MODERN SLAVERY STATEMENT 2021
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MODERN SLAVERY STATEMENT 2021
ACKNOWLEDGEMENT CEO MESSAGE
OF COUNTRY
Tabcorp acknowledges Aboriginal
and Torres Strait Islander peoples I’m pleased to present Tabcorp’s Tabcorp also formalised its
as the Traditional Custodians of Modern Slavery Statement in commitment to upholding human
the land on which we live. We pay respect of FY21. rights by launching our Human
our respects to Elders past, Rights Policy. We believe it is our
present and emerging. Our purpose of Excitement with responsibility to respect human
Integrity underpins everything rights and we expect our suppliers
we do at Tabcorp. We act with to uphold human rights and
integrity and are committed to integrate appropriate labour
creating value for our stakeholders and human rights policies and
in a responsible and sustainable practices into their business
manner. operations.
David Attenborough
Managing Director and
Chief Executive Officer We’re committed to ethical, We will continue to make it
INTRODUCTION sustainable and socially a priority to address modern
responsible procurement to slavery risks in our operations
ensure that the partners we work and supply chain.
This Modern Slavery Statement
with make fair, responsible and
covers the activities of Tabcorp
ethical decisions.
Holdings Limited (ABN 66 063
780 709) and the consolidated
In FY21 the COVID-19 pandemic
entity comprising Tabcorp and
continued to disrupt our way of
its subsidiaries (“Group” or
life and challenge our business
“Tabcorp”) and the Group’s
operations and supply chain. David R H Attenborough
interests in joint arrangements
During this time, our priority has Managing Director and
and associates in respect of the
been ensuring the safety and Chief Executive Officer
financial year ended 30 June 2021
wellbeing of our people and 9 December 2021
(“FY21”) in identifying and
supporting our partners and
addressing the potential risk
the community.
of modern slavery and human
trafficking in our operations
Notwithstanding the challenges
and supply chain.
of the ongoing pandemic, in
FY21 Tabcorp made a number
Refer to page 12 for the list
of enhancements to our
of Tabcorp entities that are
procurement processes and
considered reporting entities
policies to ensure that potential
under the Modern Slavery Act
modern slavery risks in our
2018 (Cth). This Statement is
operations and supply chain
made on behalf of these reporting
are identified and addressed.
entities as well as all other
controlled entities of Tabcorp
Holdings Limited.
Tabcorp Modern Slavery Statement 2021 02ABOUT TABCORP
Tabcorp is a world-class gambling Lotteries and Keno Wagering and Media Gaming Services In FY21, Tabcorp reported
entertainment group, listed on the revenues of $5.7 billion and a net
The Lott is Australia’s leading TAB is a leading omni-channel MAX is Australia’s largest gaming
Australian Securities Exchange profit after tax of $269 million.
official licensed lottery business wagering operator in Australia, services provider, offering a wide
with a market capitalisation of Tabcorp’s businesses generated
with operations in NSW, Victoria, providing betting experiences range of services, including
approximately $11.5 billion at $4.9 billion of total benefits for
Queensland, South Australia, across digital channels and in electronic gaming machine
30 June 2021. our stakeholders in FY21, which
Tasmania, ACT and Northern retail (on-course in licensed ("EGM") monitoring and related
comprised State and Federal
Territory. venues and agencies) in NSW, services, EGM financing and
Tabcorp has national reach Government taxes, employee
Victoria, Queensland, South maintenance, and solutions and
through retail partnerships costs, shareholder dividends,
Keno is a social lottery-style Australia, Tasmania, ACT and other value-added services.
with over over 9,000 venues, payments to racing industry
game that is played in licensed Northern Territory.
the largest retail footprint of any bodies and commissions paid
clubs, hotel and TABs in certain
company in Australia, in addition to our retail partners.
Australian states and territories. Sky Racing is a multi-channel
to digital channels.
racing and sports broadcaster
For more information about
Tabcorp’s retail network ® in Australia.
Tabcorp’s business operations
comprises business partnerships and strategy please refer to our
Our international operations
with venues that sell lotteries, 2021 Annual Report available
comprise an Isle of Man based
Keno and wagering products. at www.tabcorp.com.au.
international wagering pooling hub
This includes TAB agents, hotels,
(Premier Gateway International)
clubs and newsagents.
and the US based vision and
distribution hub and licensed tote
Tabcorp employs over 4,000
provider (Sky Racing World).
people across our operations.
We operate three market leading
businesses:
Tabcorp Modern Slavery Statement 2021 03ABOUT TABCORP CONTINUED
Australian Operations
Northern Territory Queensland
8
Western Australia New South Wales
8
South Australia Victoria
8 8
LEGEND
ACT
Lottery
Global Operations
8
8 Keno
Media distribution Wagering
Media broadcasting
and licensed tote pooling hub in
Wagering to 50+ countries
provider in USA the Isle of Man
Tasmania
Media
Gaming Services
Tabcorp Modern Slavery Statement 2021 04FY21 PROPOSED GOVERNANCE AND
DEVELOPMENTS DEMERGER POLICY FRAMEWORK
Key developments since the • Incorporated modern slavery Tabcorp has announced its Tabcorp is committed to good regularly reviewed and revised as
beginning of the reporting and human rights due diligence intention to undertake a demerger corporate governance and to appropriate to reflect Tabcorp’s
period include: into the standardised processes of its Lotteries and Keno business maintaining leading corporate evolving needs, changes in law
and templates for Tabcorp’s (“Demerger”) following the governance practices which and developments in corporate
• Launched Tabcorp’s Human
procurement processes. conclusion of a strategic review help us meet or exceed the governance practices.
Rights Policy.
• Conducted supplier risk of structural and ownership requirements of applicable
• Established a cross-functional options to maximise value for legislation and corporate For more information about
assessments, supplier
Steering Committee comprising shareholders. The proposed governance standards. Tabcorp’s corporate governance
segmentation analysis and
key representatives from Demerger will create two Our corporate governance framework, practices and
profiling to identify country
the business to oversee standalone, market leading arrangements are core to our policies please refer to our
of origin and demographics
Tabcorp’s modern slavery ASX-listed companies with distinct vision to be The Trusted Gambling 2021 Corporate Governance
of suppliers, size of spend and
risk management, labour and operating profiles, strategies and Entertainment Company and Statement available at
category of the goods/services.
human rights policies and growth opportunities. to building on our purpose of www.tabcorp.com.au.
practices. • Enhanced pre-screening
delivering Excitement with
supplier activities including
• Developed and incorporated The proposed Demerger is subject Integrity. Tabcorp has a number of
modern slavery related
training on our modern slavery to shareholder, court, regulatory policies in place that support
questions which have been
and human rights policies and other stakeholder approvals Tabcorp’s corporate governance our governance framework to
added to our procurement
and practices into our induction and is targeted for completion framework applicable in FY21 address modern slavery in our
tendering templates.
program for all new starters. by June 2022. For further is summarised in the diagram operations and supply chain.
• Introduced key performance information refer to Tabcorp’s ASX below. Tabcorp’s corporate These policies are set out on
• Reviewed and enhanced policies
indicators for our Procurement announcements of 5 July 2021, 18 governance arrangements are the following pages.
relating to modern slavery,
team members for modern August 2021 and 19 October 2021.
including our procurement
slavery, sustainability and
policy, to ensure they uphold
mandatory training. Board of Directors Other independent
our commitments to modern assurance
slavery and human rights and • External Auditor
align with market practice. Audit
Risk and People and
Technology Nomination
• Internal Audit
Compliance Remuneration
Committee Committee Committee egal and other
L
Committee Committee
professional advisers
(as necessary)
Standing Board Committees
MD & CEO
Executive Leadership Team
Management Committees including:
• Data Governance Committee • Information Security Steering Committee
• Disclosure Committee • Integration Steering Committee
• Executive Risk and Compliance Committee • Pandemic Preparedness Working Group
• Inclusion and Diversity Committee • Whistleblower Committee
Frameworks, policies, procedures and practices as approved by
the Board and the Executive Leadership Team
Tabcorp Modern Slavery Statement 2021 05GOVERNANCE AND POLICY FRAMEWORK CONTINUED
Tabcorp Code of Conduct
Tabcorp’s Code of Conduct is founded upon Tabcorp’s values and sets out the standards of behaviour that are expected of all employees, Directors and contractors.
The Code of Conduct is one of the ways we put Tabcorp’s integrity and values into practice. It is built around the recognition that everything we do in connection with our work at Tabcorp
should be measured against the highest standards of ethical business conduct.
The Code of Conduct defines the expected standards of behaviour at Tabcorp across eleven guiding principles including acting ethically and with integrity, treating people with dignity and
respect and calling out dishonest and unethical behaviour. It includes practical guidance for employees about how to access support and make an official report if they experience or witness
behaviour not aligned with the Code.
The Board oversees and approves material changes to the Code. The Executive Leadership Team and senior managers are responsible for instilling and reinforcing Tabcorp’s values, the
Code and Group policies. The Code and key policies are communicated to employees and made available to new starters. Training and awareness of the Code and key policies are provided
to employees, and changes are communicated when required. Material breaches of the Code and key policies are reported to the Board or relevant Committee as appropriate.
Create
Do it as Do the Right Explore What’s Make a
Awesome
One Team Thing Possible Difference
Moments
We are stronger together. We all have the power to delight We’re passionate and proud
We always act with integrity, We listen. We think big.
We are inclusive, collaborative and inspire, so let’s dial up about making a real change for
standing up (and speaking out) We ask ‘what if’. Our curiosity for
and know that amazing ideas the excitement and create customers, and benefiting our
for what’s right what’s next will shape tomorrow
can come from anywhere awesome moments communities
Tabcorp Modern Slavery Statement 2021 06GOVERNANCE AND POLICY FRAMEWORK CONTINUED
Supplier Code We also expect our suppliers We expect our suppliers to Whistleblower Policy Inclusion and
to monitor their suppliers' uphold human rights and integrate
of Conduct Consistent with our commitment Diversity Policy
compliance with Tabcorp's appropriate labour and human
The Supplier Code of Conduct Supplier Code of Conduct and rights policies and practices to maintaining a culture of honesty Tabcorp’s Inclusion and Diversity
is one of the ways in which ensure timely remediation of any into their business operations. and integrity, Tabcorp has a Policy sets out our commitment
Tabcorp ensures that we work non-compliance. Suppliers are Whistleblower Policy and to a culture of inclusion and the
with partners that make fair, required to notify us if they Through this policy, Tabcorp framework in place to respond to creation of a bias-free workplace
responsible and ethical decisions. become aware of an actual commits to: any reports of actual or suspected where all are welcomed and
breach or reasonable likelihood misconduct within Tabcorp and to respected. The People and
• Undertake human rights due protect whistleblowers from
The Supplier Code of Conduct of breaching the Code. Remuneration Committee is
diligence, risk assessment detrimental conduct and breaches
outlines the expectations we have responsible for overseeing the
and monitoring processes of their confidentiality. This policy
of our suppliers across six areas: Human Rights Policy to understand, assess and
policy, monitoring Tabcorp’s
applies to Tabcorp’s current and inclusion and diversity strategy
• Integrity, ethics and corporate At Tabcorp, we believe that address potential human rights former employees, Directors, and reviewing progress against
conduct; human rights are universal and violations associated with contractors and suppliers, its objectives.
• Corporate governance; fundamental rights that preserve our own operations and the including employees of
the inherent freedom, dignity and activities of our business contractors and suppliers.
• Labour and human rights;
partners and suppliers; Workplace Health,
equality of all human beings.
• Privacy and cyber security;
• Regularly communicate our Matters are reported through
Safety and Wellbeing
• Health, safety and wellbeing; In FY21, Tabcorp launched its expectation to respect human the Tabcorp Integrity Protection Policy
and Human Rights Policy which rights to team members, Service ("TIPS"), an independent, Tabcorp is committed to providing
• Environmental management. formalises our commitment to business partners and suppliers anonymous and secure service a safe environment for employees,
respecting the rights of the people and include this in relevant delivered by Deloitte, or to any contractors and visitors, and
Tabcorp’s approach is to we interact with and are impacted training programs; of a number of Whistleblower actively promotes health, safety
work collaboratively with our by our business operations and • Establish confidential reporting Report Officers. The whistleblower and wellbeing in the workplace.
suppliers to meet and exceed the relationships. Tabcorp’s Human processes for those wishing program is overseen by an Internal Through our Health, Safety and
expectations set out in this Code. Rights Policy complies with the to report human rights related Whistleblower Committee, which Wellbeing Policy we are committed
We expect our suppliers to assess guidelines for companies set out concerns and, where has accountability and a direct to eliminating or reducing health
their compliance with this Code in the UN Guiding Principles on appropriate, seek remedy; and reporting line to the Board Audit and safety risks, demonstrating
and report on any deficiencies Business and Human Rights. Committee. The Chairman of the leadership in, and commitment to,
• Undertake annual public
or breaches. We may require Tabcorp is committed to respecting Audit Committee, and where all areas of health, safety and
reporting on our legal,
suppliers to provide evidence and upholding the internationally necessary or appropriate, the wellbeing and fostering a culture
regulatory and voluntary human
of their compliance with this Code recognised human rights set out Chairman of the Board, is able of wellbeing by providing
rights commitments.
and we may conduct independent in the International Bill of Human to securely access whistleblower resources that reinforce healthy
audits of compliance. Rights, the International Labour reports and review the action lifestyle choices.
Organisation’s Declaration on taken. The Whistleblower Policy
Fundamental Principles and Rights is regularly communicated to all
at Work and the United Nations employees to raise awareness of
Declaration on the Rights of the policy and explain key features
Indigenous Peoples. such as how to make a
whistleblower report and the
protections available to
whistleblowers.
Tabcorp Modern Slavery Statement 2021 07STAKEHOLDER ENGAGEMENT RISK MANAGEMENT
Tabcorp engages with a number Tabcorp is a member of the Tabcorp’s Risk Management In FY21, Tabcorp established a
of stakeholders in addressing Certified Institute of Procurement Framework, policies and cross-functional Modern Slavery
modern slavery risks. Specialists and the Fintel Alliance, procedures set out the roles, and Human Rights Working Group
the Australian Transaction Reports responsibilities and guidelines comprising senior managers from
Tabcorp conducts vendor and Analysis Centre’s ("AUSTRAC") for managing financial, operational Procurement, Risk, Legal,
governance meetings with public-private partnership that and other risks associated with Corporate Responsibility,
strategic, tier one suppliers combines the expertise and skills our business, including human Governance and People and
on a monthly or quarterly basis. of Federal and State Government rights and modern slavery risks. Culture. This Working Group
All relevant risks, including intelligence and law enforcement The Framework enables the oversees the company’s
modern slavery, are addressed agencies and private sector identification, evaluation, identification, management,
in these meetings. businesses to protect the monitoring, management, mitigation, remediation (where
Australian financial system and reporting and oversight of necessary) and disclosure of
Tabcorp regularly engages with community from criminal abuse. risk throughout the Group. modern slavery and human
industry partners and associations rights risks.
across lotteries and wagering Human rights and modern
regarding our Fair Work slavery risk identification and
Compliance program in order management information is
to provide holistic guidance and reported to the Executive
support to our retail partners Leadership Team and the Board
in the administration of their Risk and Compliance Committee.
employment obligations. Senior managers in Tabcorp's
Procurement, People and
Culture and Legal functions
have accountability for managing
these risks.
Tabcorp Modern Slavery Statement 2021 08TABCORP’S OPERATIONS
Tabcorp employs or engages Fair Work Retail STEP ONE: STEP THREE:
over 4,000 people, over a third
Compliance Program Set expectations Monitor compliance
of which are casual or contracted
Tabcorp conducts comprehensive Tabcorp requires our retail
employees. We are committed to Tabcorp sells its lotteries and
due diligence and onboarding partners to complete online
complying with all applicable laws wagering products through a
of our retail partners. The terms self-audits on the key obligations
and regulations with respect to network of lotteries franchisees
of our contractual agreements required by them as employers.
wages, working hours, leave and wagering agents across
with retail partners specify the We also undertake annual site
entitlements, superannuation and Australia.
requirement to comply with surveys in venue which requires
workers’ compensation insurance.
workplace laws and Tabcorp’s the retail partner or an employee
We undertake an annual minimum We have undertaken significant
right to audit and access records to answer a series of brief
wage review across all our work to protect vulnerable
where required. We ensure our questions to enable Tabcorp to
operations to ensure that Tabcorp workers and prevent potential
Operations Manual and other capture potential non-compliance
employees are compensated fairly contraventions of the Fair
written commitments detail our or information gaps. Tabcorp has
and in accordance with relevant Work Amendment (Protecting
expectations to comply with established a dedicated Retail
awards or enterprise agreements, Vulnerable Workers) Act 2017 in
workplace laws. Workers Hotline, managed
where applicable. our retail networks. In 2018, we
independently by Deloitte, to
developed and implemented a
program to ensure our lotteries
STEP TWO: enable the employees of Tabcorp’s
Tabcorp has reviewed its
franchisees and wagering agents
Educate and train retail partners to anonymously
operations regarding our provision
report suspected non-compliance
of labour to other organisations comply with the Act regarding Tabcorp ensures our retail
or concerns regarding their
and has assessed and taken steps minimum rates of pay, awards partners are aware of obligations
workplace entitlements.
to address any potential risks. and enterprise agreements. The and consequences of non-
program comprises four steps: compliance with workplace laws
set expectations; educate and through targeted in-house and STEP FOUR:
train; monitor compliance; and publicly available training Take further action
take further action. offerings, templates, guidance Tabcorp has developed a process
materials and other resources. and governance around responses
Tabcorp trains our business to known or suspected non-
development managers to ensure compliance in our retail network.
they are aware of our partners’ Our approach is to work
workplace obligations and collaboratively with retail partners
Tabcorp’s role in upholding to ensure they comply with their
them. Tabcorp also publishes a obligations. In the event Tabcorp
quarterly series of educational does not believe a satisfactory
communications to our retail resolution has been reached,
network on key obligations and we may suspend or terminate an
to raise awareness of trends agreement with a retail partner.
identified through our monitoring
activities.
Tabcorp Modern Slavery Statement 2021 09TABCORP’S OPERATIONS CONTINUED
TABCORP’S Tabcorp's non-Australian suppliers Supplier risk Tabcorp has included clauses in
our supplier contracts to ensure
SUPPLY CHAIN by location management and
compliance with applicable laws
In FY21, Tabcorp engaged directly due diligence relating to modern slavery and
with over 1,823 suppliers and Tabcorp has a centralised process human rights, including the
contractors. Approximately 68% 2 1 1 for supplier pre-qualification, Modern Slavery Act 2018 (Cth).
2
of Tabcorp’s FY21 total spend 2 onboarding, contracting,
was with 50 suppliers. Our largest monitoring and relationship Suppliers that represent high
category of spend was information 6 management. Due diligence and business impact and/or value
and communication technology at risk assessments are undertaken to Tabcorp are managed by
30%. This includes items used to as part of pre-qualification for all dedicated specialists in our
develop and manage our systems, potential suppliers. This process Procurement team. The team
Number of
hardware and software purchases includes assessment for anti- meets at least quarterly with these
non-Australian
and purchases within our gaming money laundering, sanctions lists, suppliers to ensure the success
suppliers in each
business. The remaining 70% of adverse media monitoring and of our business relationship. All
country
procurement spend was on labour license status. relevant risks, including modern
activities including property, slavery, are addressed in these
recruitment and professional As part of the onboarding process, meetings.
services, travel and consumables. Tabcorp expects all its suppliers to
assess their compliance with the
68
Only 4% of total FY21 spend was Tabcorp Supplier Code of Conduct
with 82 international suppliers and report on any deficiencies or
and 94% of this spend was with breaches. We may require
suppliers based in countries suppliers to provide evidence of
deemed as low risk for modern their compliance with the Code
slavery according to the Global Key and we may conduct independent
Slavery Index. audits of compliance.
United States
France
Singapore
United Kingdom
Canada
Japan
Switzerland
Tabcorp Modern Slavery Statement 2021 10TABCORP’S OPERATIONS CONTINUED
Modern slavery risk in We have identified Tabcorp's key Labour hire Remediation
risk areas within our supply chain
the supply chain Tabcorp has risk management Tabcorp’s approach is to
as the procurement of information
Tabcorp has assessed the technology computer and processes in place to ensure we work collaboratively with our
maturity of our existing policies, electronic equipment, facilities are compliant with State suppliers to ensure they meet
systems and controls and management and labour hire Government labour hire licencing our expectations regarding
remediation mechanisms to arrangements. Information schemes in the Australian Capital modern slavery and human rights
identify and manage modern technology is our largest category Territory, Queensland, Victoria and standards. If Tabcorp were to
slavery risks. Following this, we of spend and is predominately South Australia. These schemes identify a modern slavery risk
developed a multi-year plan to sourced through Australian based are designed to bring integrity and with a supplier, we would seek
manage our ongoing modern suppliers. We have improved our scrutiny to the labour hire sector further information from the
slavery response. existing risk management and and ensure vulnerable workers supplier and collaborate to resolve
remediation frameworks where are kept safe from exploitation the situation. We did not find any
We have also undertaken risk required to mitigate these risks. and being underpaid. Under these instances of modern slavery in the
mapping of our supply chain to laws, Tabcorp must ensure that supplier assessments undertaken
identify priority risk areas where As part of Tabcorp’s supplier we only procure designated labour this year.
there may be a higher risk of governance framework, we hire services from licenced
modern slavery practices. In regularly engage with suppliers providers. Labour hire licences are
undertaking this risk profiling in these priority risk areas and granted by State-based authorities
we considered: expect them to take action toward in accordance with legislative
meeting or exceeding the modern criteria, which includes a ‘fit and
• The category of the product proper person’ test and regular
slavery and human rights
or service being procured; reporting obligations.
requirements outlined in our
• The geographic location of Supplier Code of Conduct.
the supplier; Tabcorp is continually assessing
• High risk business models; and our supply chain to confirm that
all relevant suppliers hold an
• Suppliers that engage or employ
appropriate labour hire licence.
vulnerable people.
To ensure relevant new suppliers
are appropriately licenced before
we engage them, our supplier due
diligence process includes labour
hire assessment questions, and
supplier terms include obligations
to maintain appropriate licences.
Tabcorp Modern Slavery Statement 2021 11FUTURE REPORTING CONSULTATION AND
PRIORITIES ENTITIES APPROVAL PROCESS
Going forward, and in the context The following Tabcorp entities All Tabcorp entities operate under
of the proposed Demerger, are considered reporting entities a common set of governance and
Tabcorp will progress the following under the Modern Slavery Act risk management policies and
initiatives: 2018 (Cth) in respect of FY21 and programs. This includes the
are covered by this Statement: policies and programs through
• Incorporate modern slavery
which modern slavery and human
and human rights into Code Tabcorp Holdings Limited
rights risks in our own operations
of Conduct training which is
Tabcorp Gaming Holdings Pty Ltd and our supply chains are
undertaken by all Tabcorp
assessed and addressed by
employees and contractors Tabcorp Wagering (Vic) Pty Ltd
Tabcorp.
annually; and
Tabcorp Assets Pty Ltd
• Uplift our supplier due diligence A process of consultation across
capabilities by implementing Tabcorp Finance Pty Ltd
Tabcorp and its reporting entities
new technology that will Tabcorp International Pty Ltd helped to guide the preparation
enhance the supplier risk of this Statement. This included
assessment process. Tabcorp Wagering
engagement with members of
Participant (Vic) Pty Ltd
senior management heading every
Tab Limited relevant function within Tabcorp,
the Executive Leadership Team
Tabcorp International and the Directors of the reporting
No. 4 Pty Ltd entities.
Keno (Qld) Pty Ltd
This Statement has been
Sky Channel Pty Ltd approved by the Board of Tabcorp
Tatts Group Limited Holdings Limited.
Tattersall's Holdings Pty Ltd
Tattersall's Sweeps Pty Ltd
New South Wales Lotteries
Corporation Pty Ltd
Golden Casket Lottery
Corporation Limited
Tatts Lotteries SA Pty Ltd
Ubet QLD Limited
Ubet SA Pty Ltd
Maxgaming Holdings Pty Ltd
Tabcorp Modern Slavery Statement 2021 12WWW.TABCORP.COM.AU
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