Modern Slavery Statement

1 July 2022 – 30 June 2023

Overview of New Horizons’ Modern Slavery Tracking.

The Modern Slavery Act 2018 (Cth) requires organisations with consolidated annual revenue of more than $100 million to submit an annual statement (Modern Slavery Statement) describing their actions to identify, assess and address modern slavery risks within their operations and supply chain. New Horizons Limited ACN 002 066 604 (NH) recorded an annual revenue of more than $100 million during the financial year ended 30 June 2023 (Reporting Period).

NH continues to be committed to upholding human rights and acting with integrity for our people and the wider community. This includes our commitment to take action to address the risks of modern slavery within our operations and supply chain and to partner with suppliers who share our values. Dealing with modern slavery is about actively doing what we can do to protect people’s rights and safety.

While our direct impact in relation to modern slavery practices during the Reporting Period remained low, we continue to develop our modern slavery response guided by the principles set out in the United Nations Principles on Business and Human Rights.

This is our third Modern Slavery Statement (MSS) which ties in with our primary focus, being heartfelt alignment to our values, purpose, and beliefs. We are committed to upholding human rights and acting ethically and with integrity for everyone.

Geographic risk level: Low

We consider the geographic risk of our suppliers to be low given 99% of our direct suppliers are based in Australia. Most of our direct overseas suppliers are based in countries that have a strong rule of law and mechanisms that protect human rights and have themselves implemented modern slavery strategies.

We acknowledge NH may be linked to modern slavery practices through its second and third-tier suppliers that operate in, or procure goods and services from, nations that report high occurrences of labour and human rights violations and socioeconomic factors like poverty and widespread discrimination.

Sector and industry risk level: Low

The sectors we deal with primarily involve the charity and not-for-profits, health care, housing and property sectors. These sectors are heavily regulated in Australia and generally allow for reasonable visibility over lower-tier suppliers.

We appreciate we may be linked to modern slavery practices further down our supply chain where some of our suppliers operate in, or are connected, to industries that involve low-paying, low skilled or hazardous work, such as extractive operations, electrical component assembly or cleaning industries or are located in geographical areas that may have a higher risk of modern slavery. However, to minimise this risk, suppliers responding to tenders or who are otherwise subject to our terms and conditions are required to demonstrate or confirm they have little or no modern slavery risks in their operations.

Product and services risk: Low

NH procures services such as cleaning, electrical, information technology and general maintenance. The workers in these supply chains may be from vulnerable populations, including workers from migrant, low socioeconomic or culturally and linguistically diverse backgrounds.

While we consider the modern slavery risk associated with these products and services to be low in our case, the above factors elevate the risk of modern slavery practices.

Supply chain model risks: Low

We have again assessed our supply chain model risks as low based on available information. We have a large and complex supply chain, with over 1000 suppliers during the Reporting Period.

We acknowledge the size of our supply chain makes it difficult to identify and monitor modern slavery practices further down our supply chain. This lack of full transparency creates a risk that NH may be linked to modern slavery, however, we have sought to minimise this risk by implementing due diligence processes for our suppliers, including issuing supplier questionnaires regarding their modern slavery risk and approach to modern slavery.

As our business grows, we continue to assess our modern slavery risks and ensure our policies, procedures and controls remain valid and effective to mitigate any identified, new or increased risks we discover.

To read the New Horizons Modern Slavery statement in full, please click on the link below