STATEMENT ON MODERN SLAVERY - For the period to 30 June 2020

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STATEMENT ON
MODERN SLAVERY

   For the period to 30 June 2020
Spark New Zealand Statement on Modern Slavery 2020

Modern Slavery Act
Statement 2020

This is the inaugural modern slavery statement made on behalf
of Spark New Zealand Limited (“Spark” and together with its
subsidiaries, the “Spark Group”) for the period from 1 July 2019       Contents
to 30 June 2020. It has been prepared pursuant to the requirements
                                                                       Our business       3
of the Australian Modern Slavery Act 2018.
                                                                       Our operations     4
This report was approved by the Spark New Zealand Board
on 29 March 2021.                                                      Our people         5
                                                                       Our supply chain   7
                                                                       Effectiveness of
                                                                       Spark’s approach   9

Justine Smyth, CNZM
Chair

Spark New Zealand Limited (NZX: SPK, ASX: SPK)

Spark is committed to upholding human rights – both within our own
operations and throughout our supply chain. This means the fair and
respectful treatment of all our people, and a focus on providing
fulfilling and rewarding employment. It means complying fully with
the law, but also going above and beyond compliance – acting
professionally, ethically, and responsibly as we deliver customer
outcomes, contribute to the community, and create shareholder
value. It means sourcing our products and services from suppliers
that provide safe working conditions, treat workers with respect and
dignity and conduct business in an environmentally and socially
responsible manner.
We are committed to taking meaningful action to identify, mitigate
and manage any modern slavery risks – and to continuously
improving our approach.

                                                                                          2
Spark New Zealand Statement on Modern Slavery 2020

Our business

Spark’s purpose is to help all of                    The Spark Group                                     Corporate Governance and
                                                     Spark New Zealand Limited is the parent             risk management
New Zealand win big in a digital
                                                     entity of the Spark Group. Spark is publicly        Our approach to managing modern slavery
world. We are New Zealand’s                          listed, and our issued shares are quoted            risks is supported by our high standards of
largest telecommunications and                       on the New Zealand Stock Exchange (NZX)             operational performance, corporate
digital services provider. Our                       and Australian Securities Exchange (ASX).           governance and risk management.
customers range from consumers                       Spark is a reporting entity for the                 The Board regularly reviews and assesses
and households to large                              purposes of the Modern Slavery Act                  Spark’s governance structures and processes
                                                     (Commonwealth) 2018 and our statement               to ensure that they are consistent with
enterprises, and our services
                                                     covers the Spark Group of entities.                 international best practice, in both form and
include mobile and broadband                         As at 30 June 2020 the Spark Group                  substance. Spark’s corporate policies apply at
connectivity, cloud connectivity                     comprised 30 controlled entities.                   a group level and our governance structures
and IT services.                                     Spark New Zealand Trading Limited is the            ensure the Spark Group of entities adhere to
                                                     main trading entity within the Spark Group          expected standards of conduct. Copies of,
                                                     and is the parent company of many of                and details about, Spark’s corporate
                                                     Spark’s operating subsidiaries.                     governance policies, practices and processes
                                                                                                         can be found on our website at: https://
                                                     Spark Finance Limited is the finance company
                                                                                                         www.sparknz.co.nz/about/governance
                                                     for the Spark Group and raises debt funding
                                                     in New Zealand and internationally. The             Our managing risk policy and framework
                                                     majority of these funds are then advanced to        helps people to manage uncertainty and
                                                     other members of the Spark Group in order           challenges as they pursue Spark’s strategy
                                                     to assist in funding the group’s operations.        and business objectives. The policy, overseen
                                                     Spark Finance is listed on the NZDX as SPF.         by the Audit and Risk Management
                                                                                                         Committee (ARMC), confirms the objectives
                                                     A complete list of the controlled entities in
                                                                                                         for identifying and managing risks that can
                                                     the Spark Group as at 30 June 2020
                                                                                                         impact Spark’s organisational performance.
                                                     (including ownership percentages and
                                                     principal activity information) is available        The policy and framework are benchmarked
                                                     in the Spark Annual Report 2020 on                  to COSO ERM 2017 (COSO), a leading
                                                     page 111.                                           practice risk management standard. Spark has
                                                                                                         used this standard since July 2018 when we
                                                     More information on our financial
                                                                                                         transitioned to the Agile Operating Model.
                                                     performance and business strategy may
                                                     be found on our corporate website at                For more information on our risk
                                                     https://investors.sparknz.co.nz/                    management processes, see Spark’s Annual
                                                     Investor-Centre/                                    Report 2020, pages 46-48 and page 112.

                                                        Our corporate structure

                                                                                             Spark New Zealand
                                                                                                  Limited

                                                              Spark New Zealand                  Spark Finance                 Spark Group
                                                               Trading Limited                      Limited                    Entities (15)

                                                               Spark New Zealand Trading
                                                                      Entities (12)

                                                                                                                                                       3
Spark New Zealand Statement on Modern Slavery 2020

Our operations

Spark provides a broad range                         Spark provides a broad range of                  The Spark Foundation is the charitable arm
                                                     telecommunications and digital services.         of Spark and has a mission to ensure no
of telecommunications and
                                                     Through the Spark, Skinny and BigPipe            New Zealander is left behind in a digital
digital services.                                                                                     world. It seeks to achieve this by
                                                     brands we provide mobile and broadband
                                                     connectivity, digital services and devices,      accelerating equitable access and
                                                     to consumers and households, and to some         capabilities through giving, advocacy
                                                     small businesses.                                and targeted investment opportunities.

                                                     Through our Spark Business, CCL, Digital         How we mitigate modern slavery
                                                     Island, Qrious and Leaven Brands we              risks in our operations
                                                     provide a range of digital services to           Our approach to corporate governance,
                                                     business customers, from small to medium-        as outlined above, alongside our values,
                                                     sized enterprises through to government          Code of Ethics, Supplier Code of Conduct,
                                                     departments and large enterprises. These         and Whistleblowing procedures (all detailed
                                                     include cloud connectivity, IT services, data    below) assist us to mitigate the risks of
                                                     analytics and data-powered marketing,            modern slavery in our operations. We strive
                                                     cyber security, procurement and business         for a culture where Spark people are
                                                     transformation services. Our Telegistics         committed to doing the right thing, to using
                                                     business assists our channel partners            company policies (such as the Code of Ethics)
                                                     across New Zealand with supply chain             to help inform and determine what the right
                                                     and distribution solutions.                      thing is, and to feel safe raising the alarm if
                                                     Spark owns a 50% shareholding in a network       they have concerns.
                                                     construction business Connect 8. For the         In addition, we have checks and balances in
                                                     purposes of this report, Connect 8 is treated    place in specific areas. For example, our
                                                     as a supplier of network construction services   wholesale business checks all requests for
                                                     to Spark, and has signed up to our Supplier      roaming relationships against the UN, US, UK
                                                     Code of Conduct (see below).                     and NZ MFAT sanctions lists and regularly
                                                     Through our Wholesale business we                monitor these for changes. It also checks and
                                                     resell telecommunications services within        monitors the ownership of all new and
                                                     New Zealand and provide International            existing carrier partners – and will turn down
                                                     Mobile Roaming connectivity to the               requests for roaming agreements where we
                                                     customers of offshore telecommunications         believe it is appropriate to do so.
                                                     carriers. We have relationships with more
                                                     than 370 of these carriers globally.
                                                     We are building businesses in emerging
                                                     growth areas: we have a nationwide
                                                     Internet of Things (IoT) network and
                                                     platforms; through Spark Health we deliver
                                                     a tailored suite of telco and IT services for
                                                     the health sector and are developing a
                                                     Digital Health Platform; and we have a
                                                     sports streaming and production service,
                                                     Spark Sport. Our emerging technology
                                                     business Mattr creates solutions for
                                                     verifiable data and digital trust.

                                                                                                                                                   4
Spark New Zealand Statement on Modern Slavery 2020

Our people

                                                     Our direct workforce                                   Our indirect workforce
                                                     As at 30 June 2020, Spark directly employed            We have an indirect workforce of almost
                                                     5,224 people, with more than 99% of these              3,000 with the majority of these located in
                                                     people located in New Zealand.                         New Zealand, but approximately 500 people
                                                     We employ people with a broad range of                 located offshore. We recognise our indirect
                                                     skillsets, ranging from customer service to            workforce could potentially face higher risks
                                                     engineering to professional services.                  of modern slavery than those employed
                                                                                                            directly by Spark, and we have checks
                                                     Spark meets all the requirements of New
                                                                                                            and balances in place to mitigate this.
                                                     Zealand employment law for our NZ-based
                                                     direct workforce, and in many cases goes               Our indirect workforce in New Zealand
                                                     above and beyond statutory requirements.               is a diverse mix of agency contractors,
                                                     Our Hiring Policy ensures that right to work           consultancy firms, independent contractors,
                                                     checks are undertaken and work cannot                  and people employed by our Business Hubs
                                                     commence without valid documentation. Our              – which operate under a licencing model.
                                                     remuneration structure ensures that all staff          It includes people such as cleaners and
                                                     are paid rates at or above the minimum wage,           security staff who work in Spark buildings.
                                                     with governance provided by our Human                  Our New Zealand-based indirect employees
                                                     Resources & Compensation Committee.                    are all protected by New Zealand labour laws
                                                     Spark has a diverse workforce and has a                and are governed by a range of different
                                                     strong diversity and inclusion programme to            contractual arrangements depending on
                                                     ensure our people feel valued, respected and           the type of work they do and where we
                                                     confident to bring their whole self to work. We        have employed them. Our independent
                                                     use an open employee feedback tool which               contractors and agency staff who contract
                                                     enables our people to make their voice heard,          directly to Spark are all engaged in line with
                                                     and other internal communication tools to              our hiring process in terms of right to work
                                                     ensure openness and transparency regarding             and rates of pay.
                                                     the way we work. Spark people undertake                Of our people located offshore, the majority
                                                     compliance training on a range of topics               are in Manilla, where we contract with an
                                                     including Ways of Working.                             offshore partner to run customer care centres
                                                     Spark employs interns across our business              to service our customer base in New Zealand.
                                                     in a broad range of areas. Where it is a formal        We require our partner in Manilla to make
                                                     internship, we have a policy of paying our             formal commitments around its mitigation of
                                                     interns the minimum wage (rather than                  modern slavery risk. Our partner has
                                                     requiring them to give their time for free),           confirmed that it adheres to fair pay practices,
                                                     and we ensure they are given meaningful                including paying employees for all time
                                                     career opportunities. Around one in five               worked, and that all its employees,
                                                     of these interns is engaged through                    contractors and suppliers must comply fully
                                                     programmes such as the First Foundation1               with its Equal Employment Opportunity Policy
                                                     as part of our focus on diversity and inclusion.       and applicable employment laws. We also
                                                     First Foundation interns are supported with            outsource some IT Services work to contract
                                                     scholarships, work experience and mentoring.           staff at two different IT services businesses,
                                                     Occasionally we have people who volunteer              both headquartered in India. The number of
                                                     their time in order to gain work experience or         contractors from these businesses who are
                                                     knowledge in a particular area – for example           working with Spark fluctuates depending on
                                                     our Agile transformation. These are short-term         the work required, but at 30 June 2020 it was
                                                     arrangements and we will continue to                   a little over 100 people, with around two
                                                     monitor this practice to ensure it is always           thirds based in New Zealand and a third
                                                     beneficial for the volunteer.                          offshore in India or Australia. Both

                                                     1 See http://www.firstfoundation.org.nz/ for more information

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Spark New Zealand Statement on Modern Slavery 2020

Our people (cont.)

                                                     organisations have signed up to our Supplier      •   Conduct themselves in a professional
                                                     Code of Conduct.                                      manner that upholds and strengthens the
                                                                                                           image and reputation of Spark
                                                     Our retail network
                                                                                                           New Zealand;
                                                     As at 30 June 2020, Spark operated 66 retail
                                                     stores and 24 business hubs, providing            •   Deal fairly and honestly with Spark
                                                     connectivity and digital solutions to small-to-       New Zealand’s people, professional
                                                     medium enterprises. These are located                 advisors, customers, and suppliers;
                                                     throughout New Zealand. We also have              •   Not enter into transactions or make
                                                     dealership arrangements with major retail             promises on behalf of Spark New Zealand
                                                     chains across New Zealand to sell Spark               that we are unable or do not intend to
                                                     products and services.                                honour;
                                                     Spark owns all our retail stores, and the         •   Undertake their duties with care and
                                                     people working in our stores have a                   diligence;
                                                     contract directly with Spark.                     •   Value individuals’ differences and treat
                                                     Our business hubs are operated by third-              people with respect in accordance with
                                                     party licensees. In this model we understand          Spark New Zealand’s Equal Employment
                                                     the need to ensure the rights of Hub                  Opportunities and Anti-Harassment and
                                                     employees are upheld, and we do this by               Discrimination Policies.
                                                     requiring that the terms of employment            The full Code of Ethics may be found here:
                                                     between the licensee and the staff member         https://www.sparknz.co.nz/about/
                                                     must “comply with all statutory and legal         governance/
                                                     requirements”. We have recently revised the
                                                     licence agreement, under which licensees          Grievance mechanisms
                                                     must now offer employment on terms                We have a range of avenues for our people
                                                     substantially consistent with a template          to pursue if they are concerned about Spark
                                                     agreement provided by Spark (being a fit-for      or people within Spark not living up to our
                                                     purpose agreement that meets minimum              values or our Code of Ethics – including any
                                                     legal requirements).                              instances where our business or our people
                                                                                                       are instigating or allowing modern slavery
                                                     Our values and Code of Ethics                     practices.
                                                     Our values are the cornerstones of our
                                                     culture. Our four values are:                     Whistleblowing policy
                                                                                                       Spark encourages all Spark people to report
                                                     •   Tūhono: we connect
                                                                                                       any issues or concerns they have about
                                                     •   Māia: we are bold                             compliance issues or serious wrongdoings.
                                                     •   Whakamana: we empower                         If people are not comfortable reporting an
                                                     •   Matomato: we succeed together                 issue to their people leader, they can use
                                                                                                       Spark’s Honesty Box process, an online
                                                     Our Code of Ethics sets the standards we
                                                                                                       reporting tool that enables investigation of
                                                     expect of our people when it comes to how
                                                                                                       any concerns raised by specialist staff while
                                                     they do business. Included in the document
                                                                                                       maintaining the confidentiality of the reporter.
                                                     are the behaviours expected of Spark people,
                                                                                                       We also provide avenues where people can
                                                     which include the expectation they will:
                                                                                                       raise concerns without providing any
                                                     •   Undertake their duties in accordance with     information about their identity at all.
                                                         Spark New Zealand’s values;
                                                                                                       Spark works with submitters to ensure they
                                                     •   Conduct themselves in a way that              do not suffer any adverse treatment as a
                                                         demonstrates that their honesty and           result of any reports made in good faith.
                                                         integrity is beyond question;

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Spark New Zealand Statement on Modern Slavery 2020

Our supply chain

                                                     About our supply chain                                     Spark’s biggest categories of spend include:
                                                     Our business relies on more than 2,000 local               •   The purchase of equipment and services
                                                     and global suppliers. Each year we spend                       for our customers (primarily business
                                                     over $2 billion to support our business and                    customers) either when Spark is acting
                                                     meet our customers’ needs. Our supply chain                    as a reseller or a provider of managed
                                                     is complex, as our direct suppliers often have                 services. This includes items such as
                                                     suppliers of their own – who themselves rely                   mobile devices, IT equipment services
                                                     on other suppliers and so on.                                  and support;
                                                     Through our supply chain we source a large                 •   Goods and services sold to Spark for the
                                                     number of products and services from New                       purposes of maintaining and providing
                                                     Zealand and around the globe. Of our total                     telecommunication networks; and
                                                     spend, approximately 90% is with our top 100
                                                                                                                •   Goods and services sold to Spark to
                                                     suppliers – and in this report we have chosen
                                                                                                                    enable our IT environment.
                                                     to focus on data for those top 100 suppliers.
                                                                                                                The remainder is spent on a range of services
                                                     Around 65% of our spend is with suppliers
                                                                                                                such as marketing, corporate services,
                                                     offshore and 35% with NZ-based suppliers.
                                                                                                                content rights, electricity, travel, freight
                                                     Approximately 6% of spend is with suppliers
                                                                                                                and courier, office supplies, and leasing.
                                                     based in countries identified as having
                                                     higher-risk of non-compliance with human                   Managing modern slavery risks in our
                                                     rights or modern slavery requirements2, and                supply chain
                                                     around 2% with suppliers in medium-risk                    Spark is committed to sourcing our products
                                                     countries. However, we recognise the need to               and services from suppliers that provide
                                                     go beyond the location of a supplier’s head                safe working conditions, treat workers with
                                                     office when it comes to mitigating the risks of            respect and dignity and conduct business in
                                                     modern slavery, because the manufacture of                 an environmentally and socially responsible
                                                     many of our products will be in a different                manner. Our Supplier Code of Conduct
                                                     location to the supplier’s head office. The                (the Code) sets out the minimum standards
                                                     global nature of our supply chain means we                 we expect from our suppliers across labour
                                                     must constantly monitor and review our                     and human rights, health and safety,
                                                     approach to reduce the risks of modern                     environmental sustainability, and ethical
                                                     slavery, and we require our suppliers to be                business practices.
                                                     accountable for their own supply chain. This               Section 3.1 of the Code sets out our
                                                     sub tier accountability is integrated into our             approach to Labour and Human Rights.
                                                     Supplier Code of Conduct (see below).                      This requires that our suppliers ensure
                                                     Most of our electronics and network                        workers are treated in a manner consistent
                                                     components spend is with large,                            with international human rights standards,
                                                     multinational companies who supply us with                 including the UN Universal Declaration of
                                                     finished products. We do not manufacture                   Human Rights, UN Convention on the Rights
                                                     our own products. Instead, we work with                    of the Child, and the International Labour
                                                     original design manufacturers (ODM) to                     Organisation Core Conventions.
                                                     produce Spark-branded devices. The goods                   See www.sparknz.co.nz/suppliers for
                                                     we procure are manufactured across the                     more detail.
                                                     world. Source locations include USA, China,
                                                                                                                The Supplier Code of Conduct was
                                                     South Korea, United Kingdom, and Sweden.
                                                                                                                introduced in FY18. To embed the Code, we
                                                     The services we procure are predominantly
                                                                                                                worked with our top 100 suppliers by
                                                     provided in New Zealand, Australia, India and
                                                                                                                contract value to ensure they were signed up
                                                     the Philippines.

                                                     2 High risk countries as defined by guidance in the United Nations Environment Programme Finance Initiative. This
                                                       was cross-checked with other more recent data sources to ensure we’ve identified the most important geographies.

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Spark New Zealand Statement on Modern Slavery 2020

Our supply chain (cont.)

                                                     to the Code or could demonstrate they are       with suppliers that are managed in our
                                                     adhering to an existing equivalent code of      framework. Our Code enables us to suspend
                                                     practice. We also used the Code as a basis      or cancel a non-compliant supplier’s supply
                                                     for four comprehensive, paper-based audits      of any goods or services to Spark, including
                                                     of large, offshore-based suppliers. These       suspending the payment of any associated
                                                     were significant suppliers operating in high    invoices, until that non-compliance is
                                                     risk and medium risk locations. The             remedied to Spark’s satisfaction. It also
                                                     assessments, which were validated through       enables us to terminate any or all of the
                                                     evidence provided and assertions by             supplier’s contracts with Spark.
                                                     Supplier Management, showed all four            The arrival of COVID-19 in FY20 restricted our
                                                     suppliers were adhering with the Code.          ability to carry out audits on compliance with
                                                     We endeavour to ensure all new suppliers        the Code. Instead, our focus in FY20 was on
                                                     sign up to the Code as part of their            incorporating environmental, social and
                                                     onboarding process. We do have a small          ethical considerations into our supplier
                                                     number of legacy or non-standard processes      selection processes. We have also matured
                                                     which do not yet require a supplier must sign   our approach and now include a scored
                                                     the Code, and we will be working to remove      section in our Request for Proposal (RFP)
                                                     and/or update those early in FY22. After this   process where we seek information from
                                                     time, signing up to the Code will be fully      suppliers on their non-financial performance
                                                     integrated into our procurement processes       and credentials.
                                                     across all spend categories. In FY20 the only   While our initial focus has been on our top
                                                     suppliers who did not sign up to Spark’s        100 suppliers, we are conscious there may be
                                                     Code were either global suppliers that have     suppliers who do not sit in this category who
                                                     their own code of conduct which Spark           also bring risks of modern slavery due to the
                                                     deemed equivalent to the Spark Code, or         nature of their business – for example, those
                                                     suppliers deemed low risk based on the          that employ migrant labour. In the remainder
                                                     services provided and the nature of the         of FY21 (to 30 June) and in FY22 we will
                                                     supplier – for example if the business is       investigate how we can more effectively
                                                     subscribing to a piece of software for a        monitor and mitigate any modern slavery
                                                     short period of time, and there is no request   risks within this part of our supply chain.
                                                     for proposal (RFP) process involved in
                                                                                                     Our Supplier Code of Conduct is
                                                     selecting it.
                                                                                                     underpinned by our Spark Value
                                                     If we become aware that a supplier is           Management Policy, which sets out
                                                     unable to meet the requirements of the          detailed guidelines for Spark people
                                                     Code, we work with them to implement            who are engaging suppliers – including
                                                     our process of remediation plans and            the requirement to source and procure
                                                     timeframes. We have ongoing conversations       goods and services ethically and responsibly.
                                                                                                     We also require suppliers to sign up to
                                                                                                     Spark’s Supplier Health and Safety Policy.

                                                                                                                                                 8
Spark New Zealand Statement on Modern Slavery 2020

Effectiveness of Spark’s approach

Spark is committed to identifying,                   We have strong foundations in place to           There have been recent instances of modern
                                                     do this, by way of an established operating      slavery in New Zealand and we recognise the
monitoring, and measuring the
                                                     model to monitor achievements against            need to raise awareness of slavery risks
risks of modern slavery in our                       our objectives. This includes strong risk        amongst our people, many of whom may
operations and supply chain.                         and issues management, along with                assume “that doesn’t happen here”.
                                                     processes to ensure we adapt and respond         To fully assess our effectiveness in this area,
                                                     to planned and unplanned challenges where        we will need to benchmark ourselves against
                                                     necessary We are focused on maintaining          other, similar, organisations and evaluate our
                                                     and enhancing this awareness across Spark        strengths and weaknesses. We will be doing
                                                     and its supply chain and have people and         further evaluation of our approach, and will
                                                     processes align to deliver this. We are a        identify actions for improvement, in the
                                                     values and purpose-driven business, with         remainder of FY21 and through FY22.
                                                     a strategic focus on building a diverse and
                                                                                                      One of our first steps will be to back up
                                                     inclusive culture, a track record of strong
                                                                                                      our Supplier Code of Conduct with regular
                                                     corporate governance, and a Code of Ethics
                                                                                                      audits of our direct suppliers, to ensure
                                                     and a Supplier Code of Conduct – both of
                                                                                                      we are assessing for modern slavery risks
                                                     which are deeply embedded in our relevant
                                                                                                      effectively and we will be planning for this
                                                     business systems and processes. These
                                                                                                      in the remainder of FY21 and implementing
                                                     are all underpinned by a culture that
                                                                                                      it in FY22.
                                                     encourages our people to speak up if they
                                                     are uncomfortable or concerned about             We also recognise that while our Supplier
                                                     anything they see.                               Code requires our suppliers to provide
                                                                                                      assurance there are no instances of modern
                                                     As a publicly listed, consumer-facing and
                                                                                                      slavery in their own supply chains, best
                                                     high-profile (within New Zealand) business,
                                                                                                      practice is to identify modern slavery risks
                                                     we are subject to a healthy level of scrutiny
                                                                                                      beyond our immediate supplier relationships.
                                                     from our stakeholders. Our shares are held
                                                                                                      We will be investigating possible avenues
                                                     by a geographically diverse shareholder
                                                                                                      for assessing risk in this sub tier in the
                                                     base who hold us to account on issues of
                                                                                                      coming months.
                                                     sustainability and social responsibility.
                                                     Sustainability is a key pillar of our business
                                                     strategy, and we have been continuously
                                                     improving and expanding our disclosure
                                                     on our non-financial performance in the past
                                                     few years. Our Annual Report for FY20 was
                                                     prepared in accordance with the International
                                                      Framework and the GRI Core Option.
                                                     We are a New Zealand-based company with
                                                     the vast majority of our operations, people
                                                     and customers located in New Zealand and
                                                     subject to New Zealand’s strong labour,
                                                     employment, and anti-corruption legislation.
                                                     This means we have a lower risk of modern
                                                     slavery in our operations than we would
                                                     otherwise, but we cannot be complacent.

                                                                                                                                                     9
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