This statement is approved by the Board of Directors on 29th September 2023 and signed by the President of SALA – Kenji Mamiya.
This statement is made pursuant to the Modern Slavery Act 2018 (Cth). This statement outlines the approach and initiatives by Summit Auto Lease Australia Pty Ltd ABN 870 054 704 737 (SALA) to identify and address the risks of modern slavery in its business operations and supply chains during the financial year commencing 1 April 2022 and ending 31 March 2023 (2022-23 Financial Year or Year 4).
SALA was established on December 20th, 1996 and is a subsidiary company of Sumitomo Mitsui Auto Service Company Ltd (SMAS) incorporated in Japan.
It trades under the business name Summit Fleet Leasing and Management and its head office is at Unit 7, 36-48 South Street, Rydalmere NSW.
SMAS shareholders are
At the core of SMAS lies the Company’s Business Philosophy. The Corporate Mission Statement is based on this philosophy and represents SMAS fundamental and ultimate value standard stating an “utmost respect for the individual” and placing a prime importance on integrity and sound management.
As a subsidiary company of SMAS, SALA shares its parent company’s core values and abides by them through its governance, policies and procedures.
SALA operates nationally with physical offices in New South Wales, Queensland, Victoria and Western Australia, without international presence, does not own or control any other entities and has approximately 83 employees.
SALA is a provider of:
SALA supports the principles of the Commonwealth Modern Slavery Act 2018 in the areas of Human Rights, labour standards, environment and anti-corruption measures.
SALA believes that it has an ethical responsibility to promote human rights by showing respect for human rights through its own behaviour, and by sharing this ethos with its customers.
SALA recognises the complexity of Modern Slavery risk, and in particular the variety of ways in which it can manifest in operations and supply chains.
SALA is committed to maintaining and improving systems and processes to mitigate the risk that it might be involved, wittingly or unwittingly, in the commission of Modern Slavery and Human trafficking in any part of its operations, customers and supply chain (including contractors and suppliers), products, services and staff activities.
SALA expects its staff, suppliers and business partners to adhere to similar high standards and to take reasonable steps to ensure that other third parties they do business with adhere to similar standards.
SALA’s operations are primarily office based, focussed on the provision of financial services. The main categories of supply chain activities relating to or supporting the Company’s business activities are as follows:
Within these supply chains, our supplier bas contains a mixture of short term and longer-term business relationships. Our longer-term business relationship are predominately subject to written contracts, however, we transact with a number of suppliers on an ad hoc basis.
In Australia, SALA works with approximately 3000 suppliers, ranging from small businesses to multi-national companies, whilst some IT support is procured from suppliers located in Belgium, Singapore, USA, and UK. Of the Company’s suppliers, 250 acciount for more than 90% of its total spend.
SALA takes a collaborative approach to our relationship with our supply chain and encourages transparency by encouraging whistleblowers to report instances of unethical, unlawful or undesirable conduct in accordance with the Whistleblower Policy of SALA. Should issues be reported as a result of our due diligence, we will give guidance and support to our suppliers and contractors to help identify and work through an appropriate resolution.
In the case of repeated or serious instances, we will give consideration to the termination of our relationship accordingly.
We strive to do suppliers who demonstrate ethical business practices and values, including in relation to human rights. The risk that modern slavery is present in our supply chain is assessed in a focussed, collaborative manner by relevant internal stakeholders across our Legal, Risk, Procurement and Operations teams. In seeking to identify the modern slavery risks in our operations and supply chain, we considered the potential for our business to cause, contribute to, or be directly linked to modern slavery.
In doing so, we looked at;
Having regard to this assessment process, given the fact that our operations are based in Australia, our geographic risk remains low according to the Global Slavery Index. Furthermore, the risk of modern slavery occurring in our direct employment of workers also remains low having regard to our ongoing compliance with the legal framework regulating employment practices in Australia. For these reasons, we are of the view that there are low risks that our operations have caused or contributed to modern slavery risks during the Reporting Period.
However, the location of our business does not completely remove the risk of modern slavery from our supply chains. WE are conscious that our direct suppliers in Australia may have operations and downstream suppliers in countries where modern slavery practices are more prevalent, including those suppliers who manufacture goods with raw materials sourced from high-risk countries. For example, it is widely reported that some motor vehicle and information technology infrastructure manufacturers rely on their suppliers to source high-risk products such as minerals and other raw materials from countries with an increased risk profile for child or forced labour in order to produce components fitted into their products. This means that, by virtue of our supply chain, we are at risk of being directly lined to modern slavery through the business practices of companies in the later tiers of our supply chain.
SALA operates our business in accordance with our Code of Conduct as well as conducting its business in accordance with various polices, including the following which address human rights and ethical employment practices;
SALA also has a number of policies that set out in a transparent manner our employees’ rights to remuneration and a safe working environment. These policies include;
A professional training module on Modern Slavery in included in the learning management system, which all employees and contractors of SALA must complete annually on Modern Slavery and Human Trafficking and the requirements of the Modern Slavery Act 2018.
During the year ended 31 March 2023, SALA onboarded approximately 180 new suppliers to our Supply and Services Agreement which includes a Modern Slavery clause for all its suppliers to understand the applicable laws and regulations including the ACT and provide confirmation of their compliance.
During the year ended 31 March 2023 we issued surveys to approximately 1900 suppliers within our supply chain to collect information on our suppliers’ operations and their inherent modern slavery risks and governance practices.
The suppliers who responded to the due diligence questionnaire demonstarted varying levels of materity in their approaches to identifying, preventing and managing modern slavery risks in their operations and supply chain.
Due to the limited scope of suppliers who engaged in the survey, our intention is to focus the Modern Slavery Due Diligence Questionnaire to those 250 suppliers who represent over 90% of total spend.
Our Whistleblower Policy sets out he mechanisms by which our employees can raise grievances. The policy includes protections for the whistleblower’s confidentiality, as well as preventing their victimisation. No complaints related to modern slavery were reported via our whistleblower channels during the Reporting Period.
If our investigative processes determine an issue of non-compliance with our policies by one of our suppliers, we will endeavour to have our supplier identify and correct those issues. If it is apparent that an individual has suffered harm as a result of such issue, we will seek to ensure that they are ‘made good’ by leveraging our position with our supplier,
If a supplier fails to make progress in respect of required remediation, we may subject it to review and sanctions by leveraging our position with them, including the potential termination of our relationship.
We remain committed to providing effective remedies where our operations cause or contribute to adverse human rights impacts. Our approach to remediation is to engage directly with affected persons, and work with our business partners and other stakeholders to remediate any such impacts and consider how our internal processes can be improved to prevent similar impacts in the future.
Although it is very difficult to assess the effectiveness of the steps referred to above, relevant indicators include:
SALA did not identify any such issues in its operations or supply chain during the year ended 31 March 2023 independently or through the company’s due diligence procedures, nor has it received any notification of such issues within its own business or those of its industry peers. Consistent with SALA’s assessment of its own modern slavery risk and due diligence procedures employed by SALA, identified its key suppliers as having a low risk of modern slavery within its operations. It is acknowledged, however, the SALA operations, and those of its primary suppliers, take place within Australia and have a low incidence of modern slavery generally.
Whilst we are confident that we operate in a relatively low risk business sector and our management and processes minimise the risk of modern slavery or human trafficking occurring, we are committed to further improvements and will continue to review and enhance our approach to addressing human rights risks by taking further steps in Fiscal Year 2023 which may include:
As described above, SALA does not own or control other reporting entities. No consultation process was required.
This statement is approved by the Board of Directors on 29th September 2023 and signed by the President of SALA – Kenji Mamiya.
