Modern slavery

It is imperative that Centuria Capital Group establishes a responsible and sustainable supply chain that aims to mitigate the modern slavery risks.

Modern slavery situations occur where businesses or individuals use coercion, threats or deception to exploit people and limit their freedom. This can include human trafficking, slavery, servitude, forced labour, debt bondage, forced marriage and child labour. Supply chains in the property development and real estate industry are complex and diverse, and we are committed to mitigating the modern slavery risk along the supply chains as outlined in this disclosure.

All listed and unlisted entities follow the strategies and policies set in place by Centuria Capital Group when managing respective supply chains and mitigating modern slavery risks.

Policies and initiatives

We continue to adopt a risk based approach to assessing modern slavery risks across its operations and supply chain. This approach acknowledges that certain segments of the business and some suppliers expose the Centuria to higher risks. We acknowledge that no approach to assessing modern slavery risks is perfect and will continue to update the current approach based on findings and in consultation with the wider industry.

The modern slavery risk-based approach considers:

Material spend
Supplier type
Location of supplier

We ensure that the Group’s employees are aware of the issues produced by modern slavery practices and prioritise training to help staff take appropriate action where modern slavery risks are suspected or identified, including how to engage with suppliers when a concern or incident is raised.

During this reporting period, all facility managers have completed modern slavery training provided by independent training providers appointed by Centuria. Facility managers in Australia receive training from Safetrac, an online training platform that has been built by qualified and experienced lawyers. This year, we have also extended our modern slavery training to our offices in New Zealand via a third-party asset management contractor as the independent training partner.

Modern slavery training

What modern slavery is
Regulatory requirements for both Australia and New Zealand
Identifying modern slavery practices
Creating partnerships with suppliers to combat modern slavery practices
Understanding our ability to influence change
Reporting structures.

Supplier engagement

Our suppliers are involved in our processes of responding to modern slavery practices. This year, we have had a 77% turnaround rate to provide Informed 365 System assessments. We continuously strive to have a strong relationship with our suppliers and believe that this is a strong indication that they share the same values as us.

Governance

Our Board’s have responsibility for establishing a framework of risk management across the Group. In FY21, a Modern Slavery Working Group was established to facilitate our response to modern slavery. Chaired by the Group Manager of Sustainability (GMS), the working group discusses key actions taken by each part of the business to assess modern slavery across its operations. Meetings are also attended by relevant representatives across the organisation, including asset management, development and corporate divisions.

All material risks that are identified by the Working Group are reported to the Centuria Capital Group Board through the Audit, Risk & Compliance Committee, where strategic responses are made regarding mitigating the risks of modern slavery.

Modern slavery roadmap

The last Modern Slavery Statement mapped out strategic areas of focus for the Group across 2022. A summary of the roadmap is as follows:

Ongoing awareness training for our employees and suppliers within Australia and New Zealand.

Centuria continue to partner with Safetrac to deliver Modern Slavery training to staff. At time of reporting, all Facility Managers in Australia have completed training.

Engaging key personnel and our third-party asset management team in New Zealand to begin awareness training.

Centuria has worked with Bayleys to help strengthen their approach to managing modern slavery. In FY23 Bayleys completed a financial analysis of their top two suppliers, adopting a risk-based approach to assess modern slavery.

Formalise modern slavery roadmaps for our cleaning, labour, security, corporate and development operations.

All operational segments have a roadmap which is managed by respective representatives.

Engage with suppliers who either fail to complete the Informed 365 questionnaire, or have identified areas for improvement.

Centuria has increased the number of suppliers assessed by the Informed 365 system.

Provide periodic updates to the Culture and ESG Board Committee.

The Culture and ESG Committee received regular updates regarding the Group’s Modern Slavery efforts, including outcomes from the recent Modern Slavery Act 2018 review.

Test grievance process is fit for purpose by trialling scenario of modern slavery incident.

After trialling incidents across teams, Centuria has identified areas of improvement and will continue to enhance the processes involved in monitoring grievances and escalation processes by way of awareness and education. Centuria will periodically test grievance processes in various scenarios.

Review of payment on time.

The Group now monitors payment on time for suppliers during a monthly meeting. The Modern Slavery Working Group receives regular updates regarding the performance of this metric and seeks to remedy delays in payment for suppliers.