Addressing modern slavery
Swinburne is committed to taking the necessary steps to identify and resolve any form of modern slavery within the University’s operations, our suppliers and partner organisations. We deplore all forms of slavery and forced labour, and we understand the significant role of universities in helping to end modern slavery.
Swinburne's Modern Slavery Statement outlines our commitments and steps taken to resolve any forms of modern slavery within our operations, suppliers and partner organisations.
We are participating in the university sector’s modern slavery program which aims to work collaboratively with our suppliers and peers in the sector to address modern slavery across our supply chains. Our Modern Slavery Statement is also published on the Australian Border Force’s online register.
Our 2025 Modern Slavery Statement is awaiting approval
The information on this page is related to Swinburne's 2025 Modern Slavery Statement. Please note that this has not yet been approved by the Attorney-General's Department or published on the Modern Slavery Statements Register.
Understanding our modern slavery risks
Swinburne recognises and supports that freedom from slavery is a fundamental human right. Swinburne relies on the Australian Modern Slavery Act’s definition of modern slavery which includes eight types of serious exploitation:
- trafficking in persons
- slavery
- servitude
- deceptive recruiting for labour/services
- forced marriage
- forced labour
- debt bondage
- the worst forms of child labour
The worst forms of child labour mean situations where children are subjected to slavery or similar practices or engaged in hazardous work.
We support the UN Guiding Principles on Business and Human Rights (UN Principles), which are the recognised global standard for preventing and addressing business-related human rights harm. We recognise our moral obligation to respect human rights and as per the UN Principles we will take action to prevent, mitigate and, where appropriate, remedy modern slavery across our operations, supply chains and in our investments.
Swinburne’s total student headcount in 2024 was 45,258 across higher education and 22,787 across vocational education. At the end of 2024, Swinburne had more than 2,700 employees (2,383 full-time equivalent), comprising full-time, part-time and fixed term and casual staff.
Most Swinburne employees have terms and conditions of employment through one of the university’s enterprise agreements. Staff are represented in the enterprise bargaining process by the National Tertiary Education Union (NTEU) and Australian Education Union (AEU) or can self-represent. Not all employees of the university choose to be a member of a union and membership is not compulsory. Australian-based employees who are not covered by an enterprise agreement are covered by modern awards. Swinburne supports freedom of association and employee representation and continues to have positive and regular interactions and communications with relevant Unions.
Swinburne is compliant with applicable labour laws and regulations. We do not impose any penalties or other negative consequences on employees wishing to cease their employment with the university. Employees leave their jobs without barriers or fear of consequences. On the rare occasions where we need to source labour from outside Australia (particularly to provide services within those geographies), we do so in a way that is compliant with the local labour laws and regulations and, to the extent appropriate, provide comparable terms and conditions to Swinburne’s Australian employees.
We have policies and procedures in place to ensure a safe, equitable and supportive work and study environment for our staff and students. The university’s People, Culture and Integrity Policy sets out the university’s commitment to building a positive culture, promoting integrity, and supporting university members, community and industry partners. Ethical conduct is expected, encouraged, and supported with no tolerance for corrupt conduct, fraudulent activities, and maladministration. The policy requires that responsible persons must be free from a conflict of interest, bias and inappropriate influence when making decisions and dealing with other persons or organisations on behalf of the university. These policies are supported by the Complaints, Reviews, Appeals and Misconduct Framework for students and staff.
The university is committed to providing an environment for work and study that is safe, respectful, inclusive; free from bullying, violence, sexual harm, harassment and assault, discrimination, and harassment and vilification. The university is also committed to the safety of children and has zero tolerance for sexual harm and child abuse.
The university’s position on improper conduct (including fraud and corruption, criminal offences, actions that lead to substantial risk to health and safety of a person) is guided by the principles of:
- upholding the highest standards of legal, ethical, and moral behaviour
- ensuring the organisational culture and embedded risk controls effectively deter improper conduct
- building willingness to report wrongdoing
- ensuring compliance with public interest disclosure or whistle-blower legislation (including the Public Interest Disclosure Act and the Corporations Act (2013,PID Act)
- protections for individuals who disclose improper conduct; and natural justice.
Swinburne researchers are committed to the highest ethical, professional, and scholarly standards. Our research adheres to the Australian Code for the Responsible Conduct of Research (2018). We are committed to ensuring that all Swinburne research is conducted responsibly with honesty, integrity and respect for human research participants, animals, and the environment. Research may be undertaken in partnership with a variety of Australian and international external parties that may include start-ups, small to medium enterprises, not-for-profit enterprises, multinationals, and government bodies. Due diligence is carried out on potential research partners to assess their ethical and sustainable business practices align with Swinburne’s own integrity standards. Foreign interference legislation requirements are adhered to, supported by assessment and reporting processes, as applicable.
Swinburne has an independent disclosure service for employees and third parties to report suspected or actual illegal or improper activity. Information outlining how to access this service and the process for managing disclosures is found within Swinburne’s Improper Conduct and Whistleblowing Guidelines. Disclosers may disclose anonymously if they wish.
Through investments in public and private companies, we can have an impact on the environment and communities worldwide. We believe we have an opportunity to influence those companies to create positive change. Our areas of focus within our Responsible Investment Charter are:
- climate change
- human rights and modern slavery
- sustainable development.
Swinburne requires our investment fund manager to undertake an annual review of Swinburne’s portfolio performance against the Responsible Investment Charter and best practice. The 2024 review confirmed that Swinburne’s investments comply with all commitments within the Investment Charter and the portfolio continues to perform well across all key ESG metrics monitored. The university rated A+ in Mercer’s Responsible Investment Evaluation and ranks within the upper quartile of its global peer group, and well above the global university and education sector.
Importantly, the assessment confirmed that the portfolio has no exposure to companies with high severity red flag incidents in relation to modern slavery (aligned to UN Global Compact principles on forced labour and child labour). Swinburne’s investment manager reports at least annually to the Swinburne Audit and Risk Committee, and Council, on regular assessments undertaken to confirm this position.
Swinburne conducts a yearly analysis on its procurement spend to assess the risks of modern slavery across our supply chain. The risk assessment for 2024 spend is based on outputs from the ArcBlue (part of Bain & Company) modern slavery tool. This tool determines risk exposure using different sources (e.g. 2023 Global Slavery Index, RESPECT Responsible and Ethical Private Sector Coalition Against Trafficking, NSW Anti-Slavery Commissioner Guidance on Reasonable Steps etc.) and produces a risk level assessment at a country, spend category (i.e. broadly aligned to industries), and supplier level.
Insights from the tool highlight that in 2024 Swinburne procured from 77 spend categories (975 suppliers) that contain an inherent high risk of modern slavery, influenced by factors such as complex global goods supply chains and low skill labour workforces (refer Table 1). The level of risk assigned to each category presents a view on the level of risk for that industry’s supply chain, rather than the risk of the direct supplier alone.
| Risk categories | Percentage |
|---|---|
| High risk | 47% |
| Medium risk | 33% |
| Low risk | 20% |
Key categories of the university’s spend that contain an inherent high risk of modern slavery are listed in Table 2.
| Goods | Services |
|---|---|
Peripheral equipment Equipment (scientific, engineering, telecommunications, AV, medical, electronics) IT network infrastructure Stationery and kitchen supplies Laboratory supplies Merchandise and apparel, including uniforms and PPE Mobile devices and accessories |
Commercial cleaning and hygiene services Security Construction Catering Hotels and motels International student recruitment Software Licences |
Swinburne procures goods directly from overseas countries, albeit the proportion of these overseas suppliers is small relative to the number of total suppliers (21.2%). Of these, 138 suppliers located across the Asian, South American, and African regions are presenting with higher inherent risks of modern slavery, as shown in Graph 1 and Table 3 due to the higher rates of modern slavery and human trafficking prevalent in those regions.
As the university predominantly focuses on local procurement, Swinburne’s spend with suppliers based in high-risk locations outside of Australia is mostly limited to student (international) recruitment services and educational support services (e.g. thesis examination and marking services).
The map (Graph 1) outlines Swinburne’s suppliers in 2024 by country in relation to the prevalence of modern slavery risks as per the ArcBlue tool.
| High-risk country | Number of suppliers |
|---|---|
| India | 47 |
| South Africa | 6 |
| Sri Lanka | 5 |
| Bangladesh | 4 |
| Cambodia | 3 |
| Philippines | 3 |
| Pakistan | 2 |
| Saudi Arabia | 2 |
| Laos | 1 |
| Turkiye | 1 |
| Timor-Leste | 1 |
Bringing together the two inherent risk assessments of Spend Category and Country into one overall risk score, Swinburne’s modern slavery tool identifies 23 unique suppliers (1% of total suppliers) who are identified as being of a very high risk of modern slavey and 1,129 unique suppliers (31% of total suppliers) who are identified as being of a high risk of modern slavery (refer Table 4). Whilst these results are in line with educational organisations of our size, we continue to work with fellow universities, the AUPN and our suppliers to reduce our overall modern slavery risk.
The spend categories and countries identified as high risk are the subject of Swinburne’s detailed analysis that is conducted during strategic procurement tenders and specific category reviews. Many of the spend areas require a deeper analysis of suppliers, taking into account their complex global supply chains, as opposed to purely focusing on the individual supplier that Swinburne transacts directly with. Strategic procurement projects delivered across Swinburne in 2024 considered and addressed inherent modern slavery risks for the relevant category and/or country.
While we continue to assess and address the overall modern slavery risk across our operations, investments and research activities, our supply chain remained our primary focus of action in 2024, given that this is the area where the potential risks of modern slavery occurrences are most prevalent.
| Risk level | Number of suppliers | Percentage of suppliers |
|---|---|---|
| Very-high risk | 23 | 1% |
| High risk | 1,129 | 31% |
| Medium risk | 176 | 5% |
| Low risk | 2,259 | 63% |
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"Our commitment to the elimination of modern slavery is a shared value and priority across our community. Swinburne is committed to contributing to the elimination of modern slavery across the world".
Professor Pascale Quester , Vice Chancellor and President
Our actions to assess and address risks of modern slavery
Swinburne recognises its responsibility to act to prevent, mitigate and, where appropriate, remedy modern slavery in our operations.
We also accept our obligation to work collaboratively with our direct and indirect suppliers to address the risks of occurrence of modern slavery across our supply chain. In 2024, we undertook several actions in this area and contributed significantly to the Australian Universities Procurement Network (AUPN) Anti-Slavery Program’s sector response.
Raising the awareness and understanding of modern slavery
As an educational institution, Swinburne recognises the importance of raising awareness and educating our students and staff on the critical human rights issue of modern slavery.
Throughout 2024, we continued to deliver presentations to senior stakeholders, staff, and students on modern slavery. Furthermore, we included modern slavery as an ongoing content topic within the induction pack training materials distributed to new starters within the Procurement Team and the university as a whole. These sessions and materials provided information on the issue of modern slavery and its prevalence, the actions being undertaken by Swinburne, and, importantly, what actions individuals should take to assess and address related risks.
In 2024, all members of the Procurement team received detailed modern slavery training, which elevated the capability of these practitioners to identify and acting on risks across Swinburne’s supply chain.
Representatives across Procurement, Legal, Risk and Governance, Research and other operational teams have been engaged on this issue to mobilise cross-university collaboration through ad hoc forums and specific initiatives.
Swinburne's supplier due diligence
To mitigate the risk of modern slavery in key service contracts, the procurement team undertakes the following activities:
- periodic issuing of questionnaires to selected suppliers requesting information to understand risks and actions taken;
- tender evaluation requiring suppliers to demonstrate policies, processes, and/or systems to reduce the risk of modern slavery and actions to mitigate or address modern slavery risks;
- periodic assessment of wages being paid at market/award rates, including auditing of employee payslips; and
- executing contracts with obligations specific to reducing labour exploitation and modern slavery.
In 2024, Swinburne used the ArcBlue supply chain transparency and modern slavery tool in its own procurement processes and when collaborating with the broader university sector on specific anti-modern slavery initiatives. The tool supports improved supply chain visibility, undertaking of due diligence actions and providing indicators to measure effectiveness.
The results of due diligence during our own tender processes indicated a wide range of maturity in the modern slavery efforts within the suppliers assessed, and most responses required further information to better understand specific modern slavery risks.
To supplement the ArcBlue tool, Swinburne leveraged media monitoring alerts that related to suppliers, countries, and industries relevant to the university sector. These alerts were and remain critical to support capability uplift initiatives.
During 2024, armed with the insights provided by these tools on where risks might be high across Swinburne’s supply chain, the Procurement Team undertook deeper modern slavery reviews across specific spend categories.
Swinburne’s procurement framework
Swinburne’s procurement framework is structured around a strong focus on sustainability and improving social outcomes, including reducing risks and occurrence of modern slavery in our supply chains.
We take a holistic view of value for money in our strategic procurement of goods and services. This means that we base our purchasing decisions on a wide variety of criteria, including environmental and social factors, as well as more common criteria of quality, timeliness, and cost.
We avoid setting unrealistic delivery timeframes and/or driving suppliers to offer unrealistically low prices, understanding the risks that this can present to labour exploitation (including modern slavery) and other negative impacts.
The framework consists of policies, procedures, guidance materials, templates, and tools that strive to deliver a balance of commercial and social value through any procurement that the university undertakes. In 2024, we continued to embed the framework in our working practices through university-wide communications, presentations, and training.
The procurement framework contains due diligence measures in procurement processes to assess the risk of modern slavery across both new and ongoing supplier engagements.
Regardless of any other considerations, any procurement determined to contain an inherent high risk of modern slavery is referred to the Procurement team. Project planning, evaluation and decision-making stages of strategic and tactical procurement projects include a focus on modern slavery. A modern slavery risk questionnaire is included in procurement (tendering) projects where the risk of modern slavery exists.
Swinburne's contract terms
As a key control mechanism, Swinburne’s standard contract templates include clauses addressing modern slavery risk. These terms and conditions outline the supplier’s obligation to investigate modern slavery in their own operations and supply chains, as well as assess and address risks, take meaningful actions including due diligence and remediation, and have necessary processes and systems in place.
These terms also include an obligation for suppliers to include similar clauses in their own contracts with suppliers, supporting our intent to create positive impact across our entire supply chain.
Modern slavery clauses are embedded in all our new supply arrangements and in existing supplier contracts as they are renewed.
Modern Slavery Statement
Collaboration as a university sector
The Australian University Procurement Network (AUPN), the peak body for strategic procurement across the higher education sector in Australia and New Zealand, is taking an active approach to addressing this critical human rights issue.
Recognising the opportunity for universities to work together to leverage aggregated buying power and resources, a working group was established in August 2019 to drive a sector-wide approach. Renamed in 2023 as the AUPN’s Anti-Slavery Program, the vision of the program is to support members to improve supply chain human rights transparency, reduce individual university costs and resources, collaborate on risks and issues for greater impact, and contribute to reporting requirements.
Swinburne’s Director of Procurement, Sustainability and Property Services continued as Chair of this program in 2024, performing an important leadership role in driving outcomes. Working group members contributed their time and effort on a voluntary basis, with each AUPN member university contributing towards the program through a portion of membership fees. This funding goes towards program management, engagement of specialised subject matter expertise, and execution of specific initiatives.
Through this program, it is envisaged that both AUPN members and their suppliers will benefit from improved operational efficiencies and gain improved effectiveness in mitigating risk and improving social performance in supply chains.
The program delivered several key initiatives in 2024.
An Academic Advisory Board was established in July 2020 and refreshed in 2022 with ten academic members from seven universities with specific experience and expertise in modern slavery.
With an aim to enrich the sector approach, academics were asked to provide insight and contribute expertise to help members understand risks and take action relative to the academic’s area of expertise. Key insights were disseminated to universities through communications and guidance materials.
ArcBlue’s modern slavery tool was implemented at Swinburne (and across most other Australian universities) at the start of 2024. This solution determines risk from different sources and applies an inherent risk score at a country, spend category, and supplier level.
The aggregated data in the tool reflects the large breadth and scale of our combined supply chains across the sector and the crossover of suppliers being used by multiple universities.
Templates and guidance documents are made available to all AUPN members by the program, including a risk questionnaire, contract clauses, supplier code of conduct guidelines, guidance on effective grievance mechanisms and remediation, and modern slavery statement guidelines.
These materials aim to provide member universities with information on grievance mechanisms, remediation, and a university’s role in preventing and mitigating modern slavery within their supply chains. The materials go beyond procurement/supply chain considerations and offer overall guidance on grievance mechanisms and remediation universities’ operations.
One of the program’s key objectives is to raise awareness, educate and stimulate action across the university sector, external stakeholders, and suppliers.
The monthly University Anti-Slavery Forum continued to build momentum during 2024, showcasing a suite of external speakers sharing insights and learnings on important topics related to modern slavery. Up to 85 procurement and other university staff attended each of the nine sessions throughout the year, representing 40 Australian and New Zealand universities. Speakers included representatives from Australian Red Cross, Property Council of Australia, Supply Chain Sustainability School and The Freedom Hub. Meetings also discussed progress on key initiatives, updates on action addressing key risks, and invited suggestions for collaboration. Minutes and key resources were disseminated across teams and made available through the AUPN portal.
The program engaged externally during 2024 to gather insights from other sectors and collaboration programs as well as raise awareness of the AUPN program. Groups engaged include Migrant Justice Institute, Anti-Slavery Australia, and ACRATH (Australian Catholic Religious Against the Trafficking of Humans).
Measuring our effectiveness
The influence and purpose retained by universities in society create an opportunity for Swinburne to take a leadership role, together with the wider university sector, in addressing Modern Slavery risks and actual instances.
Swinburne recognises that our approach to this critical issue will continue to evolve over time and that measuring our effectiveness is essential to prioritise our efforts for the periods ahead.
We will measure our effectiveness through:
- ongoing contribution into reviews of Swinburne’s risk assessment framework and processes to ensure appropriate and up-to-date consideration of human rights abuses across our operations and supply chains
- periodic reviews of the risk profile of Swinburne’s existing supplier base with particular attention devoted to the progress made to reduce supplier risk profiles through action and review (for example, responses to questionnaires); and
- monitoring of progress against Swinburne modern slavery key performance indicators.
| Our commitment | 2024 outcomes |
|---|---|
| All Swinburne staff and students are made aware of modern slavery issues through communications and training | Comprehensive Procurement framework continued to be embedded, including modern slavery information, education, processes, policies and risk monitoring within supplier relationships. Eighty key purchasers and procurers representing significant proportion of high risk spend completed refresher training on Swinburne’s procurement framework and modern slavery risks. Revision of the communication and education process with modern slavery to be included in the new starter training and quarterly refresher courses available for key purchasers and procurers. Swinburne staff continued their involvement and education through AUPN meetings and training sessions. |
| Swinburne supplier engagement reviews that incorporate an assessment of modern slavery risks in the supplier’s operations and supply chain | Tender documents and subsequent evaluations require suppliers to demonstrate policies, processes, and/or systems to reduce the risk of modern slavery and actual actions taken to comply with policies. In 2024, modern slavery reviews were undertaken for key high-risk tenders, including cleaning services, printing, merchandise, lighting and building refurbishments. |
| Swinburne supplier contracts that include modern slavery clauses | Swinburne’s standard contract templates include clauses addressing modern slavery risk. The terms and conditions outline the supplier’s obligation to investigate modern slavery in its operations and supply chains, assess and address risks, take meaningful actions including due diligence and remediation, and ensure necessary processes and systems are in place. They also include an obligation for suppliers to include similar clauses in their contracts with suppliers, supporting our intent to create positive impact through the end-to-end supply chain beyond our direct suppliers. These clauses continue to be embedded in all new supply arrangements and in existing supplier contracts as they are renewed. |
| High-risk suppliers engaged in response to risk alerts or undertaking proactive reviews | Deep modern slavery assessments continued to be undertaken. In 2024, five assessments were undertaken in high-risk areas across categories including services and merchandise. These assessments including activities such as reviewing supplier information to understand risks and actions taken and auditing of employee payslips to assess market rate wages. |
| Year-on-year reduction in the proportion of suppliers indicated as being of a higher risk of modern slavery | The University continues to make progress in reducing suppliers at the level of very high and high risk of modern slavery. |
| Completion by suppliers of the ArcBlue modern slavery risk questionnaire | Supported ArcBlue to identify and work with 20 suppliers to undertake the risk questionnaire and related assessments. |
Priorities for the future
Swinburne recognises that continuous learning and improvement is an important component of any journey to eliminate modern slavery. Priorities for 2025 include:
- further capability uplift across the Procurement and Sustainability teams to better identify modern slavery risk and assess supplier maturity (alongside other ESG priorities) in strategic procurement processes
- further use of analytics embedded in the ArcBlue modern slavery tool within Swinburne’s procurement processes, utilising its insights during tenders and deep assessment of higher risk spend areas
- engaging suppliers to secure participation in the rollout of modern slavery questionnaires across selected high risk spend areas;
- collaborating with the university sector to support key issues or risks that the AUPN Modern Slavery Program acts on
- engaging with university Governance and Legal teams to review the appropriateness of Swinburne’s complaints procedures and services to support modern slavery grievances
- delivering presentations, communications, and training sessions to raise awareness and uplift capabilities across the university around modern slavery.
Get in contact
If you’d like to know more about our commitment to address and diminish Modern Slavery, please contact us at sustainability@swinburne.edu.au.