REPORTING CRITERION 4

Actions taken to assess and address risks

CES Ltd has completed a number of actions to address modern slavery and risks it imposes. The following actions have taken place in 2022 or continued from 2021:

• Strategy, Risk and Governance Team was established as part of the organisational restructure in 2022

• Continued partnership with the Australian Anti-Slavery Catholic Network (ACAN)

• The continued appointment of two Modern Slavery Liaison Officers (MSLO), from the Strategy Risk & Governance and Procurement & Contracts departments who lead the operational activities to identify and mitigate modern slavery risks within the organisation. The MSLOs works closely with the Executive Leadership team to collaboratively work together for the organisation approach to modern slavery. The MSLOs participate in the ACAN monthly webinars and engage with ACAN expertise on a needs basis to assist in actions to address risk of modern slavery and keep informed of new initiatives and the risk management program activities.

• CES Ltd Modern Slavery Policy - CES Ltd implanted a Modern Slavery Policy in 2021. This Policy provides a robust framework to ensure compliance with the reporting requirements of the Act, whilst also providing guidance for staff not to knowingly use or contribute to modern slavery practices.

• The development of contractual clauses for standard contracts. CES Ltd will access ACAN guidance for comprehensive clauses for high-risk contracts.

• Completed a Modern Slavery risk assessment Operations and Supply Chain.

• Completed Modern Slavery awareness training through ACAN - The two MSLO have completed modern slavery training-learning modules and are developing a training session for all of the organisation. E-learning modules cover;

» ACAN- Modern Slavery 101

» ACAN- Business Relevance

» ACAN- Implementing a Modern Slavery Risk Management Program

• Recognizing the Feast Day of St Bakhita on the 8th February concerning the plight of the victims of modern slavery.

• CES Ltd Social Justice Reference Group initiatives / website