Aristocrat is committed to ensuring that working conditions in its operations and supply chains are safe, that all workers are treated with respect and dignity. We also require that business operations are environmentally responsible and conducted ethically in line with applicable laws, and in a manner that meets appropriate community and societal standards.
The past year has brought with it exceptional challenges across procurement and supply chains due to COVID-19. Aristocrat has taken action to maintain business continuity, mitigate supply chain risks and further reinforce our approach to adopting responsible business practices.
As part of our business continuity process, we are continually engaging and communicating with our suppliers regarding their financial health and capacity to provide services and deliver our products on time.
CONTINUOUS IMPROVEMENT WITH OUR SUPPLIERS
To ensure our standards are met, and with a view to continuous improvement in the way we work with our suppliers, in 2019 we began updating our supply chain contracts to require suppliers to comply with all applicable Modern Slavery, Human Rights, Conflict Minerals and related laws. Contracts have been updated on a priority basis, with supplier criticality and contract duration being key considerations.
Throughout 2020, we have updated these provisions in key agreements with our strategic suppliers and incorporated additional requirements to reflect best business practices and legal developments. Updated provisions also include ethical sourcing and anti-bribery clauses. As part of our due diligence process, we are continually and actively communicating with suppliers regarding our requirements and monitoring their compliance with our agreements.
CONFLICT MINERAL SOURCING
Aristocrat complies with all applicable Conflict Minerals regulations, including the US Dodd Frank Act (Section 1502), and the EU’s Regulation 2017/821 concerning minerals originating from conflict zones and high-risk areas. We require our suppliers to also:
- supply conflict-free materials and products;
- respond to requests for information on sources of supply; and
- perform due diligence on their own suppliers and sources of materials for products to be supplied to Aristocrat.
EMPLOYEE AWARENESS AND TRAINING
To raise awareness with employees, we have developed a Modern Slavery and Human Trafficking Training Course tailored to our business. This training comprises two modules: the first aimed at all employees, serving as an introduction to what modern slavery is, what signs to look for, and what employees should do if they observe or suspect it is occurring. The second is aimed at employees working in our Global Supply Chain, Procurement, People & Culture, Design & Development functions, and other employees who have direct engagement with suppliers. The content aims to educate and upskill these supplier facing employees to understand our ethical sourcing obligations and commitments, as well as providing guidelines on how to effectively partner with and assess suppliers to drive improvements.
The rollout of module one is expected to commence at the end of 2020 and module two during 2021.
In 2020, we published our Supplier Code of Conduct which reflects our company values and captures our ethical sourcing principles, reinforcing our commitment to conducting business with the highest levels of integrity and in compliance with both the letter and spirit of applicable laws and expectations. View our Supplier Code of Conduct
In tandem with supplier contracts, the Supplier Code of Conduct places obligations on suppliers based on the modern slavery legislation in Australia and the United Kingdom, the Responsible Business Alliance Code of Conduct, and other international standards. Suppliers are required to adhere to the principles set out in the Supplier Code of Conduct and Aristocrat will assess a supplier’s performance and commitment to compliance when making sourcing decisions, including the selection, retention, and termination of suppliers.
Our goal is to work with suppliers to improve conditions through communications, training, monitoring and follow-up assessments and we place an obligation on suppliers to cooperate with us to identify and mitigate sourcing risks and remediate potential violations in their supply chains.
HUMAN RIGHTS AND MODERN SLAVERY
In 2020, Aristocrat had no major suppliers that were located in the “highest prevalence” countries reported in the 2018 Global Slavery Index (GSI).
Suppliers in territories that are reported by the GSI to have a “higher prevalence” of modern slavery and human trafficking are required by Aristocrat to complete a Modern Slavery Survey, introduced in 2020, which is aimed at ensuring suppliers:
- maintain policies and procedures to safeguard key human rights, including freedom from discrimination, child and forced labour;
- treat their employees and contractors with dignity and respect; and
- provide safe working conditions, reasonable working hours and fair remuneration.
We phased the release of the Modern Slavery Survey based on geographic and social risk factors. Phase 1 (higher risk) has been completed and phases 2 and 3 (lower risk) are planned for completion in December 2020, and January 2021 respectively10.
Aristocrat requires suppliers to provide periodic self-assessments to ensure human rights violations are not occurring within their operations. The specific nature of due diligence undertaken for each supplier has evolved to reflect emerging best practices regarding procurement and supply chain management. For example, the current version of our supplier due diligence assessment includes several questions relating to the identification and evaluation of modern slavery and human trafficking risks, including questions with respect to:
- the use of contracted workers or other sub-suppliers;
- the availability of workers to support increased business or order volumes;
- the recognition of labour union representation;
- compliance with regulations relating to child labour, forced labour, health and safety, working hours, compensation, freedom of association and collective bargaining, and abuse;
- the availability of employee reporting and whistle-blowing policies; and
- protection against fire and other hazards.
The COVID-19 pandemic has prevented the Global Supply Chain (GSC) team from conducting on-site supplier audit visits during 2020. We intend to resume the regular program of on-site visits when government guidance allows and travel restrictions are lifted.
10TISCreport, an accredited B Corp social enterprise, has assessed our latest UK Modern Slavery Statement and confirmed it has passed all technical compliance checks, with Aristocrat Technologies Europe Limited being in the top 6% of companies in scope for Section 54 in meeting the minimum criteria in 2020. TISCreport is not affiliated to UK Government but reports regularly to the Home Office Transparency in Supply Chains Modern Slavery Strategy and Implementation Group.