2017-18 Anti-Slavery & Human Trafficking statement
This statement is made on behalf of the board of AMP Capital Holdings Limited and its subsidiaries (AMP Capital) about the UK Modern Slavery Act 2015 (“the Act”) which requires large employers to be transparent about their efforts to eradicate Slavery and Human Trafficking in their supply chain and any part of their business.
AMP Capital is a leading global asset manager specialising in real estate, infrastructure, fixed income, equities and multi-asset solutions. We are headquartered in Sydney, Australia, and operate in a number of other locations globally, including AMP Capital Investors (UK) Limited, our UK entity situated in London.
AMP Capital is a majority owned subsidiary of AMP Limited (“AMP”). AMP was founded in 1849 and is listed on the Australian Securities Exchange. AMP provides services including financial advice, retail superannuation and individual life insurance.
AMP Capital’s supply chains primarily consist of direct relationships with other regulated financial institutions based in Australia or other jurisdictions with comparable legal and regulatory frameworks. However, through our Real Estate Asset Management activity, which is largely limited to Australia and New Zealand, we work with a broader range of suppliers that facilitate operations in Shopping Centres, Office and Industrial locations.
AMP Capital is committing to:
- ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business
- acting ethically and with integrity in all our business relationships
- implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our supply chains
- taking appropriate steps to ensure anyone who works for AMP Capital, irrespective of their capacity or location works in an environment in which their fundamental rights and freedoms are respected
The AMP Code of Conduct states:
"AMP provides a respectful, diverse and safe workplace which supports the physical and psychological wellbeing of our employees and contractors. We believe this is critical to our ability to deliver outstanding results for customers, business partners and shareholders."
In respect of our material suppliers, we have in place controls to:
- identify and assess potential risk areas in our supply chains and in our business
- monitor potential risk areas in our supply chains and in our business
We also have in place controls to:
- ensure that Conflicts of Interest are escalated
- ensure that incidents/breaches are escalated
- protect whistleblowers
As part of AMP Capital’s risk management framework, in this reporting period we have re-stated our position on Slavery & Human Trafficking as set out in this disclosure in a Directive Note to our material suppliers. Our expectation is that they will commit to applying these standards to their operations and to their suppliers. We will provide our employees with ongoing risk and compliance training to ensure that they manage potential risks to our business. We encourage our employees to identify and report any potential breaches of policies and we also have protections in place for whistleblowers.
In quarter two of 2018 a dedicated project and working group has been established to ensure successful planning, development, delivery and embedding of measures and controls to continually improve our approach to supply chain governance.
We believe that additional work to ensure there are more robust measures and controls in our business to address the issue of Slavery and Human Trafficking will allow for further transparency and understanding of the risks that may exist in our supply chain.
This work includes but is not limited to:
- updating material supplier’s contracts to include requirements on Anti-Slavery and Human Trafficking as they are amended or refreshed
- updating non-material supplier’s contracts with the relevant language as they are amended or refreshed
- ensuring that all new relevant suppliers’ contracts include these requirements
- ensuring that initial and ongoing due diligence of our suppliers specifically considers Slavery and Human Trafficking
- providing targeted training to relevant employees in order to reinforce their obligations
- updating relevant Policies to ensure that they consider these requirements in detail
Additionally, we are exploring options and opportunities to collaborate with industry partners to work toward:
- Reducing the reporting burden on our common supply chains
- Improving data quality and integrity in relation to the risks and practices disclosed by our suppliers
- Discussing and sharing knowledge on key risks in our supply chains
For example, a pilot project is being considered in our Real Estate business that will investigate the use of an online data portal and information gathering system to help streamline and automate the process of contacting suppliers and analysing their responses.
Signed for and on behalf of the Board of AMP Capital Holdings Limited
Signed for and on behalf of the Board of AMP Capital Investors (UK) Limited
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