Financial Year 2022 - 2023
Modern slavery is a grave violation of fundamental human rights, impacting an estimated 45 million men, women, and children worldwide. This crime involves exploiting victims through coercion, threats, deception, and other forms of manipulation. The term "modern slavery" encompasses various forms of severe exploitation, such as trafficking, slavery, servitude, forced marriage, forced labor, debt bondage, the worst forms of child labor, and deceptive recruiting for labor or services. In line with the Modern Slavery Act's definition, our assessment on modern slavery includes data analysis and collation across all reporting entities and their controlled entities, as the latter are also considered reporting entities for the purpose of this statement.
2. Our Commitment
At Renascent, we are deeply committed to eradicating the potential for modern slavery practices within our operations and supply chain, ensuring this commitment permeates all levels of our business. Respecting human rights aligns with our core values and beliefs, and we strive to treat everyone equitably, fostering a safe, ethical, and transparent workplace and operating environment.
We have embarked on a rigorous journey, taking significant strides to address modern slavery risks. As we progress, we will continually refine and enhance our approach and assessment, identifying and responding to the risk of modern slavery practices within our organisation.
3. Reporting Entity Identity
This statement is issued on behalf of Renascent Australia Pty Ltd and its wholly owned subsidiaries, including Renascent Regional Pty Ltd, Renascent Constructions (Victoria) Pty Ltd, Renascent Western Australia Pty Ltd, Renascent QLD Pty Ltd, and Dice Renascent Pty Ltd (collectively referred to as Renascent, we, us, or our), in accordance with the Modern Slavery Act 2018 (Cth). From a practical standpoint, these six Australian entities function as a single entity, sharing board members, corporate functions, policies, and procedures.
5. Our Structure, Operations and Supply Chain
5.1 Our Structure
Renascent is a privately owned construction company that has been serving government and private clients since 1995. Our expertise lies in construction, refurbishment, fit-out, and facilities maintenance. We take pride in our strong connection with the local community and our commitment to giving back. With offices strategically located in Sydney (NSW), Orange (NSW), Melbourne (VIC), Brisbane (QLD), Canberra (ACT), Perth (WA), and Tivendale (NT) our teams actively engage with the Australian community, supporting various local, civic, professional boards, and charitable organisations. We believe in sharing our success with those around us.
While each of our entities operates as a stand-alone business, they are governed and managed by the Renascent Board of Directors, our Executive Management Committee, and our Senior Executives and Managers. Notably, Dice Renascent is a jointly owned and operated indigenous company, with a 51-49 ownership structure respectively.
All our entities adhere to the same set of policies, procedures, plans, and an integrated management system overseen by the Renascent Board of Directors, our Executive Management Committee, and our Senior Executives and Managers. Our headquarters is located at Level 4, 174 Pacific Hwy, St Leonards NSW, and we maintain satellite offices in Orange (NSW), Melbourne (VIC), Brisbane (QLD), Perth (WA) and Tivendale (NT).
5.2 Our Operations
Renascent is a construction company specialising in fit-out, refurbishment, construction and maintenance services. As the head contractor, we play a crucial role in evaluating, engaging, and monitoring numerous subcontractors who assist us in executing building projects. Additionally, we handle significant procurement activities to fulfill the project requirements on behalf of our clients.
The evolution of our business is founded by our ability to innovate and lead change to provide our clients with project and financial surety. Our delivery model is built on experience, intellect, resources, and efficient systems. Our philosophy is simple yet powerful: thorough front-end management ensures certainty in project completion. By prioritizing meticulous planning and coordination, we deliver exceptional outcomes and peace of mind to our clients.
To ensure the best possible outcomes, our National Leadership Team comprises highly skilled and experienced professionals who possess in-depth knowledge of the construction industry and exceptional leadership abilities. We maintain an outstanding safety record across all projects, demonstrating our unwavering commitment to governance. This commitment is reinforced by the continuous development and improvement of our accredited integrated management systems. As responsible members of the corporate community, we adhere to industry best practices and strengthen our governance framework through regular internal and external audits.Safety is a top priority at all our sites, and effective management is ingrained in our entire team, from the managing directors to our site personnel. Renascent has implemented robust processes and procedures to ensure compliance with relevant legislation and standards, including the Fair Work Act 2009, respective state Work Health and Safety Acts, and the Modern Slavery Act 2018 (Cth).At Renascent, we hold various accreditations that exemplify our commitment to excellence in project execution. These accreditations showcase our dedication to upholding the highest standards in our industry.
5.3 Supply Chain
Renascent operates with a team of over 130 employees, managing up to 30 active projects across various industry sectors simultaneously. Our dedicated team is the driving force behind the reliability and success of our projects. We value the diversity of our employees, who bring unique perspectives, techniques, and strategies to our Renascent family. Together, we form a highly dynamic team capable of confidently tackling every project.
To deliver our projects, we heavily rely on subcontractors and suppliers. Subcontractors play a crucial role in procuring the necessary products and materials within their respective packages, adhering to the project's scope and specifications. In certain cases, Renascent or our clients may directly handle procurement decisions.
In our supplier engagement and management processes, we have integrated ongoing due diligence and oversight of Modern Slavery risks for existing suppliers. As a prerequisite for new vendors, we now require their mandatory acknowledgement of our Modern Slavery objectives, ensuring their understanding and compliance.
6. Modern Slavery Risks in Our Operations and Supply Chain
As we progress with embedding our supply chain risk systems and processes, we are taking a phased approach toward improving transparency across our direct and extended supply chains throughout our operating regions. The construction sector has experienced longstanding demand for low-skilled, manual, often migrant labour, which makes it particularly vulnerable to risks of debt bondage, human trafficking and forced labour practices. The indirect use of site labour utilising low-skilled manual work recruited for sub-contractors by labour hire agencies, is an area requiring greater transparency across the construction industry.
Another area of risk is the lack of visibility in multi-tiered manufacturing supply chains for construction materials. Materials are sourced, processed, assembled and finished, traversing several countries, some of which have an elevated risk of modern slavery. These production phases are transient and, in the property and construction industry, have not been readily traceable to the end user.
Globally, 18% of modern slavery victims are found in the Construction Industry, making it a high-risk industry.
Common modern slavery risks in construction are:
- Forced or unpaid labour
- Child labour
- Unsafe conditions
- Debt bondage
The drivers of high victim rate are:
- High demand for low-skilled labour
- Poor visibility over the supply chain – due to outsourcing
- Materials being sourced from high-risk geographies.
6.1 Risk Assessment FY23
Renascent conducted a risk assessment to evaluate any new risks related to modern slavery in its operations. The assessment revealed that the risk profile remained unchanged, and the modern slavery risks within Renascent's operations and supply chain are as follows:
- Underpayment of workers and exploitation of migrants in construction, trades, or labour hire.
- Labor conditions and child labour in the supply chain of building and mechanical products and materials.
- Labor conditions and child labour in the supply chain of manufactured goods, such as furniture, hardware, and fittings.
Renascent recognise these risks and is committed to addressing them appropriately. Efforts will be made to mitigate these risks and ensure that the company's operations and supply chain are free from modern slavery practices.
7. Actions Taken to Assess and Address our Modern Slavery Risks
During the reporting period, Renascent’s priorities were to better understand the modern slavery risks within our operations and supply chain and establish a framework to ensure that modern slavery is considered in all our operational and supply chain relationships.
Key actions undertaken include:
8. Actions Taken to Assess and Address our Modern Slavery Risks
Assessing the effectiveness of actions taken to address modern slavery is crucial to ensure progress and identify areas for improvement. Here are some Renascent key steps and considerations to evaluate the effectiveness of our anti-slavery efforts:
1. Establishment of a Modern Slavery Working Group: We have formed an internal Modern Slavery Working Group, comprising key individuals from various roles within our organisation. This group is responsible for addressing and implementing Renascent's key actions to stop and prevent modern slavery in our operations. The working group includes:
▪ Group Operations Manager
▪ Chief Financial Officer
▪ National HSEQ Manager
▪ National HR Manager
2. Annual Review of Risk Registers: We conduct an annual review of the Company and Project Risk Registers to identify any new risks associated with modern slavery. This helps us stay proactive in our approach.
3. Establishment and Review of Key Actions: We have established key actions to prevent and stop modern slavery in our operations. These actions are regularly reviewed to ensure their effectiveness and relevance.
4. Engaging External Providers: We enquire about the modern slavery efforts of our external providers, including subcontractors, suppliers, and consultants through our prequalification process. This helps us assess their commitment and compliance in combating modern slavery.
5. Internal Audits: We conduct internal audits to identify any new or potential cases of modern slavery within our operations. This proactive approach allows us to address any issues promptly.
6. Annual Modern Slavery Statement: Each year, we develop a Modern Slavery Statement that outlines the progress made in combating modern slavery. This statement highlights achievements, challenges faced, and lessons learned.
7. Continuous Improvement: We use the findings from assessments and evaluations to inform our strategic planning and continuously improve our anti-slavery efforts. This ensures that our actions remain effective and aligned with our goals.
9. Continuous Improvement Commitments
Improvement Commitments We understand that addressing widespread modern slavery practices in global supply chains requires strong collaboration not only with suppliers but also with government, industry, and civil society. We are fully committed to eliminating modern slavery risks from our supply chains, and we are continuously advancing our initiatives in close cooperation with our suppliers, employees, and stakeholders. During the FY24 reporting period, Renascent is dedicated to the following actions:
▪ Risk Assessment: Conduct a thorough risk assessment to identify any new risks related to modern slavery. Review the findings and establish a plan to monitor and mitigate the most significant risks.
▪ Due Diligence: Enhance our subcontractor, supplier and consultants’ engagement and interview process by incorporating questions regarding modern slavery risk and compliance at the tender stage. This will ensure that we are diligent in selecting partners who share our commitment to eradicating modern slavery.
▪ Training and Awareness: Implement an internal Modern Slavery training program that will be rolled out to all staff members. This training will raise awareness, enhance understanding, and equip our employees with the knowledge and skills to effectively address and respond to modern slavery issues. Investigate external 3rd Party Training providers and determine if this training would be value adding.
▪ Monitoring and Reporting: Establish monitoring mechanisms to track and evaluate the effectiveness of our efforts to combat modern slavery. Regularly report on progress, challenges, and achievements.
By undertaking these actions, we aim to strengthen our proactive approach to combatting modern slavery and create a work environment that is free from exploitation and injustice.
This statement was approved by the Board of Directors of Renascent Australia Pty Ltd on 14th July 2023.