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 under the Modern Slavery Act 2018 (Cth) (‘the Act’).

QIC’s approach to modern slavery is managed at the QIC corporate level, and is focused on continuous improvement. During this reporting period QIC:

• Updated our Modern Slavery Standard, which details expectations of our employees in relation to the management of modern slavery risks in our activities
• Updated the charter and responsibilities of our Modern Slavery Working Group
• Updated our Modern Slavery Risk Framework
• Increased guidance and information available to our employees to educate them about modern slavery and the risk areas within our activities
• Updated mandatory firm-wide Modern Slavery Awareness e-learning training, intended to increase awareness of modern slavery risks during supplier negotiations, as well as being a component of managing supplier relationships throughout their lifecycle 
• Released an internal Procurement Modern Slavery Toolkit to support our people making informed procurement decisions.

At QIC, we manage diverse asset classes and products on behalf of our clients, and we have different levels of ownership in, and influence over, our investments. Due to this, while our Modern Slavery Risk Framework is consistent, our approach to meeting our obligations under the Act varies across asset classes. In addition to the initiatives undertaken at a QIC corporate level, we have continued to progress the following activities specifically within our Real Estate business:

• Continued to include modern slavery questions in QIC Real Estate's tender process to ensure that proper consideration is given to human rights and modern slavery in the establishment of contracts, ongoing supplier relationship management and due diligence.
• Collaboration and certification with the Cleaning Accountability Framework (CAF). QIC Real Estate has been a member of CAF since 2018. CAF is a multi-stakeholder organisation that exists to end exploitation in property services and improve labour standards through education and advocacy.
• QIC Real Estate has three assets that have achieved CAF certification: Robina Town Centre, QLD; Castle Towers, NSW; and Eastland, VIC. Robina Town Centre and Castle Towers successfully completed an independent 'health check' process during the reporting period conducted by CAF to ensure ongoing compliance. As Eastland only received CAF certification in June 2022, its 'health check' is currently in progress. Three additional QIC Real Estate assets also commenced the CAF certification process during the reporting period, which are due for completion in FY24. 
• Assessment of the modern slavery risks of our real estate suppliers. Using the Fair Supply platform, we analysed QIC Real Estate's supplier spend and mapped the modern slavery risk of our supplier industries across 10 tiers of supply chain. The most significant modern slavery risks within QIC Real Estate's supply chain relate to the operations of our shopping centres due to the risks associated with commercial services and suppliers (including cleaning contractors and security services), and our Real Estate development projects due to the potential modern slavery risks associated with construction activities. 

Based on the supplier analysis, 150 of Real Estate’s suppliers were identified and invited to complete the Property Council of Australia’s Modern Slavery Supplier Platform questionnaire to assist us in gaining visibility regarding their understanding and approach to modern slavery. The Supplier Platform now includes 42 property industry members, and was established to lessen the reporting burden of suppliers to the property industry by asking them about the actions they are taking to assess and address human rights and modern slavery risks across their operations and supply chains on a single questionnaire and platform. The questionnaire response rate for QIC Real Estate’s suppliers was 55% (82 suppliers), which is above the average response rate across the broader platform.

Responses from the questionnaire have been assessed to establish a benchmark of QIC Real Estate’s suppliers’ current understanding and management of modern slavery risks to allow us to monitor changes over time. This will enable us to understand suppliers’ knowledge gaps and provide information and education to help improve their approach. This presents an opportunity to lift the maturity in managing modern slavery risks within our supply chain.

Below is an overview of some of the key findings from the most recent round of supplier responses:

• There were no reports of any respondent suppliers having been identified by their own employees or a third-party as having instances of modern slavery in their operations or supply chains.
• Only six respondent suppliers reported directly manufacturing products or maintaining operations outside of Australia. 
• Half of the respondent suppliers reported that they source manufactured products and services from overseas, with China being the most common country where items are sourced from. 
• Almost all respondent suppliers (96%) reported their key stakeholders have a general understanding of modern slavery.
• 44% of respondent suppliers provide training on modern slavery to their employees or suppliers and 21% plan to provide training in the coming year.

QIC Real Estate continued to attend the Informed 365  Modern Slavery Property Supplier Platform  Group as part of our membership with the Property Council of Australia’s Modern Slavery Supplier Platform. This group meets monthly to identify opportunities to continuously improve the platform. In FY24 QIC Real Estate will also be a member of the Property Council Human Rights and Modern Slavery Working Group, which works on initiatives to help improve the industry’s response to modern slavery.

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.