Modern Slavery Statement

Introduction and Commitment

We are committed to conducting our business with integrity and respect for human rights, including taking proactive steps to identify, assess, and address modern slavery risks in our operations and supply chains. Modern slavery encompasses serious forms of exploitation including human trafficking, slavery, servitude, forced labor, debt bondage, forced marriage, and the worst forms of child labor [1].

As a retail solar installation company operating in New South Wales, we recognise that modern slavery can occur in various forms throughout global supply chains, including in the manufacturing of solar panels, electrical components, and other materials used in our installations. We are committed to playing our part in the global effort to eliminate modern slavery and to ensuring that our business operations and supply chains are free from modern slavery practices [2].

This Modern Slavery Statement demonstrates our commitment to transparency and accountability in addressing modern slavery risks. While our organization may not currently meet the mandatory reporting thresholds under the Modern Slavery Act 2018 (Commonwealth), we have chosen to prepare this statement voluntarily as part of our commitment to responsible business practices and continuous improvement in our approach to modern slavery prevention [3].

Our commitment to combating modern slavery is aligned with our core values of integrity, respect, and social responsibility. We believe that all workers in our operations and supply chains should be treated with dignity and respect, work in safe conditions, be fairly compensated, and have their fundamental human rights protected. This commitment extends to our direct employees, contractors, suppliers, and all other parties involved in our business operations [4].

We recognize that addressing modern slavery requires ongoing vigilance, continuous improvement, and collaboration with suppliers, industry partners, and other stakeholders. This statement outlines the steps we have taken during the reporting period to assess and address modern slavery risks, and our plans for strengthening our approach in future periods [5].

About This Statement

This Modern Slavery Statement is prepared in accordance with the Modern Slavery Act 2018 (Commonwealth) and covers the reporting period from [start date] to [end date]. The statement describes the structure of our organization, our operations and supply chains, the modern slavery risks we have identified, and the actions we have taken to assess and address these risks [6].

The Modern Slavery Act requires certain entities to report annually on their actions to assess and address modern slavery risks in their operations and supply chains. The Act defines modern slavery as including eight types of serious exploitation: trafficking in persons, slavery, servitude, forced marriage, forced labor, debt bondage, deceptive recruiting for labor or services, and the worst forms of child labor [7].

This statement has been prepared following the guidance provided by the Australian Government and incorporates the mandatory criteria specified in the Modern Slavery Act. These criteria include describing our structure, operations and supply chains; identifying modern slavery risks; outlining actions taken to assess and address risks; describing how we assess the effectiveness of our actions; and detailing our consultation processes [8].

We have adopted a risk-based approach to modern slavery, focusing our efforts on areas where the risks are highest and where we can have the greatest impact. This approach recognizes that modern slavery risks vary across different industries, geographic regions, and types of business relationships, and that effective responses must be tailored to specific risk contexts [9].

Our statement is reviewed and approved by our senior management and is published on our website to ensure transparency and accessibility. We welcome feedback on our modern slavery efforts and are committed to continuous improvement in our approach to preventing and addressing modern slavery risks [10].

Our Structure, Operations and Supply Chains

Our organization operates as a retail solar installation company registered in New South Wales, Australia, specializing in the design, supply, and installation of solar photovoltaic systems for residential and commercial customers. We employ approximately [number] staff across various functions including sales, design, project management, installation, and customer service [11].

Our business structure includes direct employees who are responsible for customer consultation, system design, project management, and administrative functions, as well as a network of licensed electrical contractors and installation technicians who perform the physical installation work. We maintain partnerships with equipment suppliers, financing providers, and other service providers to deliver comprehensive solar solutions to our customers [12].

Our operations encompass the entire customer journey from initial consultation through to system commissioning and ongoing maintenance. This includes conducting site assessments, designing customized solar systems, obtaining necessary permits and approvals, procuring equipment and materials, coordinating installation activities, and providing post-installation support and maintenance services [13].

Our supply chain includes multiple tiers of suppliers and service providers. Tier 1 suppliers include solar panel manufacturers, inverter suppliers, mounting system providers, electrical component suppliers, and installation contractors. Tier 2 suppliers include raw material providers, component manufacturers, and logistics providers who support our Tier 1 suppliers. We also engage various service providers including professional services, technology providers, and administrative support services [14].

The solar industry supply chain is global in nature, with solar panels and components manufactured in various countries including China, Germany, South Korea, and other locations. This global supply chain presents both opportunities and challenges in terms of modern slavery risk management, as it involves multiple jurisdictions with different labor standards and regulatory frameworks [15].

Our procurement processes involve selecting suppliers based on factors including product quality, technical specifications, pricing, delivery capabilities, and increasingly, environmental and social responsibility considerations. We maintain supplier relationships through regular communication, performance monitoring, and collaborative improvement initiatives [16].

We recognize that our supply chain complexity and global nature require systematic approaches to modern slavery risk assessment and management. This includes understanding the geographic and industry contexts in which our suppliers operate, the labor practices in their operations, and the potential for modern slavery risks at different tiers of our supply chain [17].

Modern Slavery Risks in Our Operations and Supply Chains

Through our risk assessment processes, we have identified several areas where modern slavery risks may exist in our operations and supply chains. These risks vary in terms of their likelihood, potential impact, and our ability to detect and address them effectively [18].

Manufacturing and Production Risks represent the most significant modern slavery risks in our supply chain, particularly in the manufacturing of solar panels, inverters, and other electrical components. The solar panel manufacturing industry has been associated with forced labor risks, particularly in certain geographic regions where labor standards may be inadequate and monitoring systems may be limited [19].

Solar panel manufacturing involves multiple stages including silicon purification, wafer production, cell manufacturing, and module assembly, each of which may involve different suppliers and subcontractors. The complexity of these manufacturing processes and the pressure to reduce costs can create conditions where modern slavery risks may emerge, particularly in lower-tier suppliers where visibility and oversight may be limited [20].

The extraction and processing of raw materials used in solar panels, including silicon, silver, aluminum, and rare earth elements, may involve modern slavery risks in mining operations, particularly in regions with weak governance structures and limited labor protections. These risks may be several tiers removed from our direct supplier relationships, making them challenging to identify and address [21].

Installation and Construction Risks may exist in our installation operations, particularly where we engage subcontractors or temporary workers for installation activities. The construction industry has historically been associated with modern slavery risks including exploitation of migrant workers, debt bondage, and unsafe working conditions [22].

Installation work often involves physical demands, working at heights, and exposure to electrical hazards, which may create conditions where vulnerable workers could be exploited. We recognize the importance of ensuring that all workers involved in our installation activities are properly trained, fairly compensated, and working in safe conditions [23].

Geographic Risk Factors influence the likelihood of modern slavery risks in our supply chain, with higher risks typically associated with countries that have weak governance structures, limited labor protections, high levels of poverty and inequality, and inadequate enforcement of labor laws. Our supply chain includes suppliers from various geographic regions with different risk profiles [24].

Regions with higher modern slavery risks may include areas with significant manufacturing activity but limited labor protections, countries experiencing conflict or political instability, and locations with large populations of migrant workers who may be vulnerable to exploitation [25].

Industry and Sector Risks are relevant to our business given that the renewable energy sector, while generally committed to sustainability principles, may still face modern slavery risks in manufacturing, construction, and raw material extraction activities. The rapid growth of the solar industry and pressure to reduce costs may create conditions where modern slavery risks could emerge [26].

Vulnerable Worker Populations may be at higher risk of modern slavery, including migrant workers, temporary workers, workers in informal employment arrangements, and workers with limited education or language skills. We recognize the importance of ensuring that our employment practices and those of our suppliers provide appropriate protections for all workers, particularly those who may be more vulnerable to exploitation [27].

Business Model and Procurement Risks may arise from certain business practices including excessive cost pressure on suppliers, short-term contracts that may incentivize cost-cutting, complex subcontracting arrangements that reduce visibility, and inadequate due diligence processes that fail to identify modern slavery risks [28].

Actions Taken to Assess and Address Modern Slavery Risks

We have implemented a comprehensive approach to assessing and addressing modern slavery risks in our operations and supply chains, recognizing that this is an ongoing process that requires continuous improvement and adaptation [29].

Risk Assessment and Due Diligence processes have been established to systematically identify and evaluate modern slavery risks across our operations and supply chains. This includes conducting risk assessments of our suppliers based on geographic, industry, and business model risk factors, as well as ongoing monitoring of risk indicators and emerging issues [30].

Our due diligence processes include reviewing supplier information, conducting site visits where appropriate, engaging with suppliers on labor practices and human rights issues, and requiring suppliers to provide information about their own supply chains and risk management practices. We have developed risk assessment tools and questionnaires to support these processes [31].

Supplier Engagement and Capacity Building initiatives involve working collaboratively with our suppliers to build awareness of modern slavery risks, develop capacity for risk management, and implement effective prevention and remediation measures. This includes providing training and resources to suppliers, sharing best practices, and supporting suppliers in developing their own modern slavery prevention programs [32].

We have established communication channels with our key suppliers to discuss modern slavery issues, share information about risks and mitigation strategies, and collaborate on improvement initiatives. This engagement recognizes that effective modern slavery prevention requires partnership and shared responsibility across the supply chain [33].

Policy Development and Implementation has involved developing and implementing policies and procedures that address modern slavery risks in our operations and supply chains. This includes updating our supplier code of conduct to include specific requirements related to modern slavery prevention, developing procurement policies that incorporate human rights considerations, and establishing grievance mechanisms for reporting concerns [34].

Our policies are communicated to all relevant staff and suppliers, and we provide training and support to ensure effective implementation. We regularly review and update our policies to reflect evolving best practices and regulatory requirements [35].

Training and Awareness Programs have been implemented to build awareness of modern slavery issues among our staff, suppliers, and other stakeholders. This includes providing training on modern slavery risks, indicators, and response procedures, as well as raising awareness of our policies and expectations [36].

Training programs are tailored to different audiences and roles, with specialized training provided to staff involved in procurement, supplier management, and risk assessment activities. We also provide resources and support to help suppliers develop their own training programs [37].

Monitoring and Audit Processes have been established to monitor compliance with our modern slavery requirements and to identify potential issues or areas for improvement. This includes conducting supplier audits, reviewing supplier performance data, and investigating any concerns or allegations that may arise [38].

Our monitoring processes are risk-based, with more intensive monitoring applied to higher-risk suppliers and operations. We use a combination of self-assessment, third-party audits, and direct engagement to monitor supplier performance and compliance [39].

Grievance and Remediation Mechanisms have been established to provide channels for reporting modern slavery concerns and to ensure that any issues identified are addressed promptly and effectively. This includes establishing confidential reporting mechanisms, developing investigation procedures, and implementing remediation processes [40].

We are committed to ensuring that any instances of modern slavery identified in our operations or supply chains are addressed through appropriate remediation measures, including supporting affected workers, addressing root causes, and implementing preventive measures to prevent recurrence [41].

Assessing the Effectiveness of Our Actions

We recognize the importance of regularly assessing the effectiveness of our modern slavery prevention efforts to ensure that our actions are achieving their intended outcomes and to identify opportunities for improvement [42].

Key Performance Indicators have been established to measure the effectiveness of our modern slavery prevention efforts. These indicators include metrics related to supplier compliance, training completion rates, grievance mechanism usage, audit findings, and remediation activities. We regularly review these indicators to assess our progress and identify areas requiring attention [43].

Supplier Assessment and Feedback processes involve regularly evaluating supplier performance in relation to modern slavery prevention, including reviewing compliance with our requirements, assessing the effectiveness of supplier risk management systems, and gathering feedback on our support and engagement activities [44].

We conduct regular supplier reviews that include assessment of modern slavery prevention efforts, and we use this information to identify high-performing suppliers as well as those requiring additional support or intervention. This assessment process helps us understand the effectiveness of our supplier engagement strategies [45].

Internal Review and Evaluation processes involve regularly reviewing our own modern slavery prevention systems and processes to assess their effectiveness and identify opportunities for improvement. This includes evaluating the adequacy of our risk assessment processes, the effectiveness of our training programs, and the performance of our monitoring and audit activities [46].

Internal reviews are conducted by senior management and involve consultation with relevant staff and stakeholders. The results of these reviews inform our continuous improvement efforts and help us adapt our approach based on lessons learned and emerging best practices [47].

External Validation and Benchmarking activities involve seeking external perspectives on our modern slavery prevention efforts, including engaging with industry associations, participating in collaborative initiatives, and benchmarking our performance against industry standards and best practices [48].

We participate in industry forums and collaborative initiatives focused on modern slavery prevention, which provide opportunities to learn from other organizations, share experiences, and contribute to collective efforts to address modern slavery risks in the solar industry [49].

Continuous Improvement Processes ensure that lessons learned from our effectiveness assessments are incorporated into our modern slavery prevention efforts. This includes updating policies and procedures based on assessment findings, enhancing training programs, improving risk assessment tools, and strengthening supplier engagement strategies [50].

We maintain a continuous improvement mindset that recognizes modern slavery prevention as an ongoing journey rather than a destination, and we are committed to regularly enhancing our approach based on new information, changing circumstances, and evolving best practices [51].

Consultation Process

This Modern Slavery Statement has been developed through a comprehensive consultation process involving relevant stakeholders within our organization and, where appropriate, external parties [52].

Internal Consultation has involved engaging with senior management, operational staff, procurement personnel, and other relevant employees to gather input on modern slavery risks, current practices, and improvement opportunities. This consultation process has helped ensure that our statement accurately reflects our operations and incorporates diverse perspectives on modern slavery prevention [53].

Consultation activities have included workshops, interviews, and review processes that have enabled staff to contribute their knowledge and experience to the development of this statement. We have also sought input from staff involved in supplier management, installation operations, and customer service to ensure comprehensive coverage of our business activities [54].

Supplier Consultation has involved engaging with key suppliers to discuss modern slavery risks, share information about our expectations and requirements, and gather input on effective prevention strategies. This consultation has helped us better understand supply chain risks and develop more effective approaches to supplier engagement [55].

We have conducted supplier surveys, held meetings with key suppliers, and participated in industry forums to gather input on modern slavery issues and to share our commitment to prevention efforts. This consultation has strengthened our supplier relationships and enhanced our collective understanding of supply chain risks [56].

External Stakeholder Engagement has included consultation with industry associations, non-governmental organizations, and other relevant parties to gather input on best practices, emerging issues, and effective approaches to modern slavery prevention in the solar industry [57].

This external engagement has provided valuable insights into industry trends, regulatory developments, and innovative approaches to modern slavery prevention that have informed our strategy development and implementation efforts [58].

Looking Forward

We are committed to continuously strengthening our approach to modern slavery prevention and have identified several priority areas for future development and improvement [59].

Enhanced Supply Chain Mapping will involve developing more detailed understanding of our supply chain, including lower-tier suppliers and subcontractors, to improve our ability to identify and address modern slavery risks. This will include working with suppliers to increase transparency and traceability in their own supply chains [60].

Technology and Innovation opportunities will be explored to enhance our modern slavery prevention efforts, including the use of digital tools for supply chain monitoring, blockchain technology for traceability, and artificial intelligence for risk assessment and monitoring [61].

Industry Collaboration will continue to be a priority, including participation in industry initiatives, sharing of best practices, and collective action to address systemic modern slavery risks in the solar industry supply chain [62].

Capacity Building efforts will be expanded to provide additional support and resources to suppliers, particularly smaller suppliers who may have limited resources for developing comprehensive modern slavery prevention programs [63].

Performance Measurement systems will be enhanced to provide better data on the effectiveness of our modern slavery prevention efforts and to support evidence-based decision making and continuous improvement [64].

Approval and Governance

This Modern Slavery Statement has been reviewed and approved by our senior management team and reflects our organization’s commitment to preventing modern slavery in our operations and supply chains [65].

The statement will be reviewed annually and updated as necessary to reflect changes in our operations, supply chains, risk environment, and prevention efforts. Regular reporting on modern slavery prevention activities will be provided to senior management to ensure ongoing oversight and accountability [66].

Responsibility for modern slavery prevention is integrated into our governance structures and management systems, with clear accountability for implementation and performance. We are committed to ensuring that modern slavery prevention remains a priority across all levels of our organization [67].