REPORTING CRITERION 3

• Feedback mechanisms: CES Ltd are working towards establishing clear feedback mechanisms that employees and workers can use to raise concerns or complaints about any issues they may face at work.

In addition to these measures, the organisation is working towards having the appropriate resources to regularly review and monitor our operations to identify and address any potential risks of modern slavery. Our aim is to work closely with our suppliers and partners to ensure that they are adhering to ethical standards and that they are taking appropriate measures to manage any modern slavery risks within their own operations.

CES Ltd, believe that our people are our greatest asset, and are committed to treating them with the respect and dignity they deserve. By taking proactive steps to mitigate the risk of modern slavery within our operations, CES Ltd are not only fulfilling our responsibilities as a responsible organisation, but are also contributing to a fairer and more just society.

Through the ACAN Program, CES Ltd and SCECE&C Ltd continue to focus activities with suppliers of labour and the operational risk associated with the following labour supply chains:

Cleaning and security services

The cleaning and security sectors typically employ temporary migrant workers engaged via subcontracting arrangements with a high rate of noncompliance with workplace rights and entitlements. Equipment and consumables used in these sectors are largely manufactured overseas, predominantly in high risk countries such as China and Vietnam.

Facility management and property maintenance

The labour force used in facilities management generally consists of temporary migrant workers Often contracted through labour hire companies.

Labour Hire

Labour hire services pose a high risk for worker exploitation and modern slavery for several reasons, including:

• focus on low-skilled, low-paid, seasonal, temporary labour

• recruitment of potentially vulnerable people such as new migrants, temporary work visa holders, international students and undocumented workers

• deceptive and opaque practices trapping workers into exploitative situations

• demanding excessive fees for visas, travel and other work arrangements, leading to debt bondage

• coercive control, threats, withholding workers’ identity documents to limit their freedom ofmovement and social isolation from community. Waste management services

The waste industry (including recycling) is a dangerous sector for workers with significant WHS risk such as exposure to toxic materials and pathogens, use of heavy machinery and dirty work environment. Modern slavery risks are similar to those faced by cleaners. Sub-contracting to small waste management companies is common across the sector as is the use of labour hire. Migrants and low-skilled workers are used in waste collection, handling and material recovery facilities.

Modern Slavery gap analysis

Last year, CES Ltd conducted a gap analysis to identify areas where CES Ltd could improve practices and procedures to prevent and mitigate the risk of modern slavery. However, this year’s gap analysis showed that CES Ltd has not progressed in some areas. This was due to a number of factors, including changes in our governance and management structures.

One of the major changes was the appointment of a Chief Executive of Strategy, Risk and Governance, who brought a new perspective and approach to managing risk and compliance. This change led to a restructuring of our governance and management areas, which impacted how CES Ltd approached our modern slavery practices and procedures.

Additionally, CES Ltd appointed a Compliance and Risk Advisor who provided further expertise and support in identifying and mitigating risks, including modern slavery. While these changes were positive for the organisation, they also resulted in a temporary disruption to our systems and processes. Another change was the relocation of modern slavery responsibilities from the People and Culture and Operations team to the Strategy, Risk and Governance (Compliance and Risk) and the Operations (Procurement) team. This change required a significant effort to transfer knowledge and ensure that the new team had a full understanding of modern slavery risks and the steps required to mitigate them.