INTRODUCTION
The Modern Slavery Act 2018 (‘Act’) commenced operation on 1 January 2019. The Act aims to combat modern slavery in global supply chains. The United Nations and Walk Free Foundation estimate there are approximately 40 million victims of modern slavery around the world. The Act creates reporting obligations for Techants Solutions Pty Ltd (defined in Structure below) including producing an annual Modern Slavery Statement (‘Statement’) and examining modern slavery risks within Techants’s supply chain.
COMMITMENT
This statement is made pursuant to sections 14 and 16 of the Act and outlines the steps Techants is taking to ensure modern slavery and human trafficking does not form part of its organisation or supply chain. Technats is committed to continuous improvement to meet its responsibilities under the Act.
OUR OPERATIONS AND SUPPLY CHAIN
Techants adheres to high ethical standards which are at the centre of its operations. Decisions and processes in its supply chain are made with careful consideration of these ethical standards. As such, Techants aims to partner with people and companies that align with these standards.
Direct Operations
Techants is an Australian privately owned company founded in 2019 with operations located in Australia, India, and Bangladesh. Techants manages the end-to-end IT environments of its clients spanning hybrid infrastructure, hosting, cloud, networking, unified communications, user and device support, professional service consultants, project services, and cyber security requirements. Techants clients are spread across a broad range of industries including aviation, manufacturing, construction, realestate, and medicin _________. Technts direct workforce comprises over 30 employees with the majority based in Australia. In 2023,
Supply Chain
Techants supply chain consists of engaging IT service providers, procurement of IT related products and office related costs such as facilities management, office amenities and office consumables. Techants has over 100 active suppliers. These suppliers are primarily located in Australia.
RISK MANAGEMENT
Direct Operations
Techants operates in a regulated environment and has robust employee policies and procedures in place. Techants employees are primarily skilled white-collar professionals and are considered lower risk for modern slavery. Techants employees are based in Australia, India, and Bangladesh. Geographically, India and Bangladesh are considered higher risk, however, given the nature of the work (white-collar professionals), remuneration packages inexcess of market rates and compliance with local labour laws, modern slavery is not considered to be a high risk.
Supply Chain
Techants has assessed its supply chain and overall considers there to be minor areas of risk. Based on Techants analysis of modern slavery risk factors, principally geography and sector, risk is limited to Techants procurement of IT hardware, specifically hardware manufactured in Asia. We acknowledge that we continue to lack visibility in overseas markets of secondary levels of our chain of suppliers and source materials used in our group’s goods and services. This risk is mitigated by Techants procurement of IT hardware from reputable Australian and international suppliers, as well as a review of such suppliers’ publicly available modern slavery statements.
DUE DILIGENCE
Techants is committed to ensuring that its operation and supply chain is free of any human rights violation and where potential risks are identified, that these are quickly addressed.
The appropriate action will depend on whether Techants has caused the impact, contributed to the impact, or is linked to the impact through its business relationships. In instances where Techants has caused the impact, actions will be taken to cease or prevent the risk. In instances where Techants has contributed to the impact or is linked to the impact through our business relationships, Techants will act and leverage our position to mitigate the remaining risk as much as possible.
Direct Operations
Techants has policies and guidance for employees including, but not limited to:
- Modern slavery policy
- Whistle-blower policy
- Employee code of conduct
- Leadership Training
- Corporate social responsibility policy
- Anti-bribery and anti-corruption policy
Supply Chain
The due diligence includes an ongoing review of all active suppliers. The review involved the following steps:
- Classification of all suppliers into three risk categories – higher risk, medium and lower risk. Factors considered in risk classification included geographical location, sector and probability of continued use or re-engagement;
- Online search of higher risk suppliers for relevant modern slavery statements and disclosures; and
- As part of Techants commitment to raising awareness of modern slavery across its supply chain, suppliers across all risk categories (weighted more heavily to higher risk suppliers) were sent a Techants questionnaire requesting information on their compliance within the requirements of the Act
The above steps were also performed for the newly acquired entities in order to obtain an understanding of each company’s supply chain and ensure compliance with Techants standards. No additional risks were identified, with the exception of countries that Techants has not previously operated in, which is outlined in the Risk Management section.
Techants continues to follow up for responses to the questionnaire and to qualitatively evaluate the level of risk associated with each supplier. Techants has also revised and refined its supplier code of conduct to include an expectation of assistance from suppliers to enable Techants to assess if the supplier iscompliant with the Act, and therefore suitable for Techants to engage with.
GRIEVANCE & REMEDIATION
Techants continues to provide avenues for affected employees to safely raise concerns about modern slavery in Techants operations and supply chain. As Techants approach to modern slavery develops there is an increasing probability that it will encounter modern slavery in its supply chain. Techants continues to monitor and, where applicable, respond to potential modern slavery incidents. No grievances were raised in the reporting period.
ASSESSING EFFECTIVENESS OF OUR RISK MANAGEMENT
The effectiveness of the modern slavery process is measured by several key metrics. We recognise that our review and assessment of our actions to identify and address our modern slavery risks in our operations and across our supply chain will be an ongoing and evolving process that we are committed to continue to build upon. We actively review and assess the effectiveness of our approach to inform our path forward.
Direct Operations
Techants conducts annual benchmarking of staff salary packages to ensure staff are fairly and appropriately remunerated. Numerous additional employee benefits are provided to all employees and regularly assessed by management.
Supply Chain
As part of the due diligence process Techants conducted a review of all active suppliers. Techants continues to engage with suppliers directly to ensure their supply chains are free of modern slavery risks. Techants monitors the active supplier listing, and correspondence / results of questionnaires, ensuring an increasing number of suppliers are deemed low risk for modern slavery. The results of the qualitative analysis were generally positive with a number of key suppliers undertaking proactive measures to minimise and mitigate their modern slavery risk. An increasing number of these suppliers have put policies and protocols in place to address modern slavery risk
In the current reporting period, a process was put in place for all new suppliers to complete the questionnaire prior to engagement with Techants, combined with the supplier code of conduct which has been revised in the current period. Further, the questionnaire sent to higher and medium risk suppliers (including to those suppliers that have previously completed the questionnaire) was enhanced to include more granular questions to assist Techants to further understand the maturity of its suppliers and their awareness of modern slavery risks.
FUTURE COMMITMENTS & NEXT STEPS
Techants will work to increase collaboration with internal and external stakeholders to prevent and address any contribution that Techants may have to the global issue of modern slavery. Techants will achieve this by focusing on raising awareness of the forms of modern slavery among its employees and suppliers, continuing to evolve its due diligence processes to aid in the identification of risks, expanding the scope of its supply chain risk assessment, reviewing existing processes (particularly the IT hardware procurement process) and exploring ways to improve identification and action on risks throughout its supply chain. Further initiatives planned include:
- Further review of and engagement with potential high-risk suppliers who did not respond to Techants’s questionnaire
- Continually review and assess low and medium risk rated suppliers
- Provide further training to employees on modern slavery
CONSULTATION & APPROVAL
This statement is made pursuant to sections 14 and 16 of the Act. It has been made available for comment and review by the Techants Executive Leadership team. The statement was approved by Mohibbur Rahman and Sivakumar Velayuthan as Directors of Techants Solutions Pty Limited on 1 July 2023. We consulted the relevant companies we own or control in the development of this statement. The statement will be updated annually.