REPORTING CRITERION 3

When procuring goods and services the table below identifies 4 key risk factors which can indicate an increase of modern slavery in supply chains:

Sector Example of Goods or Service with Potential Risk

Industry Sector CES Ltd and SCECE&C Ltd procures construction and facilities maintenance services, which are known to be high risk for both domestic instances of modern slavery and for the manufacturing of products used in the course of those operations.

Commodity or Product Specific products and commodities are deemed high risk by the US Department of Labor’s 2018 List of Goods Produced by Child and Forced Labor, the Global Slavery Index (GSI) and other international guidance materials.

Example of Labour Rights Risk

Forced labour in the production of building and construction materials

Geographic Location The risk based on geographic location is based on the estimated prevalence of modern slavery and the government responses as outlined in the 2018 GSI. CES Ltd and SCECEC&C Ltd predominantly engages Australian suppliers, it is recognised that goods and associated services may come from countries other than those of suppliers’ headquarters.

Workforce Profile

In undertaking the supplier analysis, CES Ltd considered the type of labour involved in the production of our goods and services, particularly where low skilled, vulnerable or migrant labour is used, or where the work is deemed as ‘3D’ work (dirty, dull or dangerous).

CES Ltd and SCECEC&C Ltd recognises, for example, that electronic equipment contains metals and minerals that may be sourced from regions known to be at high risk of modern slavery practices.

For example, that electronic goods from Malaysia would be considered to be at high risk of modern slavery.

Cleaning services, may use vulnerable or migrant labour which the work is deemed as ‘3D’ work (dirty, dull, or dangerous).

Exploitation of such employment conditions, below award wages or docking of wages.

CES Ltd has identified the following risk factors and will implement a process to engage with high spend suppliers and invite them to join Sedex and Vendor Panel. In doing so, Service Providers, Contractors and Suppliers will be able to complete a comprehensive self-assessment questionnaire (SAQ). SCS will have access to results of the SAQ and any corresponding red flags factors that may contribute to modern slavery practices. Currently CES Ltd has a decentralised data system and collation of this data is under development. Clear understanding of risks in our operations will be developed further throughout 2022 and onwards.

There is further risk associated with the uncontrolled expenditure in Staff Reimbursements. While there is an approval process in place for these expenses, there is no overall visibility for these costs and is considered a High Risk procurement activity. Review of this process may be required in future by CES Ltd.