National Australia Bank Modern Slavery and Human Trafficking Statement
This Modern Slavery and Human Trafficking Statement (Statement) is made pursuant to the Modern Slavery Act 2015 (UK) (MSA) by National Australia Bank Limited (ABN 12 004 044 937) (NAB) in respect of NAB and its related bodies corporate (NAB Group) and relates to the financial year 1 October 2015 to 30 September 2016 (2016 financial year).
About our business
NAB is a financial services business providing a range of financial products and services. NAB operates principally in Australia and New Zealand, with an international network extending to China, Hong Kong, India, Indonesia, Japan, Singapore, Vietnam, the United Kingdom and the United States. The NAB Group’s portfolio comprises Australian Banking, including retail, business, private, corporate and institutional banking, and wealth management, NZ Banking, NAB Wealth and Corporate Functions and Other.
NAB has a global supply chain made up of around 1,761 contracted suppliers1. Our supply chain relationships include suppliers from the following sectors: Information, Communications, and Technology; Property Services (including Facilities Management, Utilities, Cleaning, Waste Management and Security); Business Process Offshoring; Logistics and Correspondence; Consulting Services; Marketing; Print and Promotional Goods and Services; Fleet Management; Office Supplies; and Corporate Clothing.
NAB seeks to do business with suppliers that have similar values, ethics and sustainable business practices, including those related to human rights. NAB recognises that as a large purchaser of goods and services, the business conduct and performance of its suppliers can have a significant impact on its performance and reputation within the communities in which it operates.
NAB understands that the environmental, social and governance (ESG) risks relating to suppliers will vary depending on their industry, geographic location and company size and, therefore, the scope of NAB’s suppliers’ policies, processes and systems are expected to reflect their specific ESG risks.
NAB’s policies and principles
One of NAB’s key values is ‘respect for people’. As stated in its new Human Rights Policy (developed in 2016), NAB does not tolerate slavery, human trafficking, forced or child labour or child exploitation. In addition to the Human Rights Policy, NAB has various other policies which assist in managing human rights, including the following:
- Code of Conduct
- ESG Risk Principles
- Group Procurement Policy
- Group Outsourcing and Offshoring Policy
- ESG Risk Credit Policy
NAB is also in the process of updating the following policies to assist in managing human rights, with a view to reducing the likelihood of its operations or business relationships being associated with modern slavery and human trafficking:
- Group Whistleblower Protection Policy
- Group Supplier Sustainability Principles
NAB’s risk management and due diligence processes
As a financial services organisation with a professional workforce, NAB considers the risk of modern slavery within its direct business operations to be low. However, NAB recognises that through its supply chain and customers, it can be indirectly exposed to the risk of modern slavery and human trafficking.
NAB has implemented risk management processes to identify, assess, mitigate and monitor potential risk areas where it could be exposed to human rights concerns, including modern slavery and human trafficking. This includes use of a ‘High Risk ESG sectors and sensitive areas list’, which is used to determine customers and suppliers that may have a higher risk of ESG issues. NAB has a Group Whistleblower Protection Policy and associated Group Whistleblower Program that allows employees to raise concerns in a confidential manner.
NAB has a Supplier Sustainability Program in place to manage ESG risks within its material supply chain relationships. At the Supplier Sustainability Program’s core are a set of NAB Group’s Supplier Sustainability Principles (GSSPs) which outline the requirements suppliers are expected to meet to do business with NAB, including requirements in relation to labour practices and human rights. The GSSPs form part of the requirements of the Group’s Procurement and Outsourcing & Offshoring Policies. Further details about NAB’s Supplier Sustainability Program (including the GSSPs) can be accessed here.
The ESG risk assessment undertaken on NAB’s supply chain indicated potential for exposure to modern slavery and human trafficking through: (i) purchase of office consumables such as tea, coffee, sugar, cocoa and biscuits for our kitchens; (ii) cleaning services employed by building owners or facilities managers for buildings occupied by NAB; (iii) purchase of corporate clothing; and (iv) print and promotional goods and services. Actions undertaken within the 2016 financial year to minimise these risks include:
- updating the Group Procurement and Group Outsourcing & Offshoring Policies to explicitly incorporate reference to the MSA.
- continuing to purchase Roundtable for Sustainable Palm Oil biscuits and Fairtrade certified tea, coffee, sugar and cocoa (the NAB Group is one of the largest Fairtrade endorsed workplaces in Australia and New Zealand).
- joining the Cleaning Accountability Framework (CAF)2 Advisory Committee in Australia. This year, NAB and its property services partner in Australia have strengthened cleaning tender and contract requirements relating to fair pay, sham contracting, reasonable working hours and the treatment of subcontractors (among others).
- enhancing supply chain ESG risk assessment processes for relevant suppliers that operate in sectors included in NAB’s ‘High Risk ESG sectors and sensitive areas list’.
In the 2016 financial year, NAB did not identify any instances of modern slavery or human trafficking associated directly with its operations. In risk assessments undertaken to date in relation to NAB’s supply chain, no cases of modern slavery or human trafficking were identified.
As a financial institution, NAB also recognises that modern slavery and human trafficking is a potential risk in relation to financing activities. NAB’s ESG Credit Risk policies and processes incorporate a risk-based approach to assess human rights risk (incorporating modern slavery and human trafficking) as part of credit risk assessment and due diligence (which includes use of the ‘High Risk ESG sectors and sensitive areas list’ to determine customers that may have a higher risk of ESG issues).
Training and communications
NAB is in the process of reviewing its training to determine the extent of the information that is available to employees on modern slavery and how to report instances of modern slavery. NAB is also considering incorporating information on modern slavery and human trafficking in the communication supporting the roll-out of its new Human Rights Policy.