This statement, made pursuant to section 14 of the Modern Slavery Act 2018 (Cth), is published on behalf of NEC Australia Pty Ltd and its wholly owned subsidiaries, NEC IT Solutions Australia Pty Ltd and NEC IT Services Australia Pty Ltd (together referred to as NEC, we, us or our). The purpose of this statement is to outline our approach to ensuring that NEC has comprehensive frameworks and processes in place to minimise the risks of modern slavery in our business operations and supply chain. NEC acknowledges that slavery can occur in many forms as detailed in the Act including human trafficking, slavery, servitude, forced marriage, forced labour, debt bondage, child labour and deceptive recruiting. NEC is committed to operating responsibly and establishing and adhering to the highest ethical standards with a goal of identifying and working with its supply chain to eradicate the various forms of slavery.
2. Our structure, operations and business
In Australia, NEC is an information and communications technology company with over 1500 employees having a combined turnover in excess of $400 million. NEC Australia Pty Ltd is a wholly owned subsidiary of NEC Corporation, incorporated in Australia and has its headquarters in Melbourne. NEC Australia Pty Ltd owns two subsidiaries, being NEC IT Solutions Australia Pty Ltd and NEC IT Services Australia Pty Ltd. From a practical perspective, these three Australian entities operate as one entity and share all board members, corporate functions, policies and procedures. Further information on NEC Corporation’s response to modern slavery can be found here: https://www.nec.com/en/global/csr/modernslavery/
NEC’s main operations consist of the delivery of information technology and communications infrastructure, biometric solutions and managed services to our customers, both government and enterprise as well as corporate functions including sales, marketing, finance, procurement, legal risk and compliance. Our supply chain is comprised mostly of the procurement of technology to be on sold to customers (hardware, software and cloud services), professional services consultants and office consumables.
3. Risk identification
In FY2019, NEC undertook a review of the potential risk of modern slavery practices across our operations and supply chain taking into consideration factors such as sector, industry, product and service type and geographic location. In undertaking this review, NEC categorised its spend into the following categories: equipment and services sourced from globally recognised communications technology suppliers; NEC branded products sourced through NEC related entities; domestic field services, contracting and professional services suppliers; domestic facilities management and cleaning services; and office consumables and miscellaneous suppliers. As a result of the review, NEC identified some low risk areas which will likely form part of future assessments as well as areas on which it should focus its immediate efforts including major suppliers in each category, its field services suppliers, services currently delivered from overseas and its cleaning services. Our review also revealed limitations in the data captured and recorded on some of our suppliers. We will use these results to prioritise our supplier engagement activities next financial year.
4. Risk management and due diligence
To manage the risks of modern slavery in our supply chain, NEC has undertaken the following measures:
- introduced its first anti-modern slavery policy;
- commenced audits of key suppliers via a targeted questionnaire;
- introduced a mandatory questionnaire to new suppliers to enable initial risk assessment;
- expanded its vendor registration processes to capture and record more information about the individual suppliers;
- updated its Supplier Code of Conduct; and
- developed a plan to educate its staff on the impacts and risks of modern slavery through an internal training program.
5. Ongoing assessment of risk
In 2020, and the years to come, NEC will work to increase collaboration with internal and external stakeholders to prevent and address any contribution that NEC may have to the global issue of modern slavery. NEC will achieve this by focusing on raising awareness of the forms of modern slavery among our employees and suppliers, continuing to evolve our due diligence processes to aid in the identification of risks, expanding the scope of our supply chain risk assessment, reviewing existing processes and exploring ways to improve identification and action on risks throughout our supply chain.
This statement was approved by the boards of NEC Australia Pty Ltd and its subsidiaries.