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Specialist in Asia Pacific, Japan, China, India and South East Asia and Global Emerging Market equities.

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Stewart Investors manage investment portfolios on behalf of our clients over the long term and have held shares in some companies for over 20 years. They launched their first investment strategy in 1988.

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Human rights and modern slavery

Human rights and modern slavery

Responsible investment report

In September 2022, the 2021 Global Estimates of Modern Slavery reported that there are an estimated 49.6 million people globally living in situations of modern slavery, an increase of around 10 million people since the previous estimates were released in 20171.

This means one in every 150 people are affected by modern slavery, with women, children and migrants disproportionately impacted1. As these estimates are based on 2021 data, this number does not account for the number of people impacted by the escalation of the Russia-Ukraine conflict.

There is an ever-greater need to focus on this topic, in light of the COVID-19 pandemic, the Russia-Ukraine conflict, the growing recognition of the human rights implications of climate change, and the need for a just and equitable transition to a lower-carbon future. These forces will all have long-lasting and far-reaching human rights implications.

Companies that fail to proactively manage these issues will face an increasing level of scrutiny, in addition to legal, reputational, and financial implications.

What is First Sentier Investors doing? 

Human rights issues are still widely misunderstood by many stakeholders, including investors. FSI first started formal work on human rights in 2016, setting up a human rights working group of investment team members, which culminated in the creation of a Human Rights Toolkit.

In 2022, we updated the Human Rights Toolkit to provide additional guidance on the human rights implications of armed conflict and arranged for human rights experts from advisory firm Pillar Two, to provide our investment teams with training on this topic. 

We have since engaged with several companies on the issue (see the feature below), as well as with clients. In addition, we lead a sub-group within the Responsible Investment Association of Australasia (RIAA) Human Rights Working Group, focused on developing investor guidance on the implications of armed conflict for investors. Proactive human rights due diligence by companies prior to an armed conflict breaking out is our preferred approach. However, for companies that find themselves potentially causing, contributing or directly linked to human rights abuses as the result of an armed conflict, heightened human rights due diligence provides a framework for navigating the situation, in addition to ensuring the company complies with international humanitarian law.

Throughout the year, we also continued our work on modern slavery. The three-year review of the Modern Slavery Act in Australia provided an opportunity to reflect on what was working under the legislation and how all stakeholders can do better to address this issue.

We feel that investors have an important role to play in this review process, and contributed to submissions and consultations on behalf of, or as part of, FSI, Investors Against Slavery and Trafficking APAC (IAST APAC), RIAA and the Financial Services Council.

IAST APAC reached an important milestone in 2022, completing its first full year of collaborative engagements (see feature below).

We did some preliminary analysis on other issues including mental health and access to nutrition, which we intend to do further work on in the coming year.

Investment team progress

Investment teams have been engaging with a range of companies on human rights and modern slavery, with details shown below.

Australian Equities Growth

The Australian Equities Growth team discussed modern slavery risks with 20 ASX-listed companies in 2022. While it continued to focus on retailers, the team broadened its focus to other sectors including IT and healthcare. For companies with broad product ranges and third party manufacturers, it encouraged industry collaboration to maximise leverage with manufacturers. After researching the risk of worker exploitation in the Australian horticultural supply chain several years ago, the team continued to encourage the supermarkets to participate in industry-wide collaborations to educate growers and workers on appropriate pay and conditions.

Australian Small and Mid Cap Companies

The Australian Small and Mid Cap Companies team has engaged with all relevant companies on working conditions, employee welfare and accommodation, both from companies’ own manufacturing facilities and outsourced offshore manufacturing operations. The team has also engaged with relevant companies on their shipping activities, which is an industry that can have opaque practices which may mask modern slavery risk.

Multi-Asset Solutions

The Multi-Asset Solutions team has partnered with Sustainalytics for its modern slavery thematic engagement service. Sustainalytics is now two years into a three-year engagement programme, which by the end of the year had increased to 16 companies, from 12 in 2021. These companies are equally split across the apparel and construction sectors. Of these companies, nine have improved their scores through either adopting policies on responsible recruitment, commencing supplier audits and by seeking feedback from Sustainalytics on human rights programmes.

Fixed Income, Short Term Investments and Global Credit

The Fixed Income, Short Term Investments and Global Credit team continued its engagement with companies on the topic of human rights and modern slavery, with 24 engagements completed over the year. On the issue of the Russia-Ukraine conflict, the team engaged with four companies that have continued operations in Russia and/or Ukraine and will continue to do so in 2023.

Global Listed Infrastructure

The Global Listed Infrastructure team has assessed where the greatest modern slavery risks lie across its research universe. Companies were ranked according to the vulnerability index of countries they operate in, with the highest risks seen in companies with operations in Africa, Latin America and parts of the Asia Pacific region. The team is also focused on companies involved in the build-out of renewables, as elevated modern slavery risks have also been associated with the production of solar panels and wind turbines. It has engaged with a number of companies in its portfolio on these issues over the past year.

Realindex

The Realindex team continued its engagement work regarding modern slavery. Besides being involved in the collaborative engagement with IAST APAC and engagement on the Russian/Ukraine conflict, Realindex has raised issues of modern slavery with a number of companies it has engaged with globally. This questions the company’s supply chain management including beyond tier one suppliers, as well as discussing policies and any remediation conducted for modern slavery issues identified.

First Sentier Investors’ submission to Modern Slavery Act review

In 2022, the Australian Federal Government undertook a review of Australia’s Modern Slavery Act 2018 (Cth) (Modern Slavery Act). FSI believes that the Modern Slavery Act has been successful in raising business and government awareness of the risks of modern slavery. However, enhancements will be required for businesses to be compelled to identify, report on and, most importantly, address the risks of modern slavery, going forward.

In our submission to the review, we indicated our support for many of the proposed initiatives and made several recommendations, including:

  • Reducing the annual revenue threshold for reporting entities to $50 million (from $100 million), subject to greater resourcing to monitor and review the resulting increase in volume of statements submitted
  • Refining the definition of ‘modern slavery’
  • Harmonising reporting criteria and timelines
  • Establishing an Anti-Slavery Commissioner
  • Retaining the current, broad approach of non-punitive enforcement mechanisms
  • Continuing the Modern Slavery Statements Register
  • Considering introducing mandatory human rights due diligence.
  •  

Reporting on progress

The country map below, taken from our Modern Slavery Portfolio Analytics tool, shows the levels of modern slavery risk across various countries where we invest in listed equities and corporate fixed income.

The size of the bubble relates to our exposure to companies across these asset classes (expressed as percentages in the labels), and the colour of the bubble relates to modern slavery risk (darker green = higher risk). Modern slavery risk is measured per country using a combination of factors including the total number of people living in modern slavery conditions, the number of victims as a percentage of population and the country’s vulnerability score as measured by the Global Slavery index. As the map demonstrates, our greatest risks are concentrated in Asia, hence why we decided to focus on this region as part of the IAST APAC initiative profiled above.

Figure 7. Our global modern slavery risk for listed equities and corporate fixed income

Map of global modern slavery risk

Source: Global Slavery Index 2018, First Sentier Investors Data as at 31/12/22

According to the 2021 Global Estimates of Modern Slavery, one in every 150 people are affected by modern slavery. Women, children and migrants are disproportionately impacted.

Challenges

Despite the efforts of many, the number of estimated victims of modern slavery worldwide continues to rise. While the numbers quoted in the Global Estimates of Modern Slavery are concerning, it has made a number of recommendations to action between now and the 2030 target date for eradicating modern slavery.

As responsible investors, we have an obligation to set expectations that investee companies find, fix and prevent modern slavery within their operations and supply chains, as well as engage with policy makers and broader stakeholders including survivors, civil society organisations and ESG data providers.

Future plans

After we complete our fourth consecutive modern slavery statement in 2023, we will review the effectiveness of our approach and refine it as appropriate.

We will also continue the engagement with companies in relation to the human rights implications of the Russia-Ukraine conflict and other armed conflicts globally. We also hope to build on the preliminary analysis already completed on the topics of mental health and access to nutrition.  

Resources

First Sentier Investors has developed a Human Rights Toolkit to help all investment teams globally better manage human rights risks in our portfolios. The toolkit provides research and guidance for each of the following steps:

  • Identifying companies with a risk of human rights in their operations or supply chains
  • Assessing companies’ approach to the issues identified
  • Engaging with the companies identified as at risk of human rights violations
  • Internal reporting on our progress

This has formed the basis of our approach to addressing human rights risks within our investment portfolios, which we are required to report on in accordance with legislation in Australia.

Download our latest Modern Slavery Statement.

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