Anti-modern slavery statement

This statement is made in accordance with the Modern Slavery Act 2018 (Cth) for the year ending on 31 March 2021 (‘RYE 2021’).

Introduction

Datacom Australia Holdings Pty Limited (ABN 45 094 235 373) is reporting on behalf of itself and its ‘Reporting Entities¹' in relation to how we are approaching the global social evil that is modern slavery, and how we are addressing that problem within our own operations and supply chains. We are very committed to this cause, and so have voluntarily applied our anti-modern slavery programme for our entire Datacom Group of companies, owned or controlled by Datacom Group Limited (our parent company incorporated in New Zealand). In this statement, a reference to ‘Datacom’ means any and all of our companies with our Datacom Group.

We have also taken the positive step of being part of an approach with other leading New Zealand businesses to the New Zealand Government, to encourage the introduction of similar legislation in New Zealand to that of the Modern Slavery Act.

We oppose all forms of modern slavery practices and are committed to eradicating these practices from our own operations and supply chains. Modern slavery can take many forms, and even in Australia, New Zealand and the other countries in which we operate, modern slavery still exists. Some of its forms include forced or compulsory labour, servitude, trafficking in persons, debt bondage, forced marriage, forced prison labour and child labour. We are committed to identifying, preventing, mitigating and remediating modern slavery impacts connected to our business.

We recognise that as a large purchaser and supplier of a diverse range of products and services, we must embed appropriate practices in our business and seek to work with suppliers who are aligned to our values.

In this statement, we set out the actions Datacom has taken to recognise and minimise the risk of modern slavery in our business operations and supply chain in the reporting year ending on 31 March 2021.

Our structure, operations and supply chains

Datacom works with organisations and communities around the world to solve their biggest challenges, imagine new possibilities, and help move them to a better place by connecting people and technology.

Built on strong local values, world-class technology, and experienced people who genuinely care, Datacom sets a new standard in IT services. Datacom supports customers through a broad range of services and solutions that span technology, operations, digital and products, all underpinned by robust industry experience and insight. With almost 7,000 people working across Australia, New Zealand, Asia, Europe and the Americas, Datacom is truly world-class in capability, and proudly local at heart.

Datacom has a wide range of services and products including professional and technology management services, data centres, cloud services, integrated SaaS solutions, security offerings and management, hardware and software reselling, and contact centres. Often our customer selects the IT technology that we procure for on-supply. That means that although these suppliers are within our supply chain, we do not make the procurement decision.

In Australia, Datacom employs over 3,250 people, with over 3,300 people in New Zealand.

The majority of Datacom Group’s businesses operate in Australia and New Zealand, with some technical operations in Malaysia and the Philippines, and very small satellite functions in Singapore and the United Kingdom.

Datacom Australia Holdings Pty Limited is a wholly owned subsidiary of Datacom Group Limited and operates the Australian business. All controlled entities within the Australian business are wholly owned by Datacom Australia Holdings Pty Limited.

You can find further information about Datacom in our latest annual review.

We work with approximately 7,000 suppliers globally. Our suppliers range from large vertically integrated global providers to small businesses, mainly based in Australia, New Zealand, Asia, the United States of America and the European Union.

Our relationships include suppliers from the following sectors: technology, hardware and equipment, facilities management, waste management, office supplies, catering, cleaning, labour hire, professional services and marketing. We use these products and services in our business and we also operate as a reseller of products and services such as software, technology infrastructure and associated hardware.

Potential modern slavery risks

Our initial risk assessment and prioritisation of work focussed on the aspects we considered to be higher risk and to coincide with a broader programme of work we had commenced to improve and consolidate our procurement practices generally within Datacom. We have also paid greater attention to the modern slavery risks that would cause the greatest harm to individuals.

Internal operations

We re-assessed our internal operations and identified that our operations present the same risks we identified in our Anti-Modern Slavery Statement for last year. That is, we have a lower risk of modern slavery. As a part of this assessment, we paid particular attention to areas that could be considered to be higher risk such as operations outside New Zealand and Australia undertaken by businesses within the wider Datacom Group, recruitment practices and temporary workforce arrangements.

The majority of our workforce are permanent employees and would be considered to be in the higher skill and lower risk brackets. Our employees are employed on contracts with standard terms allowing the employee to terminate their employment on notice and all employees are paid at or above the relevant minimum wage or other award or entitlement bands. We do have blocks of temporary workers from time to time which we use for “surge” resourcing in Australia - supplied directly through our recruitment and temporary workforce providers. These companies are at the “high-end” of reputability and employ these workers, who we then induct and train. This category is one we need to do further on to better assess the potential modern slavery risks. Finally, in our supplier chain we have only a few individual contracted workers. These are largely individuals with specialised skills or experience and are engaged as professional contractors.

We also recognise that some of the Datacom Group’s operations in countries outside New Zealand and Australia are located in higher risk geographies (particularly in Asia). While these operations are not controlled entities of Datacom Australia Holdings Pty Limited, the services they provide are used by the wider Datacom Group. To address the geographic risk we have performed a high-level review of the operational practices of our off-shore businesses and consulted with them to explain and help identify any potential modern slavery risks. This included considering and reviewing processes and systems and conducting interviews and discussions with key representatives. Whilst progress on this aspect of our business was delayed during 2020 due to COVID-19, we will continue to work with these teams to assess these businesses in more detail but recognise that this may also be delayed further as Asia is still very much in the grip of COVID-19 lockdowns and travel bans.

We have also assessed the suppliers to our operations within our broader supplier assessment categorisation and will prioritise working with these suppliers further according to the higher risk categories we identified as a part of the general supply chain review and procurement consolidation process we are undertaking at a Datacom Group level.

To embed ongoing monitoring and vigilance, Datacom’s anti-modern slavery programme will be further rolled out to our business units with additional training to ensure widespread implementation by those businesses as well. This is very much an ongoing “work in progress” for us.

Supply chain

For our supply chain, as a result of our supplier risk assessment outlined above, we identified very low risk suppliers through to those within a potentially high-risk category. In the higher risk category, we identified suppliers of technology products and services (for both internal use and on-supply or resale to customers), cleaning, maintenance services, field services, application development services, construction and building works, freight, catering, office supplies, waste management, temporary workforce augmentation and marketing products.

Of course, as this supplier risk assessment was primarily focused on industry and function, there is still more work for us to do to dive deeper into our major suppliers to look at specific geographies and actual practices of the specific suppliers.

We also understand that our suppliers have their own suppliers, which may also connect us to modern slavery risk. We do not currently have a detailed understanding of this risk beyond our first-tier suppliers. We are aware, however, of some industry risks that will be in the lower tiers of our supply chain. Some of our suppliers that provide IT hardware, for example with rechargeable batteries, will have significant modern slavery risk in their supply chains. This is an area for further work in the next reporting years.

We intended to prioritise our supplier engagement activities according to those higher risk categories over RYE 2021 but have been delayed in progressing according to risk categorisation. Instead, we have focussed on rolling out preliminary programmes to assess new suppliers across the Datacom business. We intend to target a prioritised engagement programme and an on-boarding process to apply to all new suppliers during the next reporting year in Australia and New Zealand.

Our Human Rights Policy and Protected Disclosure Policy (“Whistleblower Policy”) specifically recognise the risk of modern slavery and encourages our employees, contractors and suppliers to report and act on any modern slavery concerns. Where concerns are investigated and substantiated, we are committed to taking appropriate action. Further information regarding the investigation process is publicly available in the Whistleblower Policy on our website.

We intended to set up a programme this reporting year to promptly respond to and remediate any modern slavery situations, if they arise, but COVID-19 impacted our ability to do this. This programme is currently under development for commencement in the next reporting year. We envisage that the programme would include working with the relevant supplier to manage the risk of modern slavery, remediate any harm caused, and put in place processes to prevent it from happening again. If cooperation is not forthcoming in a satisfactory manner, termination of the supplier contract may be warranted. Our preference, however, is to work with suppliers so that they can improve the conditions and rights of workers and require that those suppliers remediate any harm caused.

COVID-19 impact

We recognise the increase in vulnerability of workers in global operations and supply chains to modern slavery arising from the global response to COVID-19. We have not been required to actively manage any actual or perceived risk arising from COVID-19 in the current reporting year beyond the risks that already exist in our operations and supply chain.

The biggest impact to us has been the increase in use of “surge” resourcing in Australia, where we have had to engage temporary workers through our recruitment and workforce providers. This has meant more temporary workers in our workforce. While we are confident that these providers are reputable, we need to do more assessment with them to better understand the potential modern-slavery risks that this may pose.

Another impact of COVID-19 has been the delay in implementing several of our planned initiatives — particularly around our Asian operations. While this has been disappointing, we have ensured we are looking after our employees in Malaysia, the Philippines and Singapore during these difficult times.

Action to assess and address modern slavery risks

Our activities in the current reporting year to 31 March 2021 focussed on continuing a scoping exercise of our potential risks. We have also successfully rolled out new policies, supplier assessment documentation and processes, contractual provisions and a training and compliance programme.

This has allowed us to better understand our principal areas of risk and commence the programme in the next reporting year.

Actions have we taken in RYE 2021
Embedded our Datacom Code of Conduct.
Embedded our Human Rights Policy.
Continued with our modern slavery risk assessment.
Launched our Supplier Code of Conduct and new supplier on-boarding procedures, including a detailed anti-modern slavery questionnaire.
Commenced implementing anti-modern slavery commitments into our supplier contracts.
Implemented a training and compliance programme for the business, including compulsory annual training for all employees.

Our planned actions for next reporting year

Over the next year (ending on 31 March 2022), our key focus areas will be:

  • Assessing any ongoing COVID-19 impact or areas of additional concern or risk raised, with a focus on temporary workforce suppliers
  • Continuing with internal stakeholder engagement and ongoing review of business practices, including delivering appropriate awareness training on modern slavery principles to relevant lines of business
  • Embedding our policies
  • Rolling out our supplier on-boarding procedures and supplier due diligence, as well as reviewing our supplier contract terms
  • Designing a programme to monitor and assess compliance within our supplier community and address any areas of remediation
  • Continuing the training and compliance module throughout Datacom.

Assessment of our effectiveness

To date, we believe that we have effectively put in place the initial foundation to assess and mitigate the risks of modern slavery in our internal operations and supply chain, and have started the process of raising awareness on this important topic. But we appreciate that our progress has not been as swift as we initially hoped. There is a lot more still to be done, and in the next reporting period, we will develop processes for assessing supplier risk and measuring and assessing the effectiveness of our modern slavery programme.

We intend to continue with our actions listed above, and importantly, continue to educate and train our business teams so they are alert to the risks. We plan in time to develop a programme of monitoring and auditing our anti-modern slavery programme, including reviewing selected suppliers.

Most importantly, we recognise this is not a static programme. We will seek to adopt a process of continuous improvement, assessing if processes are up-to-date and effective, and will endeavour to focus on the areas with the highest potential impact on people.

Consultation with the Reporting Entities

Datacom Australia Holdings Pty Limited owns 100% of our Reporting Entities, and Datacom Group Limited owns 100% of any Datacom Group company carrying on business in Australia. These entities operate as part of a fully integrated business in Australia and part of the wider Datacom Group, with a central Datacom Group Board, centralised leadership team from all lines of business and a Datacom Group corporate support function that supports all lines of business (including HR, risk, property, procurement, finance and legal).

The consultation process included working with representatives of all lines of business dealing with procurement, human resources, business operations, sales and finance, risk and legal, to update this Statement.

Individual Reporting Entities Directors, and the Group Leadership Team as a whole, were made aware of the anti-modern slavery programme proposed, consulted on the programme’s planned content and application. They have fully supported the Group-wide adoption of our programme.

Approval

This Statement has been approved by the Board of Directors of Datacom Australia

Holdings Pty Limited for itself and each of the Reporting Entities on 17 June 2021.

Alex Coates — Director

DATACOM AUSTRALIA HOLDINGS PTY LIMITED

Datacom Group Limited also approve this statement on behalf of the Board of

Datacom Group Limited.

Tony Carter — Chair

DATACOM GROUP LIMITED

¹ Our Reporting Entities are Australian companies owned or controlled by Datacom Australia Holdings Pty Limited or companies in the Datacom Group carrying on business in Australia, being Datacom Data Centres Pty Limited (ABN 58 110 978 179), Datacom Systems (AU) Pty Limited (ABN 39 135 427 075), Datacom Connect Pty Limited (ABN 16 103 112 303), Datacom New Zealand Limited (a New Zealand incorporate company, ABN 95 875 120 116) and Datacom Systems Limited (a New Zealand incorporated company, in process of registration as a foreign company with ASIC).