Modern Slavery Act

Introduction

This document outlines FPA Envirochoice’s current and proposed actions to understand all possible modern slavery threats associated with its business, and to put in place initiatives to ensure that slavery and human trafficking are not present in its own operations or supply chains.

FPA Envirochoice, including its affiliated and subsidiary businesses, recognises that it has a duty under the Modern Slavery Act 2018 to take a strong stance against slavery and human trafficking.

FPA Envirochoice is fully committed to combating slavery and human trafficking in its business operations, as well as ensuring that supply chains are free of slavery and human trafficking.

Company Structure & Supply Chain

FPA Envirochoice is a long standing provider of disposable food packaging in the Australian marketplace. Our reputation is based on over 30 years’ experience. Headquartered in Perth, Western Australia, FPA Envirochoice has operations nationally in Australia, and also supplies food packaging products to New Zealand. FPA Envirochoice currently employs over 80 people in Australia.

FPA Envirochoice provides food packaging solutions to a range of organisations, in various sectors including food, retail, healthcare, entertainment & industrial.

FPA Envirochoice has a broad product range, with a current SKU count of 3121. Due to the broad quantity and range of goods sold to our customers, FPA Envirochoice has a multifaceted supply chain. FPA Envirochoice does source some products from Australia, however we also import. FPA Envirochoice currently imports products from China, Indonesia, Thailand, Hong Kong, Malaysia, Taiwan and New Zealand.

FPA Envirochoice Culture, Values, Mission & Vision

Our Mission is to develop sustainable packaging solutions that leave the world a greener place for future generations.

We will become the leading sustainable packaging solutions provider in Australia by proudly being the most convenient, reliable, and easiest company to do business with in our sector.

We are proud of being renowned for continuous improvement and delighting our customers with quality products and convenient service.

We are an organisation that values respect, learning, recognition for good work and constructive conversations. We do not value negative attitudes or accept poor standards.

Modern Slavery Mission Statement

“As a leading national supplier of food packaging products, FPA Envirochoice recognises that modern slavery and human trafficking continue to be major concerns that pose significant challenges for industries worldwide. In line with our company values, we are committed to continuous improvement of our operations and practices to eliminate modern slavery and human trafficking within our supply chains. FPA Envirochoice maintains a zero-tolerance approach to modern slavery and will continue to act with integrity in all of our business arrangements”.

Relevant Policies

  • Ethical Sourcing Policy
  • Ethical Business Practices

Modern Slavery Steering Committee

Our project team to implement and maintain the proposed Modern Slavery Practices consists of –

Gary O’Brien – General Manager
Lindsay Ride – National Procurement Manager
Tanya Sly – Business Development Manager
Kim Willow – Purchasing Supervisor
Ron Men – Purchasing Officer

Supply Chain Risks

As many of our products are sourced from overseas, it’s imperative FPA Envirochoice considers how this comprehensive supply chain could potentially be linked to modern slavery.

Below is a list of potential identified risks –

  • Non Transparency – due to the physical distance between FPA Envirochoice and its suppliers, ensuring compliance from suppliers may be challenging.
  • Traceability – as these suppliers may source raw materials and other components from other companies, it becomes harder to trace these sources for modern slavery compliance.
  • High-Risk Countries –Sourcing from some locations that are deemed to have an increased of modern slavery.
  • Timeframes – with an increased demand on sourcing products in shorter timeframes, there is a higher risk of forced excessive working hours.

Risk Mitigation & Due Diligence

FPA Envirochoice recognises the importance of mitigating the aforementioned risks, and plans to undertake due diligence in relation to slavery and human trafficking when considering new suppliers. FPA Envirochoice also commits to reviewing our existing suppliers on a periodic basis. Our due diligence and reviews will include:

  • Risk Mapping – Mapping the supply chain to determine the threats of modern slavery and human trafficking in procurement of individual goods, or procurement from particular geographical areas.
  • Risk Management – Assessing the modern slavery and human trafficking risks of new suppliers.
  • Audits – Conducting supplier audits or assessments which have a greater degree of focus on slavery and human trafficking where general risks are identified.
  • Risk Mitigation – If a supplier is considered high-risk due to their location and/or a lack of acceptable policies/processes, then the FPA Envirochoice Steering Committee will raise an investigation and consider ceasing trade with the high-risk supplier.

Further actions to address Modern Slavery

FPA Envirochoice recognises the importance of cultivating an ethical supply chain, and has placed a high priority on implementing all procedures and assessments outlined in this document to combat modern slavery. FPA Envirochoice holds long-term relationships with most of its suppliers, which allows us improved communication and enhanced trust in our business transactions.

Sedex – Sedex is one of the world’s leading ethical trade membership organisations, working with businesses to improve working conditions in global supply chains. Sedex provides an online platform, tools and services to help businesses operate responsibly and sustainably, protect workers and source ethically. FPA Envirochoice is a member of Sedex, and will follow their procedures and guidelines to improve our responsible and sustainable business practices, ensuring we source responsibly.

Raising Awareness

FPA Envirochoice will raise awareness of modern slavery issues by circulating information to employees. FPA Envirochoice will endeavour to communicate information to relevant employees relating to –

  • The principles of the Modern Slavery Act 2018, and how they apply to FPA Envirochoice.
  • What employees can do to report any identified slavery and human trafficking to the Modern Slavery Steering Committee.
  • FPA Envirochoice’s ongoing progress relating to Modern Slavery.

Evaluating The Effectiveness Of Our Approach

To measure our effectiveness in mitigating modern slavery in our organisation and supply chain, we have developed the following key performance indicators (KPI’s) –

  • Build an internal FPA Envirochoice Modern Slavery database, which will include the following –
    • Current FPA Envirochoice Supplier Questionnaire.
    • Signed copies of FPA Envirochoice’s Supplier Questionnaire from all suppliers.
    • Risk Map of FPA Envirochoice’s suppliers.
    • Internal risk assessment checklist for any potential suppliers.
  • Any relevant audit information and Sedex documentation.
    • Any relevant instruction manuals relating to the assessments and procedures mentioned in this document.
    • Responsibility task sheet – list of responsible staff member for all aforementioned FPA Envirochoice modern slavery procedures, including a completion checklist.
    • Relevant staff training schedule.
  • Ensure all requirements of the Sedex membership are met.
  • Ensure all relevant FPA Envirochoice staff are fully aware of FPA Envirochoice modern slavery procedures.

Our Commitment

In line with our continuous improvement, FPA Envirochoice values integrity within its business and commits to applying the due diligence and risk mitigation activities outlined in this document. This statement has been approved and issued on behalf of FPA Envirochoice by Gary O’Brien, General Manager, on the 5th May 2021.