Modern Slavery Statement - FY2019-2020
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Modern Slavery Statement FY2019–2020
Contents
Introduction 3 Family and Disability Services 9
Our approach 3 Joint venture partnerships 10
Key areas of focus for 2019/20 3 Our supply chains 11
Key areas of focus for 2020/21 3 Modern slavery risks 13
About UnitingCare 4 Due diligence and remediation 15
Our values 4 Operational due diligence 15
Our mission 5 Supply chain due diligence 16
Policies 6 Grievances and remediation processes 16
Our operations 8 Training 16
Blue Care and ARRCS 8 Effectiveness measures 17
Hospitals 8
Modern Slavery Statement FY2019–2020 2
Introduction
UnitingCare opposes Key areas of focus for 2019/20
exploitative practises that • Conducting a scoping exercise to map our
supply chains and operations, assess our risks
violate an individual’s dignity of modern slavery and identify measurable
and human rights in all forms. actions to address these risks.
• Maturing our supply chain risk assurance
As an outreach of the Uniting Church, our mechanisms by introducing a Supplier Code of
mission is to improve the health and wellbeing Conduct, contractual provisions for adherence
of individuals, families and communities as we with modern slavery laws and supplier risk
speak out for fairness and justice, and care with assessment tools.
compassion, innovation and wisdom. UnitingCare • Implementing a Human Rights Policy to
is committed to act in a way that upholds the strengthen our approach on preventing
intrinsic worth and dignity of every person at modern slavery risks.
every stage of life and in every circumstance • Developing and implementing a Modern
of life regardless of race, age, gender, beliefs or Slavery Action Plan FY2019-20 to direct
economic status. our efforts to eradicate modern slavery in
This statement is submitted as a joint statement connection to UnitingCare.
in accordance with the Modern Slavery Act
2018 (Cth). It is submitted by UnitingCare Key areas of focus for 2020/21
Queensland on behalf of itself and UnitingCare
• Assessing risks of modern slavery associated
Community, UnitingCare Health and Blue Care
with new and recontracted suppliers, and
which represent The Uniting Church in Australia
expanding the use of our supplier risk
Property Trust (Q.) and UnitingCare’s associated
management tools to ensure procurement
entity Australian Regional and Remote
and supplier due diligence.
Community Services Ltd (ARRCS). It describes
the steps taken by UnitingCare (including ARRCS) • Development of UnitingCare’s Modern
to prevent, detect and respond to modern Slavery Strategic Roadmap.
slavery risks in our operations or supply chain • Building supplier capacity to respond to
during the financial year ending 30 June 2020. modern slavery through awareness-raising
The modern slavery risks and impacts associated and training.
with UnitingCare’s joint venture, Leap In! are • Providing training for staff to recognise,
not included in this Statement. UnitingCare prevent and respond to concerns of
does, however, have joint venture governance modern slavery, both in our operations
processes that involve regular engagement and and supply chain.
oversight of key risks. • Increasing collaboration within our networks,
and with our partners, to strengthen our
Our approach response to modern slavery.
Our first statement was developed in
consultation with UnitingCare’s business units
and support functions.
In early 2019, we established a taskforce
to oversee and implement our modern
slavery assessment and prevention strategy.
Work was overseen, sponsored and endorsed by
UnitingCare’s Executives and approved by the
UnitingCare Queensland Board.
Modern Slavery Statement FY2019–2020 3
About UnitingCare
UnitingCare Queensland was established by
UnitingCare is the health and the Queensland Synod of the Uniting Church in
community services arm of the Australia, and is governed by the UnitingCare
Queensland Board with certain matters reserved
Uniting Church of Australia in for the Queensland Synod.
Queensland. We are committed UnitingCare employs approximately 17,000 people
to empowering and improving and is supported by 9,600 dedicated volunteers.
ARRCS employs approximately 718 people and
the health and wellbeing of is supported by 68 dedicated volunteers. As one
vulnerable individuals and of Queensland's largest employers, UnitingCare
proudly represents some well known brands and
those in need to live life in all services that engage daily with people from all
walks of life across Queensland and the Northern
its fullness. Territory. In addition to our family and disability
services provided by UnitingCare, our family of
brands includes: Blue Care; Lifeline; The Wesley
Hospital; St Andrew's War Memorial Hospital;
Buderim Private Hospital; St Stephen's Hospital;
and ARRCS.
Our Values
We believe the following values are fundamental to the work we do
and the way we work together:
Compassion Respect
Through our understanding and We accept and honour diversity,
empathy for others we bring uniqueness and the contribution
holistic care, hope and inspiration. of others.
Justice Working Together
We commit to focus on the We value and appreciate
needs of the people we serve the richness of individual
and to work for a fair, just and contributions, partnerships
sustainable society. and teamwork.
Leading through Learning
Our culture encourages innovation
and supports learning.
Modern Slavery Statement FY2019–2020 4
Our mission Our mission is expressed in seven
mission practices:
Our mission is to improve
the health and wellbeing
of individuals, families and We demonstrate the worth
and dignity of every person
communities as we:
We walk together with
First Peoples
reach out to
people in need;
We participate in God’s healing
power to the whole person
speak out for
fairness and We cultivate practices centred
justice; and on people and relationships
care with We value reflective action
compassion,
innovation and
wisdom. We are faithful stewards of
the resources entrusted to us
We stand up for what is fair
and just
Modern Slavery Statement FY2019–2020 5
Policies
Our commitment to mitigating the effects of modern slavery is
upheld by our frameworks, policies and procedures. These include
but are not limited to UnitingCare’s:
• Risk Management Framework: which adopts • Recruitment Policy: which describes the
a risk-based approach to our operational agency practice verification processes required
and supply chain risk management planning, before employment agencies will be retained
key decision making and observance of to source employees both permanently and
compliance obligations. on short term contracts. This requires that
there is an adherence to our Code of Conduct
• Code of conduct: which outlines the
and compliance with relevant legislative
principles of expected behaviour and conduct
requirements.
of UnitingCare employees, volunteers and
contractors. The Code is aligned with legal, • Investment Management Strategy: which
professional, social and ethical expectations, outlines our ethical investment principles,
and the values of UnitingCare. These as guided by the Queensland Synod’s Ethical
expectations extend to the principles that Investment Policy. This Policy prohibits our
underpin a legal and ethical rejection of participation in investments that cause social
modern slavery. injury for activities that denigrate personal
dignity, inhibit human rights, exploit people
• Human Rights Policy: which outlines our
financially and/or damage human health.
commitment to ensuring our actions and
decisions are consistent with respecting and • Procurement and Supplier Contract
upholding the human rights of all persons. Management Policy: which provides for our
This includes a person’s right to protection socially responsible and ethical procurement
from slavery. Under this Policy, we also seek to practices. Procedures and associated tools
establish relationships with entities that share and systems are being progressively updated
the same principles as UnitingCare. to improve due diligence and remediation
practices to and management of modern
• Whistleblowing Policy: which supports our
slavery risks.
people to observe high standards of good
governance and ethical behaviour, and feel • Supplier Code of Conduct: which outlines
supported to safely disclose matters which our expectation that our suppliers will act in a
may be inconsistent with modern slavery laws. manner that is consistent with the principles
UnitingCare also has a whistleblower integrity for socially responsible, sustainable and ethical
hotline which is accessible by our employees, business practices and that these principles
volunteers, contractors, consultants, suppliers are adopted throughout their supply chains.
and their relatives, dependents or spouse.
Modern Slavery Statement FY2019–2020 6
Modern Slavery Statement FY2019–2020 7
Our operations
Our services extend to all walks of life across Queensland and the
Northern Territory and are managed operationally through three
business streams; Aged Care and Community Services (Blue Care
and ARRCS); Hospitals (UnitingCare Hospitals) and Family and
Disability Services (UnitingCare).
During the course of the financial year ending Lifeline and our Family and Disability
30 June 2020, we supported more than 600,000 Services. We operate in the Northern Territory
people across 460 locations to live life in all its through Australian Regional and Remote
fullness. UnitingCare operates in Queensland Community Services.
through Blue Care, The Wesley Hospital, We also have joint venture for Leap in!
St Stephen’s Hospital, St Andrew’s War Memorial Australia Limited between UnitingCare and
Hospital, Buderim Private Hospital, Blue Care, Uniting (NSW/ACT).
Operations overview:
Aged Care and
Community Services 8,900 employees and
1242 volunteers
Provides in-home care, residential aged
care, disability services, independent
and supported retirement living,
57 aged care facilities with
private hospital services through
Blue Care and ARRCS. 3,785 residential beds
66,000 community clients
Hospitals
4,300 employees and 626 volunteers
Provides a comprehensive range of
private medical services through
The Wesley Hospital, St Stephen’s
Hospital, St Andrew’s War Memorial 4 hospitals with 1065 beds
Hospital, Buderim Private Hospital.
Operates the Helena Goldie project
in conjunction with UnitingWorld in 144,000 admissions
the Solomon Islands to teach nursing
students and to provide equipment.
Modern Slavery Statement FY2019–2020 8
Family and Disability Exported 7,400 tonnes of clothing
Services donated to Lifeline to overseas
communities Papua New Guinea,
Provides supported independent
Vanuatu, Fiji and Dubai
living, foster and kinship care, family
and children’s counselling, early
education, crisis support, allied health
and retail of donated goods through 2,600 employees and 7,600 volunteers
UnitingCare Family and Disability
Services and Lifeline.
188 Family and disability facilities
128 Lifeline stores and 11 warehouses
383,000 people receiving care
Outsourced operations
IT support and systems maintenance for UnitingCare are delivered through a Managed Service
Provider from Bangalore and Chennai in India, Manilla in the Philippines as well as Brisbane.
UnitingCare Procurement Typically, our high value high risk expenditure
UnitingCare’s procurement and contract spend is centrally managed through a category
management activities are delivered management approach. We also leverage the
through a centre-led procurement benefits and opportunities of collaborating with
operating model in partnership with other organisations.
business units and support functions.
5+47+2622A
Figure 1: Percent of spend by Approximately 10,000 suppliers
business area
$600m total spend
5%
22%
75% of total spend is through long
term supply arrangements with
approximately 200 suppliers
47%
26%
17 suppliers engaged through
UnitingCare Hub network
47% Uniting Care Hospitals 3 suppliers engaged through
26% Blue Care Queensland Government standing
22% Support Functions
offer arrangements
5% Family and Disability Services
Modern Slavery Statement FY2019–2020 9
UnitingCare Chaplaincy
7 marriage ceremonies performed
Provides counselling and wellbeing
services and marriage ceremonies.
Leap in! Australia Limited
34 employees
Provides NDIS plan management via a
digital-based platform.
4,000 customers
Modern Slavery Statement FY2019–2020 10Our supply chains
UnitingCare manages approximately 10,000 suppliers with a total
spend in excess of $600 million.
11+51+38A
Our supply chains are diverse, with goods and Figure 2: Spend by category
services being purchased from both domestic
suppliers in remote regional and metro areas
as well as international suppliers in the Asia-
Pacific region, North, South and Central America, 11%
Europe, the Middle East and Africa.
Our spend categories 38%
The purchase of medical goods, services and
equipment is our largest category of spend
51%
making up 51% of our spend (~ $310 m).
Spend within the medical category comprises
the following sub-categories:
• Prosthetics ~ 34%
• Medical Equipment ~ 27%
• Medical Services ~ 20% 51% Medical
• Medical Consumables ~ 14% 38% Non-medical
11% Tail spend
• Pharmaceuticals ~ 4%
• Other ~ 1%
The non-medical category makes up 38% of our
spend (~ $230m) and comprises the following Modern slavery is the
sub-categories: antithesis of our mission to
• Professional Services ~ 32% ensure people “live life in all
• Facilities Management ~ 25%
• Information Technology ~ 23%
its fullness”. We are committed
• Food and Beverage ~ 5% to taking meaningful actions
• General Equipment and Supplies ~ 4% to ensure modern slavery and
•
•
Transport ~ 3%
Utilities ~ 3%
human trafficking does not
• Fleet ~ 3% exist in our organisation and
• Marketing and Advertising ~2% supply chain.
Modern Slavery Statement FY2019–2020 11Modern Slavery Statement FY2019–2020 12
Modern slavery risks
The practises which constitute modern slavery include trafficking
persons, slavery, servitude, forced marriage, forced labour, debt
bondage, deceptive recruiting for labour or services and child labour.
During the financial year ending 30 June 2020,
an organisation-wide risk assessment was
Identified risk areas
undertaken for modern slavery risks both within Through the risk assessment, UnitingCare
UnitingCare and in our supply chains. Our focus identified a number of key modern slavery risks
centred on risks that may cause, contribute and/ within our operations and supply chains. These
or be directly linked to modern slavery practices included 14% being assessed as high risk, 39%
with the management of identified risks treated as medium and 47% as low. These have been
according to our Risk Management Framework. prioritised according to the severity of the
potential impact and likelihood of the risk.
The process we undertook included:
Figure 3: UnitingCare Modern Slavery Operations
Risk Management • Within our treasury, fundraising, Mission and
overseas crisis support operations there is a
low risk exposure that UnitingCare may cause,
1. Modern contribute and/or be directly linked to modern
Slavery risk slavery practices through the bequests and
5. Reporting, scoping and donations we receive or investments we hold,
escalating context exercise.
workers we engage overseas through external
and providing
assurance of agencies or chaplaincy services such as forced
controls marriage officiation. These were largely
UnitingCare assessed as low risk due to the stringency and
2.Enterprise-
Modern wide ident- rigor of our due diligence, engagement terms
Slavery Risk ification and and governing policies and procedures.
4.Develop- Management assessment
ment of action of key risks • Procurement: some medium or high risks were
plans, mitigation identified for HealthCare, Strategic Properties
strategies and and Technology procurement activities
ownership
3.Evaluation, operating outside UnitingCare’s centralised
treatment and procurement arrangements.
prioritisation
key risks
Modern Slavery Statement FY2019–2020 13Supply chain
• Offshore vendors: Asia-Pacific, North America
Supply chain scoping exercise
and Europe are all subject to contemporary UnitingCare conducted an initial scoping
forms of modern slavery. Our high-risk spend exercise to provide a starting point to
categories, operating mainly from these better understand our suppliers and
regions include: develop due diligence systems and
processes for ongoing management
- Medical consumables and equipment of modern slavery risks across our
- ICT hardware supply chain.
- furniture Based on spend and assumed modern
- building, construction and facilities slavery risk, a sample of suppliers were
management engaged to participate in the exercise
- cleaning services and products and complete a detailed online
- food and beverage self-assessment.
- apparel Key findings included:
- waste management. • A high proportion of suppliers operate
• Additional risk assessment is underway with globally and source products and
regard to the preference for specific goods services from diverse geographic
or services purchased directly by our health locations with 40% operating in high-
service partners and clients who are not risk countries and regions.
within our procurement control environment, • A high proportion of suppliers outsource
to determine if modern slavery risk had been manufacturing and/or distribution
appropriately considered. This activity is and do not have codes of conduct or
included in our operational risk actions plans modern slavery clauses in contracts
to manage any risk exposure. which increases risk of modern slavery
• Risk were also identified for purchases infringements.
made directly by our clients under their • The majority of suppliers do not identify
funding arrangements. Arrangements with modern slavery as a risk in operations or
these suppliers are often short-term or one supply chains however more than half
off and include high-risk industries including source high risk commodities from high
gardening services, hairdressing services, risk locations.
equipment supply and furniture.
• The verification and monitoring of
supplier modern slavery risk levels
was low.
• Overall, suppliers scored lowest in risk
management, training and reporting
categories which increases risk within
operations and supply chain.
These findings informed our approach to
modern slavery risk management and our
Modern Slavery Action Plan.
Modern Slavery Statement FY2019–2020 14Due diligence and
remediation
Actions taken to assess and address
modern slavery risks
Operational risks were identified as part of
Operational due diligence the scoping exercise and risk assessments
The steps we have taken to assess and mitigate were managed through existing internal risk
risks within our operations include: frameworks, policies and procedures, including
• establishing a modern slavery taskforce with due diligence processes and the external
representation from all key business areas and regulation assurance. Improvements are
underway to leverage the UnitingCare Modern
support functions.
Slavery training and awareness program.
• a scoping exercise to map our supply chains
and operations, and assess our risks of In business streams that operate outside the
modern slavery. centralised procurement function’s supplier
network, risk action plans are under development
• the development and implementation of our
to mitigate this risk exposure. Active Risk Actions
Modern Slavery Action Plan FY2019-21. Plans include contemporary risk assessment
• the review and improvement of existing tools, leveraging the existing procurement team
policies and procedures, including the Code of procedure relating to due diligence, contract
Conduct, Procurement and Supplier Contract clauses and third party-software solution to
Management Policy, Whistleblowing Policy assess high risk suppliers.
and grievance mechanisms.
As part of our Risk Action Plan mitigation
• the development of new policies and strategies, we will seek to ensure relevant staff
procedures, including the Supplier Code of are aware of them as a part of training.
Conduct (Supplier Code) and the Human
Rights Policy and Procedure.
• the review of training and education
programs, including onboarding.
• the completion of risk assessments
with key stakeholders from across
UnitingCare’s operations.
Modern Slavery Statement FY2019–2020 15Supply chain due diligence Grievances and remediation
The steps we have taken to assess and mitigate processes
modern slavery risks have focused on maturing
UnitingCare is committed to the protection and
our supply chain assurance program through the
respect of human rights across our business and
implementation of a Supplier Code, contractual
supply chain. Where we identify that UnitingCare
provisions for adherence with modern slavery
has caused or contributed to adverse impacts
laws and the implementation of supplier risk
such as modern slavery, we will seek to address
assessment tools. Due to the large number of
human rights grievances in line with relevant
our suppliers, efforts were focused on strategic
policies and procedures.
suppliers that present an elevated risk of exposure.
UnitingCare has a number of mechanisms for
The Supplier Code is communicated to suppliers as
employees and third parties to anonymously
part of our tender process and is incorporated into
report suspected or actual illegal activity or
our due diligence process. Activities undertaken
breaches of UnitingCare policies, including under
as part of this process help us to identify potential
our staff and Supplier Code, Whistleblowing
areas of risk, and, where identified, the supplier will
Policy and Human Rights Policy.
be referred for further due diligence with impact
on UnitingCare’s procurement decisions. Employees and third parties have access to
our Integrity Hotline which is operated by an
To assist with our due diligence assessments,
independent third-party or can raise concerns via
we have implemented a third-party software
our website. UnitingCare supports anonymous
solution that assists with category, supplier,
reporting through these means.
and product level risks assessments.
Where a potential risk is evaluated as high, Where risks are identified in our supply chain,
supplier assessment questionnaires can be UnitingCare’s preferred approach is to work with
undertaken in the system to facilitate a more suppliers to develop a corrective action plan
detailed assessment. with agreed timeframes rather than terminating
supplier arrangements.
High risk suppliers are monitored and reported
on an ongoing basis through the third-party
software solution. The alerts feature reports Training
on any publicly available potential adverse Internal and external awareness of the existence
information which we assess and respond to of modern slavery and how to spot the signs has
as required. been facilitated. Management have participated
New and renewed supply agreements include in modern slavery workshops for the oversight
modern slavery and Supplier Code clauses. This and management of modern slavery risks.
requires, amongst other things, that suppliers The development of formalised modern slavery
and their third-party suppliers, adhere to the training will be a key focus for UnitingCare’s
principles in the Supplier Code, implement due next reporting period to enable strengthened
diligence processes and take reasonable steps to recognition, prevention and responses to modern
minimise modern slavery risk in their operations slavery risks.
or supply chain.
The Supplier Code has been communicated
We will continue to explore opportunities to key stakeholders and to new and renewed
with our suppliers to improve how we identify, contracted suppliers to ensure understanding
assess and mitigate modern slavery risks within and participation in reducing risk of modern
our supply chain and build them into policies, slavery. Our top 20 high-risk strategic suppliers
procedures and training. were also provided with a modern slavery
education module.
Expanding our supplier education and
engagement activities will be a key focus for
UnitingCare’s next reporting period.
Modern Slavery Statement FY2019–2020 16Effectiveness measures
Our Mission at UnitingCare drives our response to modern slavery.
The key principles underlying our response include:
Worth and Dignity: We act in a way that upholds Metrics used to monitor our progress include:
the intrinsic worth and dignity of every person
• the number of modern slavery risk mitigation
at every stage of life and in every circumstance
actions overdue
of life, regardless of race, age, gender, beliefs
or economic status. When we make decisions, • the percentage of contracts that include
we consider and document its impact on modern slavery clauses
human rights.
• the percentage of supplier meetings that
Fairness and Justice: We stand up for and incorporate discussions on progress with
speak out for a society characterised by love, addressing modern slavery risks in their
compassion, equality, justice, belonging and operations and supply chain.
reconciliation so that all people, at every stage
of life, can experience ‘life in all its fullness’ • the number of supplier audits and the number
(John 10:10). This includes acting in a way that of open and closed findings
responds to the needs of the most vulnerable in
• the number of actions taken to work with
society and seeking to promote the human rights
of all people. suppliers to improve their capacity to respond
to modern slavery risks.
Stewardship: We act in ways that promote
faithful stewardship of our people, financial, • the number of whistleblowing alerts raised
property and other resources. This is aimed at during the year
enabling our core mission including promoting • the number of human rights complaints raised
environmental and social sustainability and during the year
witnessing to the vision of life in all its fullness.
• the proportion or number of complaints
UnitingCare’s focus for the first reporting resolved by a grievance mechanism
period was on embedding reviews and indicators
into governance and reporting processes • the number of modern slavery training
to help us monitor the effectiveness of our and awareness-raising programs delivered
actions to prevent, detect and respond to to suppliers
modern slavery risks and identify opportunities
for improvements. Throughout the financial year ending 30 June
2021, UnitingCare will establish a new set of
measures, aligned with our strategic roadmap,
that will ensure actions we take have a positive
social impact and support the delivery of
our mission.
This statement was approved by the
UnitingCare Queensland Board.
Nigel Alexander
Chair of Board
UnitingCare Queensland
Modern Slavery Statement FY2019–2020 17Telephone 07 3253 4000 Address Level 5 192 Ann Street Brisbane QLD Australia 4000 Mailing address GPO Box 45, Brisbane QLD 4001 Email contact@ucareqld.com.au unitingcareqld.com.au
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