to a selection of suppliers, although a broad rollout of the questionnaire was delayed ahead of key tool functionality improvements.
A selection process was undertaken during 2023 to select Arc Blue’s (part of Bain & Company) modern slavery tool. This solution determines risk from different sources (e.g. 2023 Global Slavery Index, RESPECT Responsible and Ethical Private Sector Coalition Against Trafficking, NSW Anti-Slavery Commissioner Guidance on Reasonable Steps etc.) and applies at a country, spend category (i.e. broadly aligned to industries), and supplier level.
The aggregated data in the tools reflect the large breadth and scale of our combined supply chains across the sector and the crossover of suppliers being used by multiple universities.
The objective of the Cleaning Accountability Framework (CAF) is to end labour exploitation in the cleaning service industry and to improve work standards through education and advocacy.
CAF engaged the AUPN in early 2021 to assist with the rollout of a program focusing on contract cleaning and security at university campuses which was the subject of a grant awarded to CAF. The program will include a compliance framework and assessment methodology, procurement tools (e.g. pricing schedule), and guidance information and resources.
In 2023 a pilot with three universities, including Swinburne, was undertaken to contribute to CAF’s sector certification and pricing framework. In addition, the AUPN supported CAF through facilitating presentations to the sector, disseminating project information, and facilitating surveys of university teams.
Templates and guidance documents are available to all AUPN members by the program, including a risk questionnaire, contract clauses, supplier code of conduct guidelines, guidance on effective grievance mechanisms and remediation, and modern slavery statement guidelines.
This guidance material aims to provide member universities with information on grievance mechanisms, remediation, and a university’s role in preventing and mitigating modern slavery within their supply chains. It goes beyond procurement/supply chain considerations to provide guidance on grievance mechanisms and remediation more broadly across a university
One of the program’s key objectives is to raise awareness, educate and stimulate action across the university sector, external stakeholders, and suppliers. A new University Modern Slavery Forum was established in 2022 to focus on the prioritisation and leading of actions enabled by the visibility offered through FRDM. All participating universities have representatives attend the Forum meetings, with attendance from university staff outside of procurement teams highly encouraged. The Forums support capability uplift through presentations from external speakers and universities sharing key insights and learnings. Meetings also invite feedback on key elements of the program and identifying opportunities for collaboration. Minutes and key resources are disseminated across teams and made available through the AUPN portal.
The program engaged externally during 2022 to gather insights from other sectors and collaboration programs as well as raise awareness of the AUPN program. Groups engaged include Anti-Slavery Australia, London Universities Procurement Consortium (LPUC), the Properties Council of Australia (PCA), the Belgium University Network, Red Cross Anti-Trafficking Network, and the Australian Catholic Anti-Slavery Network. The program also contributed into the Australian Government’s Modern Slavery Act review. The program was successful in winning The Faculty’s 2022 Sustainability Project of the Year award.
Measuring effectiveness
The influence and purpose of a university in society creates an opportunity for Swinburne to take a leadership role, together with the wider university sector, in addressing this issue. Swinburne recognises that our approach to this critical issue will continue to evolve over time and that measuring our effectiveness is essential to prioritise our efforts for the periods ahead.
We will measure our effectiveness through:
- ongoing contribution into reviews of Swinburne’s risk assessment framework and processes to ensure appropriate and up-to-date consideration of human rights abuses across our operations and supply chains
- periodic reviews of the risk profile of Swinburne’s existing supplier base with attention to the progress made to reduce supplier risk profiles through action and review (for example, responses to questionnaires)
- monitoring of progress against Swinburne modern slavery key performance indicators.
| Key performance indicators | 2023 outcomes |
|---|---|
| Swinburne staff and students made aware of the modern slavery issue through communications and training | More than 70 Swinburne staff (key purchasers/procurers) completed training on Swinburne’s procurement framework which includes modern slavery information and guidance |
| Swinburne supplier engagement reviews (for example, tenders) that have incorporated an assessment of modern slavery risks in the supplier’s operations and supply chain | At least 12 strategic procurement tenders across equipment and service engagements have included a review of supplier modern slavery policies, prevention actions, and labour law compliance. This includes tenders for cleaning services, printing, internal audit, merchandise, lighting upgrade and building refurbishments |
| Swinburne supplier contracts that include modern slavery clauses | 18 new services agreements and four variation agreements including modern slavery clauses were agreed and executed |
| High-risk suppliers engaged in response to risk alerts or undertaking proactive reviews | Two deep modern slavery assessments were undertaken across cleaning (utlising CAF tools) and merchandise categories, including executing detailed engagements with suppliers |
| Year-on-year reduction in the proportion of suppliers indicated as being of a higher risk of modern slavery | Information not available due to a change in risk assessment methodology made by FRDM in 2023, and the introduction of a new modern slavery tool |
| Completion by suppliers of the FRDM modern slavery risk questionnaire | Six suppliers, with assessment ongoing |
Priorities for the future
Swinburne recognises that continuous learning and improvement is an important component of any journey to eliminate modern slavery. Priorities for 2024 will include:
- further capability uplift across the Procurement and Sustainability teams to better identify modern slavery risk and assess supplier maturity (alongside other ESG priorities) in strategic procurement processes
- embedding the use of the new Arc Blue modern slavery tool within Swinburne’s procurement processes, utilising its insights during tenders and deep assessment of higher risk spend areas
- engaging suppliers to secure participation in the rollout of modern slavery questionnaires across selected high risk spend areas
- collaborating with the university sector to support key issues or risks that the AUPN Modern Slavery Program acts on
- engaging with university Governance and Legal teams to review the appropriateness of Swinburne’s complaints procedures and services to support modern slavery grievances
- delivering presentations, communications, and training sessions to raise awareness and build capacity across the university around modern slavery
- implementing Sievo, a new procurement analytics tool, that will support enhanced visibility of Swinburne’s supply chain and associated risks through improved spend data quality.
Consultation with our controlled entities
The activities we have undertaken to date to assess and address the risks in the supply chain of Swinburne covers all controlled entities. Engagement has included briefing and training sessions to ensure teams within controlled entities are aware of the risks and necessary actions.
Strategic Procurement tenders and deep modern slavery assessments have included suppliers servicing all Swinburne controlled entities. Suppliers servicing all controlled entities are included in the data uploaded to the FRDM and Arc Blue modern slavery tools.
Engagement with significant related entities, in particular Swinburne Malaysia (Sarawak), progressed in 2023 including a presentation to their Council.
Get in contact
If you’d like to know more about our commitment to address and diminish Modern Slavery, please contact us at sustainability@swinburne.edu.au.