Modern Slavery Statement 2020
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Modern Slavery Statement 2020
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Contents
About us.................................................................................................................................................................. 3
Vision and Mission ............................................................................................................................................. 4
Brief Statement from CEO .................................................................................................................................. 5
Structure, Operations and Supply Chain ................................................................................................................ 6
Our Organisational Structure ............................................................................................................................. 6
Our Governance Framework .............................................................................................................................. 7
Our Operations ................................................................................................................................................... 7
Our Supply Chain ................................................................................................................................................ 9
Modern slavery risks in Operations and Supply Chain ........................................................................................... 9
Operational Risks ............................................................................................................................................. 10
Our People …………………………………………………………………………………………………………………………………………………10
Modern Slavery Gap Analysis …………………………………………………………………………………………………………………….10
Supply Chain Risks……………… ………………………………………………………………………………………………………………………12
Our COVID-19 Response………………………………………………………………………………………………………………………………13
Action taken to assess and address risk……………………………………………………………………………………………………………14
Modern slavery action plan and road map………………………………………………………………………………………………….14
Effectiveness Assessment………………………………………………………………………………………………………………………………..15
Other……………………………………………………………………………………………………………………………………………………………….15
Disclosure Note
This statement has been made on behalf of Catholic Metropolitan Cemeteries Trust. This Statement covers all
entities owned or controlled by Catholic Metropolitan Cemeteries Trust.
ABN 85 744 325 709
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About us
This statement involves the Catholic Metropolitan Cemeteries Trust (ABN 85 744 325 709), trading
as Catholic Cemeteries and Crematoria (CCC), is a Trust constituted under the Crown Lands Act
1989 (NSW) and currently transitioning to a Crown Land Manager pursuant to the Crown Land
Management Act 2016 (NSW). It is not controlled by any other entity.
It is a registered as a charity with the Australian Charities and Not-for-Profit Commission. We have
existed for over 150 years, commencing operations in 1867 at Rookwood. The principal activities
of the Trust are to provide and maintain burial sites for all members of the community, caring for
families with dignity and respect.
Catholic Metropolitan Cemeteries Trust (CMCT) believe that everyone has the right to a dignified
funeral and enduring, future care of the family’s resting place. CMCT believe that cemeteries are
sacred and historical places in our society for the preservation of memories, and that the funeral is
just the beginning of our role.
While it is not required to comply with the mandatory reporting of the Modern Slavery Act 2018
(Cth) as our turnover is less than $100m, the Board is committed to a program directed towards
eradicating modern slavery and human trafficking, through practical measures such as anti-slavery
supply chain strategies and procurement, as well as anti-slavery education and engagement
initiatives.
THE ROAD MAP
Up to 2020 2021 BEYOND
• Board commitment to • Understand the • All potential high-risk
eradicate Modern awareness and actions suppliers are
Slavery (MS) of all our potential effectively engaged
• MS requirements high risk suppliers and educated in MS
incorporated in • Implement • Establish remedy
Procurement Strategy Procurement Strategy response when MS
Plan Plan practices and
• Increase awareness of • Implement MS policies identified in
MS with senior mgt. and procedures operations
and key staff • MS is briefly covered • All medium priority
• Completed baseline in staff and contractor suppliers are
assessment education and effectively engaged
• Completed a spend induction programs and educated in MS
analysis to determine • Adopt anti-slavery
our risk profile to MS contract clauses.
• Sent communications
to all suppliers on our
MS commitment
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Brief Statement from the CEO
CMCT has a zero-tolerance approach to all forms of modern
slavery within its business and its supply chain and is committed
to acting ethically and with integrity in all business dealings and
relationships. CMCT will implement and enforce effective
systems and controls to mitigate the risk of modern slavery
taking place in its own business or any of its supply chains.
To achieve this aim, we are taking the following steps:
1. Implement a policy which articulates CMCT's commitment to
prevent modern slavery within its operations and supply chains.
2. Communication of this policy and all relevant elements of the
programme to all employees throughout the organisation and
our business partners and supply chains.
3. The assessment of modern slavery and human trafficking risk
within CMCT and supply chains and the development of
effective, efficient and transparent controls to reduce exposure
to those risks.
4. The adoption of anti-slavery wording in contracts.
5. The adoption of appropriate due diligence on business
partners, agents, contractors, consultants, sub-contractors and
suppliers, coupled with the requirement that they implement
procedures which incorporate the principles under the
applicable modern slavery legislation.
6. Training of all relevant individuals throughout CMCT so that
compliance with this policy is the duty of all relevant employees
at all levels and individuals can recognise modern slavery
practices and take steps to avoid the same.
This statement represents the 2020 calendar year and has been
approved by the Board of CMCT on 24 February 2021.
Peter O’Meara
CEO6|M o d e r n S l a v e r y S t a t e m e n t
Structure, Operations and
Supply Chain
Our Organisational Structure
CMCT is an independent not-for-profit organisation and one of the largest cemetery trusts in NSW,
managing and delivering high quality cemetery services to a diverse range of communities and
families across Western Sydney.
The 9-member Board meets bimonthly and has established the following sub committees to assist in
performing its duties:
- Finance, Investment & Remuneration
- Audit, Corporate Governance & Risk Management
- Community Advisory
- Project Development
It has a clearly defined organisation structure comprising six departments reporting to the CEO:
- New Business Ventures
- Infrastructure, Major Projects and Assets
- Client Services & Operations
- Strategy, Communications & Marketing
- Finance, Corporate Governance & Procurement
- People Capability & Change
The Strategic Plan 2019-2021 outlines five key priorities:
- 1. Grow and maintain relationships
- 2. Business sustainability
- 3. Staff and culture
- 4. Service excellence
- 5. Enhanced governance and accountability7|M o d e r n S l a v e r y S t a t e m e n t
Our Governance Framework
Modern Slavery initiative has the following governance framework in CMCT:
(a) Board,
(b) Audit, Risk Management & Corporate Governance Committee (ARMCGC)
(c) CEO
(d) Head of Finance, Risk Management & Procurement (FRMP)
The Board approved the Procurement Strategy Plan in February 2020 which incorporated
ACAN’s Modern Slavery initiative. The FRMP leads a Procurement Project team and reports
regularly to the CEO and periodically to the ARMCGC.
Our Operations
Catholic Metropolitan Cemeteries Trust (CMCT) currently operates three cemeteries in the
western Sydney area. These cemeteries are located at Rookwood, Kemps Creek and Liverpool. In
addition, we are developing a cemetery at Varroville and seeking DA approval for cemetery
development at Wallacia. The location of the Executive / Administration function and the Board's
registered office is Level 2, 11 Murray Rose Ave, Sydney Olympic Park NSW 2127.
CMCT has obligations under legislation and guidelines including, but not limited to:
• Cemeteries and Crematoria Act 2013 (NSW).
• Crown Land Management Act 2016 (NSW).
• Public Health Act 2010 (NSW).
• Australian Charities and Not-for-profits Commissions Act 2012 (Cth).
Currently supplier relationships are a combination of short and long-term engagements. For the
supply of goods, contractual terms are generally dictated to us while supply of services undertakes a
negotiation process. Other than suppliers, the key business relationships are with Community
Groups and Funeral Directors. There are no joint ventures.
An important outcome of the Procurement Strategy plan is to establish a ‘centre led’ Procurement
function that organises and manages “common use” contracts covering a substantial proportion of
OPEX AND CAPEX. We will be developing longer-term partnerships with our suppliers, while
continually assessing alternative sources of supply. Only those suppliers who can meet our standards
are appointed.8|M o d e r n S l a v e r y S t a t e m e n t Sourced from CMCT’s 2020 Annual Report, highlights a profile of our employees and services.
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Our Supply Chain
Over 12 months ending October 2019, CMCT purchased over $16m of goods and services mainly
from 69 direct suppliers. Our suppliers range from stone masons, builders, cleaners, security, legal
and IT advisors, and waste service providers. All procurement was sourced from Australian suppliers
which 50% was spent on CAPEX and 50% on OPEX.
The key area of potentially high-risk suppliers is in Building, Construction and fabrication services
totalling $7.9m. A significant component was the construction of Crypts at Rookwood cemetery. The
next major outlay of potentially high-risk suppliers is with Property and facility maintenance totalling
$382k. A significant component was the ground maintenance of the cemeteries at Rookwood and
Liverpool.
Modern Slavery risks in
Operations and Supply Chain
CMCT’s Board made a commitment to voluntarily join the Australian Catholic Anti-slavery Network
(ACAN) initiative and participated in the ACAN conference in July 2019 to develop a greater
understanding of our supply base and the potential risk to modern slavery practices.
It was clear from this analysis that we were ‘at the beginning of our journey.’
Subsequently the Procurement Project team was established and undertook the following key steps:
- Obtain Senior Management and key staff commitment to the Modern Slavery initiative,
- Increase the awareness of Modern Slavery within the organisation,
- Develop a ‘baseline’ of the organisation’s capability to implement the change,
- Completed a detailed analysis of our supply base of the potential risks to Modern Slavery,
and
- Communicate to our suppliers our intent to eradicate Modern Slavery,10 | M o d e r n S l a v e r y S t a t e m e n t
OPERATIONAL RISKS
Our People
We are confident that our risk to modern slavery through our internal staff is low due to a range of
policies, systems and practices we have in operation. These include Human Resource policies which
are intended to ensure that all staff are paid at award rates (above) according to their role and
qualification. All employment information is managed through our HR Information System and Payroll
System to manage our staff and their relevant employment and pay details.
The key points are:
• Employment - as per our Recruitment and Selection procedure, selection is based on merit,
equal employment opportunity and relevant Federal and State Legislation.
• Rates of pay are checked annually to ensure they meet minimum standards.
• Labour hire agencies inclusive of apprentices are also governed by legislation ensuring
minimum award rates of pay to all employees. All agencies are engaged on the basis that they
reflect pay rates based on Catholic Cemeteries relevant instruments and provide us with pay
rates to labour hire personnel.
• Discrimination is outlined in our Code of Conduct – we value the diversity of our people, and
as such have employees from a wide diverse.
• Protection of individuals who disclose information about illegal or improper conduct
occurring within CMCT is outlined in our Whistleblower policy.
Modern Slavery Gap Analysis
In September 2020, key senior managers and staff involved in the purchasing of goods and services
completed a ‘Bridge the Gap’ exercise to establish a baseline.11 | M o d e r n S l a v e r y S t a t e m e n t Category Summary Management Systems CMCT have taken steps to understanding the modern slavery risks in our operations and supply chain. While our Board and senior management team acknowledge that modern slavery occurs in our business sector, our approach to identifying and managing modern slavery risks has only recently commenced. As part of the Procurement Strategy Plan, Modern slavery risk management processes will be integrated into the Procurement function. Human Resources and Recruitment CMCT has commenced incorporating modern slavery issues into our employee or contractor training or awareness programs. In 2021 our aim is hiring and onboarding processes that reference modern slavery risk management. Procurement and Supply Chain We have mapped our supply chain to understand priority suppliers and risk categories. Our existing supply contracts do not refer to modern slavery risks and we do not monitor suppliers for modern slavery risks. We have recently notified our suppliers our intent to implement ACAN’s initiative. In 2021 our aim is Modern slavery risks are considered in our procurement policies or supplier management processes. Risk Management Modern slavery is not considered in our business risk framework. We have no systems or processes in place to manage potential modern slavery risks in our operations, supply chain, business partnerships or industry sector. This will be addressed in the implementation of the Procurement Strategy plan in 2021. Customers and Stakeholders CMCT have limited understanding of our customer or stakeholder expectations around modern slavery risk management and do not elicit feedback from them on this issue. We do not have feedback or communications mechanisms in place for workers in our supply chain and do not make information on modern slavery risks publicly available.
12 | M o d e r n S l a v e r y S t a t e m e n t SUPPLY CHAIN RISKS In 2020 we identified the potential highest risk suppliers according to key indicators used by ACAN. This formed the basis of the supplier dashboards The dashboard below provides an overview of the scope and scale potential modern slavery risk within CMCT’s supply chain and is the first step in developing robust risk management systems. The information was sourced from the 2019 financial year and the indicators of potential risk are based on the best available information as disclosed in the ACAN conference in July 2019. The Dashboard does not attempt to determine actual risk to the organisation or the modern slavery risk presented by individual suppliers. Determining actual risk requires detailed information, analysis and investigation from multiple sources and stakeholders.
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It highlights CMCT has 6 potential high-risk categories involving 41 suppliers that constitutes 53% of
the overall spend.
Our COVID-19 Response
While COVID – 19 significantly impacted the delivery of services with restrictions at funerals and the
social distancing of staff and members of the public, we were able to procure the necessarily
Personal Protective Equipment (PPE) and IT hardware to continue operations and ensure the
physical contact of suppliers / contractors and members of the public was in accordance with the
NSW Health regulations.
In April 2020 the CEO reassured the employment for existing staff during the business downturn
who may have been under financial pressure. In addition, CMCT significantly changed how it
operated by:
- Allowing staff to work from home,
- Implementing a split team roster, and
- Ensuring PPE was available as required.14 | M o d e r n S l a v e r y S t a t e m e n t
Actions taken to assess and
address risk
The focus in 2020 was securing Senior Management and key relevant staff commitment to the ACAN
initiative and building our understanding of Modern Slavery risk in CMCT’s Supply chain.
Subsequently the Modern Slavery requirements was incorporated into the Procurement Strategy
plan and implementation appropriately resourced.
Modern slavery action plan and road map
Representatives of CMCT participated in the ACAN conference in July 2019 and worked with the
Archdiocese of Sydney to develop a sector-wide action plan. We used that format to develop our
own action plan by:
(a) the FRMP regularly attending the Modern Slavery Officer conference group and accessing
the ACAN web site for resources.
(b) a ‘consultative group representing senior management and key staff undertaking the
‘Bridge-to-Gap exercise and Modern Slavery E-learning module, and
(c) Establishing a Project team consisting of 3 Senior Managers, a procurement specialist and an
accountant. In addition, a consultative group was formed of staff who are either major
buyers of goods / services or have significant budget responsibility.
The key actions delivered for 2020 were:
• Joined ACAN
• Engage the Board and the leadership team of the enormity and importance of the task
• Incorporated Modern Slavery requirements in the scope of implementing the Procurement
Strategy plan
• Completed the sector specific action plan
• Completed the Bridge the Gap analysis
• Completed the Modern Slavery e-learning module – 14 attendees.
• Completed the Model supplier engagement strategy workshop - 14 attendees.
• Reviewed the spend analysis to assign a rating to each material supplier (a) Strategic impact
and value to business, and (b) potential risk of Modern Slavery
• Document the current engagement strategy with all potential high-risk suppliers
• Completed the Business Relevance module – 2 attendees
• Sent a letter to all suppliers notifying our commitment to ACAN’s Modern Slavery initiative15 | M o d e r n S l a v e r y S t a t e m e n t
Effectiveness Assessment
Effective assessments include, but not limited to:
- The Modern Slavery initiative has been incorporated into the Procurement project
implementation. Its progress is monthly reviewed by senior management and reported to
the Board every 6 months.
- The ‘Bridge the Gap’ exercise is completed annually.
- No. of employee hours dedicated to training and awareness on Modern Slavery risks.
- No. of suppliers engaged to raise awareness on Modern Slavery risks.
- No. of contracts which include anti-slavery clauses.
Other
CMCT seeks to invest as a responsible community member, and also to ensure that the investments
are consistent with its specific mission, the values of the Catholic Church, and the broader arena in
which the Trust operates.
The Ethical Statement within the CMCT Investment Policy requires investment managers of
managed funds to monitor the portfolio in relation to globally accepted norms on corporate
sustainability behaviours in the areas of Human Rights, Labour, Environment and Corruption.
In addition, on an annual basis we receive a proxy voting report from our Investment Advisor,
currently Russell Investments, as well as a report on those companies with main businesses that
engage in unethical or undesirable practices.You can also read
