2 minute read
REPORTING CRITERION 3
As you can see, there are some clear differences between the key findings from the two gap analyses. What was improved, what didn’t change, and what went backwards.
CES Ltd had:
Advertisement
• 9 - Focus Areas of Improvement ( )
• 13 - Focus Areas of no change (-)
• 0 - Focus Areas of going backwards ( )
Category
Management Systems Business Systems
Focused Areas of Improvement in 2022
CES Ltd subscribe to platforms such as SEDEX to identify risk, but beyond risk identification systems in place are still basic (e.g. an excel spreadsheet, a log on a share drive or the like), and there is no particular process for capturing incidents, assigning priorities or grading severity of incidents, and it does not capture progress.
Monitoring and Reporting
Risk Management Operational Risk
The governance framework guides appropriate actions, but the application is still somewhat ad-hoc. Monitoring and reporting happens when there is an incident in an ad-hoc fashion.
Processes are in place to check compliance with award wages and legislative requirements. Identifying External Risks Processes exist to identify external risk of modern slavery but it is not consistently applied.
HR and Recruitment Policies and Systems
Training
Labour Hire / Outsourcing
A policy is in place, but systems are in a state of development.
The Strategy, Risk and Governance Team have initiated the development of training for staff.
A policy is in place but the process is still not fully developed. Cases are responded to as they arise.
Customers and Stakeholders
Procurement and Supply Chain
Information Provision Broader engagement with stakeholders who share common values and goals.
Monitoring and Corrective Actions
Regular review of supplier documentation, and based on risk profile, some audits of selected suppliers are carried out. Regular monitoring is an area for improvement.
These results are based on the answers that were provided, i.e. it is a subjective self-assessment.
Based on these findings, a set of recommendations have been developed to address the gaps and ensure that our modern slavery practices and procedures are effective and robust. These recommendations include:
• Improving the communication of the modern slavery policy to all employees, to ensure that they are aware of their responsibilities and the steps required to prevent and mitigate modern slavery risks.
• Ensuring that due diligence processes are developed and consistently applied across all suppliers, to identify and manage any modern slavery risks within our supply chains.
• Implementing, reviewing and updating our training and awareness programs to ensure that they are effectively reaching all CES Ltd employees, and addressing any identified gaps in coverage.
• Identifying the gaps within teams and expanding those areas with the appropriate resources.
By implementing these recommendations, CES Ltd believes that it can effectively address the gaps identified in our gap analysis and further strengthen our modern slavery practices and procedures. CES Ltd is committed to regularly reviewing and updating these practices to ensure that they are continually improving and maintaining our commitment to responsible business practices.
