Zero tolerance for modern slavery

As a leader in responsible investment, Active Super believes modern slavery practices are a violation of human rights.

We have a zero-tolerance approach and we are committed to eliminating modern slavery throughout our operations, investments and supply chains.

This is a summary of the policies and procedures we have in place to identify and address modern slavery in our investments, and also at a corporate level in the day-to-day running of our business.

For more information, please refer to our 2020 Modern Slavery Statement published accordance with the Modern Slavery Act 2018.

Read our full statement.


What is modern slavery?

Modern slavery includes human trafficking, slavery, servitude, forced labour, debt bondage, child labour, forced marriage and deceptive recruiting for labour or services. These practices cause grave abuses of human rights to victims and are serious crimes.


Our business

Active Super provides superannuation and pension products and services to around 80,000 members, with approximately $13 billion in funds under management.

We also provide financial planning and general inquiry services to members in a number of regional locations, including Newcastle, Wollongong, Ballina, Orange, Wagga Wagga, Parramatta and Tamworth.

We are a leading super fund for responsible investment, and proud to be one of only four funds to have all products certified by the Responsible Investment Association of Australia. We are certified Carbon Neutral by Climate Active and we also manage one of the most sustainable direct property portfolios in Australia.

We have approximately 100 staff and our registered office is located at 28 Margaret Street, Sydney.


Risk assessment

As an Australian superannuation fund, Active Super operates within a heavily regulated financial services environment, with frameworks and procedures in place to govern employment practices, employee conduct, governance and risk management, whistleblowing and due diligence. Our employees are primarily skilled white-collar professionals and, therefore, the risk of modern slavery in our operations has been assessed as low.

The risk of modern slavery in our corporate supply chains is also considered low, given the majority of our suppliers are based in Australia and in high-skilled and professional industries with low labour-related risks.

There is, however, an increased risk of modern slavery within our investments as they involve hundreds of companies and associated supply chains throughout the world. We go to great lengths to manage and mitigate these risks as you would expect from one of Australia’s leading responsible investors.

The policies and procedures in place to counter the risk of modern slavery across all areas of our business are summarised below.


Our supply chains

As a superannuation fund, we appoint a range of external service providers to assist with our legal obligations, including our administrator, custodian, group insurer and investment managers. We also engage external providers to provide actuarial, consulting, accounting, legal and tax advice, marketing, travel, telecommunications, catering, information technology, cleaning, stationery and couriers.

These appointments are subject to specific service level agreements following a rigorous procurement process. To combat the risk of modern slavery, we also use a methodology based on analysis of geographic risk, product risk, sector risk and entity risk. We request and analyse supplier self-assessment questionnaires, which include information about a supplier’s own modern slavery risk identification and mitigation frameworks.


Supply chains within our investments

Externally managed investments

Active Super’s investment portfolio includes investments in Australian & international equities (listed and unlisted), fixed income, infrastructure, and property. The portfolio is principally managed by external fund managers, with stringent oversight by the Active Super Investment team.

Active Super applies a responsible investment strategy across all asset classes of the fund. This means that every company we invest in is assessed not only for its ability to deliver returns, but also for the environmental, social and governance (ESG) risk it poses to the world, including modern slavery.

We apply this assessment when on-boarding new fund managers, and all fund managers are reviewed annually. (For more details, please see our Sustainable and Responsible Investment Policy and Active Ownership Policy.)

Mapping supply chains within investment portfolios establishes a baseline for identifying risk. We continue to work with our fund managers to ensure that modern slavery is considered in our investee companies. These processes help to screen out any companies engaging in human rights abuses or modern slavery from our portfolios.

As universal asset owners, Active Super uses its voice and its vote to engage with companies on any modern slavery or human rights concerns. There are various Active Ownership strategies we can deploy to influence positive outcomes in these matters. (For more details please see our Active Ownership Policy.)

Furthermore, when selecting and appointing asset managers, we check that their approach to active ownership activities is aligned with our own. We also engage regularly with asset managers to ensure they are addressing modern slavery in their voting decisions.

Finally, Active Super collaborates with industry groups such as UNPRI, ACSI and RIAA to address issues associated with modern slavery and adopt best practice in meeting legislative requirements.

Direct property investments

Through our direct property portfolio, Active Super manages several retail shopping centres, office buildings and one business park in NSW. Modern slavery is included as part of the ESG considerations that we feed into our agreements with property suppliers and property managers.


Future commitments

Active Super is committed to understanding and addressing modern slavery risks in our business operations and supply chains and we are continually improving how we do this. For example:

We have established a Modern Slavery Working Group comprising employees from various divisions of the business including the Legal & Compliance, Risk and Investment teams.

We will be revising relevant governance policies to ensure all Active Super employees are able to identify, assess and report modern slavery matters should they arise. We’ll also be providing mandatory staff training.

We are establishing a procurement committee and strengthening our supplier due diligence program including annual reviews of key engagements such as our administrator, custodian, group insurer and IT provider.

We are continually strengthening our measurement and assessment for portfolio managers regarding their ESG risk.

For a complete list of the targets and key performance indicators Active Super has in place for FY20/21, please refer to our 2020 Modern Slavery Statement.

Read our full statement.