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Specialists in equity portfolios in Asia Pacific, emerging markets, global and sustainable investment strategies

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Human rights and modern slavery

Human rights and modern slavery

Why is it important to us?

Modern slavery is a crime that is present in every country in the world, with around 50 million people estimated to be living in situations of modern slavery globally1. This is an increase of 10 million people since the previous estimates in Walk Free’s Global Estimates of Modern Slavery 2018. Women, children and migrant workers are disproportionately impacted and approximately 60% of victims are estimated to be in the Asia-Pacific region.

This situation is exacerbated by forces such as climate change and nature loss, as their adverse impacts push people to migrate and expose vulnerable populations to modern slavery.

Beyond modern slavery, human rights are at risk of violation all over the world, particularly in areas of armed conflict. The escalation of the Israel-Palestine conflict in the latter half of 2023, as well as the ongoing conflict in Ukraine, have highlighted the adverse impacts that armed conflict has on the rights of vulnerable civilian populations. At any given time, there are more than 100 armed conflicts going in the world2, putting both civilians and soldiers at grave risk of human rights abuses.

Investors have a role to play in identifying and managing human rights risks within our portfolios, as companies that fail to proactively manage these risks can face legal, reputational and financial consequences. We can contribute positively by articulating our expectations of the companies we invest in, as they relate to human rights, and holding them accountable for meeting these expectations. We can also make efforts to map the human rights and modern slavery risks related to our portfolios, so we can manage them more proactively.

What is First Sentier Investors doing? 

Members of the Responsible Investment team led the development of the Responsible Investment Association of Australasia’s (RIAA) Investor Toolkit on Human Rights and Armed Conflict, which was launched in May 2023. This is part of a broader piece of work to better understand our exposure to Conflict-Affected and High-Risk Areas (CAHRA), and what it means for our human rights risks.

A key part of the ESG Data Strategy was the development of an interactive Modern Slavery Dashboard, based on data provided by Walk Free’s Global Slavery Index (GSI) 2023. Walk Free also presented to investment teams to help them understand the scope of data in the GSI, and how it could be used in investment processes.

The dashboard is designed to provide investment teams with a high-level mapping of modern slavery risk by country and by industry, as well as information regarding where at-risk products are being imported from. The investment and RI teams also worked closely with the firm’s Corporate Sustainability team and other teams across the firm to produce our Modern Slavery Statement 2023, which provides further details on our work in this area.

The UN Global Compact (UNGC) is a voluntary initiative that calls for companies to meet minimum fundamental responsibilities in the areas of human rights, labour, the environment and anti-corruption. In 2023, we worked with a number of investment teams to identify if any companies in their portfolios were flagged for non-compliance with UNGC and how to address this. In general, the proportion of companies rated as ‘watchlist’ or ‘non-compliant’ with the ten principles of the UNGC – as assessed by Sustainalytics – is low across the portfolios, and stable over the course of 2023. The funds managed by several teams had no investments in companies assessed as non-compliant. The funds managed by investment teams which had some level of investment in companies assessed as non-compliant, may continue to hold the company because they are aware of the situation and monitoring or engaging with the company on the issue, or they disagreed with Sustainalytics’ assessment.

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

Australian Equities Growth completed a research project on free, prior and informed consent (FPIC) in a traditional owner context and its application in Australia, and used this work to inform its conversations with mining and energy companies on their approach to FPIC. The team also progressed its ongoing engagement with electronics retailer JB Hi-Fi as part of the Investors Against Slavery and Trafficking (IAST APAC) initiative.

Australian Small and Mid Cap Companies

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

Short Term Investments

The Short Term Investments team continued its engagement with companies on the topic of human rights and modern slavery. Major domestic banks have already been familiar with modern slavery risks, having operations in the UK, which introduced Modern Slavery legislation in 2015. However, a number of regional banks still remain in the early stages of identifying relevant issues and industry best practice across their own operations and financing activities. Focus to-date has primarily been on establishing and implementing appropriate policies and procedures, including the roll-out of general training to staff.

Global Listed Infrastructure

The Global Listed Infrastructure team assessed the risk of modern slavery in its research focus list, considering sectors, geographies, and companies. External data sources, including the Transparency International Corruption Perceptions Index, helped identify countries associated with modern slavery risks. Each company in the focus list was ranked based on the vulnerability index of the countries where they operate and engagement efforts are prioritised towards companies with higher exposure in countries ranked higher on the index.

RQI Investors

The RQI Investors 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, RQI 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 1. Our global modern slavery exposure and risk for listed equities and corporate fixed income

Map of global modern slavery risk

Source: Global Slavery Index 2023, First Sentier Investors Data as at 31 December 2023

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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

In sustainable finance strategies around the world, there is a particular focus on climate change data, and on actions that can be more easily measured, such as reducing carbon emissions.

And while this is welcome, it can sometimes be at the cost of investors’ attention being directed towards human rights issues, which are harder to quantify but no less important than climate action. Moreover, a lack of progress on human rights and modern slavery will compound the issues that are, regrettably, being worsened by climate change.

We advocate for a more holistic view of the climate change and human rights nexus, so that we can aim to drive positive change in both areas, not at the expense of one.

It has been challenging to find good quality data to determine our exposure to human rights risks. We have sought to engage with other investors, standard setters, ESG research providers and civil society organisations to address this issue, through our policy advocacy program, our work on CAHRA exposure, and IAST APAC.

Future plans

A future focus will include a more thorough mapping of our exposure to CAHRA, and increasing our understanding of the geopolitical risks that increase human rights risks for the companies we invest in.

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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