Human rights
We are committed to ensuring our business activities respect the rights and dignity of all people.
Our management approach
MinRes seeks to build mutually beneficial relationships and respect the rights of our employees, contractors, members of our local communities and other stakeholders directly impacted by our operations.
We prohibit the use of forced labour which includes child labour, slave labour and human trafficking.
Our Human Rights Policy outlines our commitment and joint responsibility to ensure that our business activities respect the rights and dignity of all people.
We are committed to upholding and respecting human rights principles across our operations and supply chain, including those contained in internationally recognised declarations.
MinRes is a signatory to the United Nations Global Compact, which upholds our commitment to human rights, labour, the environment and anti-corruption across our business strategy, culture and daily operations.
Governance
Our Human Rights Working Group is responsible for matters related specifically to the management and response processes for human rights and modern slavery, including the progression of our targets and Board-approved Modern Slavery Awareness and Response Roadmap.
Day-to-day oversight and coordination of human rights and modern slavery activities are undertaken by our Sustainability, Supply, Sustainable Procurement, Shipping and Legal teams.
These teams work collaboratively to support the MinRes' acquisition of the utilities, goods and services required to operate, with the Sustainable Procurement team responsible for managing supplier due diligence activities.
The Shipping team manages all shipping contracts, arrangements and due diligence processes associated with the export of our products.
Our commitments
We are committed to respecting and upholding human rights principles contained within internationally recognised declarations, including:
United Nations Universal Declaration of Human Rights
International Covenant on Economic, Social and Cultural Rights
International Covenant on Civil and Political Rights
United Nations Declaration on the Rights of Indigenous Peoples
United Nations Guiding Principles on Business and Human Rights
United Nations Global Compact Ten Principles
United Nations Sustainable Development Goals
OECD Guidelines for Multinational Enterprises
International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work.
We recognise that our risk profile is constantly evolving and we are committed to identifying and addressing modern slavery risks within our operations and supply chains.
Our approach to modern slavery is consistent with the United Nations Guiding Principles on Business and Human Rights, which informs how our business practices and reporting entities may cause, contribute to or be directly linked to modern slavery practices across our value chain.
To understand our exposure, we follow a risk-based approach to identify suppliers that may have an elevated risk of adverse human rights impacts, including modern slavery.
This includes two components:
Country risk: we use a combination of the Global Slavery Index, Transparency International Corruption Perceptions Index and the Conflict-Affected and High-Risk Areas List.
Industry risk: using Tier 1 supply chain analysis, we have identified and assessed several high-risk industries such as labour hire and short-term contract workers, construction services and sourcing of safety supplies and garments.
We are governed by Australian Federal and State Government legislation, which promotes fair trading and competition while protecting the environment and the community.
From a labour and industrial relations perspective, the Fair Work Act 2009 and the Fair Work Regulations 2009 govern the employee/employer relationship in Australia.
This legislation prescribes a safety net of minimum entitlements, enabling flexible working arrangements, fairness at work and preventing discrimination against employees.
Key recruitment and labour management processes include, but are not limited to:
- undertaking checks before entering into an employment contract, including requesting a copy of identification documents to confirm age and identity
- providing all workers with a written employment contract with employment terms clearly defined
- paying all workers their legal pay entitlements on time and providing all employees with pay slips that define wage payments and leave entitlements
- providing safe accommodation at our mine-site accommodation villages and at our construction sites that our workers are free to leave at will
- providing access to a confidential mailbox where employees can raise and seek resolution to disputes or grievances.
We follow a risk-based approach to identify suppliers with elevated risks of modern slavery.
All new suppliers are screened via our third-party risk assessment software, which assesses the risk of the supplier across modern slavery indicators and other risk factors such as sanctions and anti-bribery and corruption practices. This assessment returns a risk rating based on defined criteria.
All suppliers that represent a potentially high-risk of modern slavery are required to complete a Self-Assessment Questionnaire (SAQ).
The SAQ process provides us with an opportunity to engage and share good practice measures to support suppliers on effective identification of human rights risks within their supply chains, as well as identification of any potential areas for improvement within their own operations.
Where a ‘red flag’ response to the SAQ has been identified, we will engage with the supplier to clarify their response and obtain further information.
MinRes is committed to engaging and working collaboratively with relevant authorities concerning any allegations of adverse human rights impacts at our operations or along our supply chain. This includes appropriate remediation of any adverse human rights impacts we may have inadvertently caused or contributed towards.
Our Supply Chain – Human Rights Incident Management Procedure aims to provide our business, and particularly those individuals in roles that directly engage and work with our suppliers, with examples of modern slavery indicators. The procedure outlines the strategies available to appropriately investigate any incidents.
We develop remediation plans on a case-by-case basis to ensure an appropriate response from our suppliers, with primary consideration given to safeguarding impacted people.
To support the detection, reporting and prevention of modern slavery within our operations and supply chain, we encourage all stakeholders to raise concerns through the various reporting channels we have available.
Our Whistleblower Policy and Whistleblower Procedure demonstrate our commitment to promoting a culture of ethical and corporate behaviour and outline the processes by which stakeholders can report matters they believe are in breach of our Code of Conduct and Business Integrity.
We provide for a whistleblower to qualify for appropriate protection even if their disclosure turns out to be incorrect or if they make the disclosure anonymously.
We have also an established independent external whistleblowing service, MinRes Integrity Assist, which provides an avenue for stakeholders to raise concerns about suspected or actual misconduct in the workplace, including those related to human rights.
The code serves as a guide on how to operate to the highest standards of ethics and integrity in our business practices, underpinned by our values.
All MinRes employees and contractors receive the code during the onboarding and induction process, while suppliers are expected to comply with the code and are provided access within onboarding processes.
Failing to comply with the code is viewed as a serious matter that may lead to disciplinary action, including dismissal and/or legal action.
If a breach has occurred, the nature of any disciplinary or corrective action will be determined in consultation with appropriate experts. Corrective actions depend on the seriousness of the breach and other relevant circumstances.
Refer to the Code of Conduct and Business Integrity for further information.
This policy underpins our commitment and joint responsibility to ensure that the MinRes' business activities respect the rights and dignity of all people.
All employees, contractors, suppliers and other relevant stakeholders are required to comply with the principles outlined in this policy, which is also referenced in our Supplier Code of Conduct. All suppliers are provided with access to the document.
Breaches of policy can be reported through various channels, including through a supervisor, manager or our confidential independent whistleblowing service.
Refer to the Human Rights Policy for further information.
This policy outlines our commitment to respect human rights and to not contribute to conflict, should we ever source or operate in a conflict-affected and/or high-risk area.
The policy has been developed with consideration of OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
The policy applies to all employees, contractors, consultants, Directors, officers and suppliers for all MinRes entities.
Breaches can be reported through a supervisor, manager or our confidential independent whistleblowing service, MinRes Integrity Assist.
Refer to the Responsible Production Policy for further information.
This procedure outlines the processes and systems used to screen suppliers prior to onboarding and is available to employees through our intranet.
This document specifies our expectations of our suppliers’ conduct with regard to health and safety, labour and human rights, community, environmental, and business integrity issues, and outlines appropriate management, reporting and compliance processes.
Our General Services Agreement requires contractors to comply with our Supplier Code of Conduct as well as any sub-contractors involved in the provision of services under the agreement.
We expect our suppliers' behaviour and practices to extend beyond our Tier 1 suppliers, ensuring their own suppliers and contractors adhere to principles equivalent or greater than ours as addressed in the code.
Refer to the Supplier Code of Conduct for further information.
This procedure outlines the cross-functional, integrated approach to the procurement and management of goods and services.
Embedded into this document are guidelines outlining how to apply the modern slavery risk assessment as part of the due diligence process when onboarding suppliers.
This procedure is available to MinRes employees through our intranet.
This guides the business on the integration of sustainability within procurement and is available to employees through our intranet.
This procedure outlines the way in which we could contribute, or be directly linked, to potential modern slavery risks.
It includes a guide on how potential incidents will be reviewed and investigated including actions that might be deployed with a supplier on a case-by-case basis.
This procedure is available to MinRes employees through our intranet.
This document outlines the steps required for the mandatory screening of any potential international counterparties to manage expectations and supply chain risks.
The procedure is available to key personnel in our Procurement, Legal, Risk and Compliance, Finance and International Trade and Strategy teams.