The Modern Slavery Act 2018 (Cth) (‘the Act’) came into effect on 1 January 2019, placing a requirement on eligible entities to submit an annual Modern Slavery Statement. The Act seeks to actively reduce the risk of modern slavery occurring in Australia and across the globe.

As an Australian entity with an annual consolidated revenue of more than $100 million, QIC is required to report on the risk of modern slavery across its investment activities and portfolios, as well as through its operations and procurement supply chains.

Reporting obligations under the Act relate to the steps taken to respond to the risk of modern slavery in our operations and supply chains, and those of controlled entities. In addition, as an investor we are required to report on the steps taken to identify and respond to the risk of modern slavery in our investment portfolios.

QIC welcomes the increasing attention that is being directed towards the prevalence of modern slavery in global supply chains. The FY22 reporting period was marked by a maturing of QIC Group’s modern slavery response. Moving beyond the initial foundations for implementing internal governance structures, awareness raising and basic supplier engagement, QIC has continued to pursue a continuous improvement approach to our due diligence and remediation framework. 

At a QIC level, we have continued to progress the following initiatives:

• Continued the ongoing process of updating supplier contracts to include clauses that specifically address modern slavery issues
• Undertook ongoing assessment of our operations, supply chains and investment portfolios for exposure to modern slavery risk
• Specific engagement with cleaning suppliers to determine the actual level of modern slavery risk exposure for particular brands of disposable rubber gloves in light of recent reports of forced labour practices in associated manufacturing facilities in Malaysia
• Development of a Procurement Modern Slavery Toolkit designed to assist procurement officers in addressing modern slavery supply chain risk at all stages of the QIC ‘procurement cycle’. The Toolkit is intended to be rolled out in the next reporting period (FY23)
• Ongoing mandatory firm-wide Modern Slavery Awareness training for staff as part of QIC’s annual compliance training.

In addition to the initiatives undertaken at a QIC level, we have continued to progress the following activities specifically within our Real Estate business:

• Ongoing due diligence relating to solar energy suppliers. QIC has an increased awareness of the risk of modern slavery in the Xinjiang Province in China and has identified that for our Real Estate supply chain there is a risk that source materials and components of solar panels could potentially be impacted.

• Continued collaboration and certification with the Cleaning Accountability Framework (CAF). Cleaning services have been identified as a sector where Australian workers can be at risk of exploitation and where a potential risk of modern slavery might occur. CAF is a multi-stakeholder organisation that exists to end exploitation of cleaners across property services and improve labour standards through education and advocacy, and includes a worker-centric due diligence mechanism. Given the potentially elevated risk identified in respect of our ownership of shopping centres around Australia, QIC Real Estate’s ongoing collaboration with CAF remains a key priority in our overall modern slavery response.
  • In FY22, Eastland in Victoria obtained CAF certification, joining two of our other major retail centre assets, Robina Town Centre in QLD and Castle Towers in NSW who have previously gained CAF certification.

• Signing up to the Property Council of Australia’s modern slavery supplier platform, which enables us to request our suppliers to complete a centralised best practice questionnaire regarding their understanding and approach to modern slavery. QIC Real Estate’s top 200 suppliers by risk and spend were invited to complete the questionnaire.
  • The responses to the questionnaire will inform how we can best support our suppliers in their modern slavery journey. Our intention is that through understanding the areas where their knowledge gaps may be, we can provide leadership, information and education to improve their approach and thus lift the response to modern slavery across our supply chain.

• Fair Supply was engaged to investigate the potential risk across a number of manufacturers and QIC Real Estate used this information to make an informed decision about the most appropriate supplier to engage prior to progressing our onsite solar rollout. It should be noted that although generally appropriate mitigation frameworks were in place, a clear outcome was that it was practically impossible, based on the available information, to categorically exclude the existence of possible linkages to Uyghur forced labour. More broadly, we have also enhanced our due diligence process to specifically ask new suppliers about their understanding of any Xinjiang or forced labour practices in their own operations or in their supply chains.

During the reporting period, QIC did not become aware of any actual or suspected incidences of modern slavery in its supply chains or operations.

For more on QIC's approach to Modern Slavery, see our Modern Slavery Statement.