SUPPLIERS Human rights and modern slavery

Human rights and modern slavery

Gold Fields has for some time been focused on safeguarding the human rights of those involved in its operations and supply chain. Whilst Gold Fields is comfortable that its employment practices eliminate the risk of modern slavery practices within its Australian operations, it acknowledges that there is a risk that we may contribute to modern slavery practices through our actions in our supply chains, for example by setting cost targets that can only be met by using exploited labour. Furthermore, we may be directly linked to modern slavery practices through the activities of our business partners, including our supply chain.

There are multiple risk factors that contribute to this position, including sector-based risks, product/services risks, geographic and jurisdictional risks, as well as particular entity risks.

With a current international focus on modern slavery practices, reinforced by legislation in certain jurisdictions (for example the UK and Australia), Gold Fields is seeking to improve its understanding of its supplier base to ensure we procure only from businesses whose products and services have been ethically sourced and are free of forced labour.

Our strategy and process in relation to the identification and elimination of modern slavery practices in our supply chain is informed by a multi-disciplinary, integrated team across our supply chain, legal and sustainable development functions.

To ensure compliance with Australia's Modern Slavery Act (2018), our Supply Chain team is currently focused on:

  • identifying high-risk sustainability suppliers within our supply chain;
  • developing an audit ‘plan-of-attack' focusing primarily on categories of spend known to be high-risk;
  • driving acknowledgement by suppliers of Gold Fields' Values and Group Supplier Code of Conduct;
  • updating policies, procedures, and contract templates to meet the requirements of the legislation;
  • training personnel in how to identify and address human rights and/or modern slavery issues; and
  • collaborating with industry peers with a view to eliminating modern slavery from our supply chains.
Human rights supplier self-assessment questionnaire

Gold Fields, in conjunction with peer companies, has developed a Modern Slavery Toolkit, comprising an "Understanding Modern Slavery" brochure, frequently asked questions, and a Human Rights Supplier Self-Assessment Questionnaire (SAQ).

Key suppliers to Gold Fields' Australian mines have been provided with the Modern Slavery Toolkit to assist them in identifying possible human rights contraventions. Suppliers are required to complete the SAQ, which is designed to support the identification of modern slavery risks, foster collaborative efforts between suppliers and organisations to address those risks, improve supply chain transparency, and identify areas for further due diligence. The SAQ has also been integrated into the Australian region's tender processes.

Where required, Gold Fields will provide support to its suppliers to address contraventions. Blocking a supplier would only be considered as a last resort.

Supplier human rights risk assessment tool

Whilst the SAQ is a valuable tool and critical input, it should not be relied on as the sole measure of a supplier's modern slavery compliance risk. A cloud-based platform is used to assess supplier human rights risk using data from multiple sources (including the SAQ), which are designed to moderate supplier human rights self-assessment scores.

Gold Fields' Procurement and Contracts personnel in Australia have received training on how to recognise and respond to risks of modern slavery in the supply chain. This training will continue to be developed alongside Gold Fields' work in this space.

Supplier Screening

All Tier 1 vendors (those that supply goods, materials or services directly to Gold Fields) are screened on a monthly basis, via a third-party screening solution for Government and Government Official affiliations, and recorded transgressions and whether regulator action has been taken (as well as for adverse media exposure) against an array of pre-defined criteria, including (but not limited to): regulatory, anti-competitive practices, trademarks and copyright, labour practices, human rights, environmental, health and safety, management and operational issues.

Following the screening of the prospective supplier, actual or potential risk exposure is presented as part of the adjudication process for discussion and consideration. On a monthly basis, screening results are reported to the in-country leadership, and quarterly to the Board’s Audit Committee.

Additionally, our Australia region has conducted a high-level review of its expenditure profile in order to understand those product/services categories which present a potential higher risk of human rights abuses and/or modern slavery practices. From that analysis, we have overlaid additional risk analyses with respect to geography and workforce composition, in order to prioritise our due diligence programme.

Third party verification of human rights compliance

In addition to completing an on-line human rights supplier self-assessment questionnaire and third-party screening, prospective suppliers may receive a request to allow third-party access to their company's operations or manufacturing facilities, for the purpose of conducting an audit of worker conditions.

This request may extend to other suppliers within the supply chain and is designed to provide Gold Fields with comfort that appropriate labour practices are in place and that fundamental human rights are being observed. Should the audit results flag an issue, businesses will be given suitable opportunity to address the findings.