Our Modern Slavery Statement

This statement is Blue Connections Pty Ltd’s Modern Slavery Statement (Statement) pursuant to the Australian Modern Slavery Act 2018 (Cth).

The purpose of this statement is to outline the actions Blue Connections IT Australia are taking to assess and address modern slavery risks in its business operations and supply chains, and how we plan to continue to improve our frameworks and processes in the future.

Our Structure

Blue Connections IT Australia is a private company based in Melbourne, Victoria.

Blue Connections IT specialises in delivering IT Products and Services to medium to large Australian enterprises and organisations.

Since its inception in 1997, Blue Connections has grown to a team of over 160 people, operating Australia-wide with staff in most Australian states.

Our Operations and Supply Chains

Blue Connections Australia’s main operations are based in Scoresby Victoria.

Blue Connections’ operations include Services based around Microsoft, Infrastructure, Networking and Communications, Managed Services and Lifecycle Management.

Our warehousing operations involve the sale and distribution of broad wide range of leading brand IT products. The warehouses are fully operated by Blue Connections with the workers in these warehouses being employed directly by Blue Connections companies.

Our supply chain comprises mainly global well known multi-national technology companies that we have enjoyed long term partnerships with. The list of brands that Blue Connections Australia represents, and supports are listed on our website.

Potential risks in operations and supply chains

Blue Connections’ focus is on potential risks to people rather than risks to our business entities.

As an Australian IT Services company, Blue Connections recognises that the industry in which it operates has the potential to be a risk area for modern slavery. Blue Connections is at risk of being directly linked to modern slavery as many of our suppliers have production sites in the Asia Pacific and China regions where human rights risks can be considered on the higher side.

In our supply chains both globally and in Australia, the risks of modern slavery are predominantly associated with our manufacturing suppliers who operate in countries where there is high volume of foreign migrant labour and potentially less legal entitlements for workers. These types of risks for these supply chains include poor working conditions and a lack of employment entitlements. Further risks could arise where a supplier may use parts or components that have been sourced from third parties (e.g., factories, or mining in the case of minerals and resources used to create the products we distribute). In such instances, there may be a strong focus on minimising production costs and poor labour practices. Identifying and addressing these potential risk scenarios both at a group and local level will be the priority of our supplier engagement activities over the next reporting year.

Within Australia, Blue Connections Australia has warehousing in Melbourne, Australia. As we maintain full control of our owned and operated services and warehousing operations, we believe there is low risk of modern slavery as we ensure a high level of working conditions. For all Blue Connections direct employees, we comply with the relevant industrial relations laws and workplace laws in each jurisdiction we operate.

Assessing and addressing the risk of modern slavery practices

Blue Connections IT has formal policies and procedures in place to promote ethical, open and transparent business conduct for our employees and suppliers. These policies and procedures apply to Blue Connections Australia. Blue Connections’ policies contribute to our commitment to prevent violations of human rights, including modern slavery. These policies include our Whistle-blower, Bribery and Corruption, Children in the Workplace, Code of Conduct, and Health and Safety policies. These policies include general remediation processes that address various adverse human rights impacts to allow people to safely raise concerns.

Blue Connections Australia will continue to review its policies to ensure that they include processes to also help address the risk of modern slavery in our operations and supply chains.

During our second reporting period, our focus has been on gaining a better understanding of modern slavery risks and how those risks may be present in our operations and supply chains. As part of our modern slavery due diligence, we have considered risk factors including the sector we operate in, the types of products we distribute, as well as the geographical locations where those products are manufactured.

Many of our suppliers are large multi-national companies who have robust modern slavery compliance measures already in place. We know that many of them have and are separately reporting on their modern slavery initiatives under the UK and Australian legislation.

During our second reporting period, we engaged with our Tier 1 suppliers to better understand their operations and supply chains. This involved developing and sending correspondence to our Tier 1 suppliers asking them about their modern slavery arrangements. This included asking them to notify us if they are aware or become aware of any modern slavery risks within their business. We also strongly encouraged each of our suppliers to have modern slavery controls in place. We also requested that suppliers provide us with their Modern Slavery statements (if they were required to provide one).

Measuring effectiveness of actions taken

Over the past 2 years Blue Connections, has focused on engaging with suppliers and understanding their supply chains. Blue Connections has reviewed the information it has received from each of its suppliers and from this, has built a stronger understanding of its supplier’s operations and supply chains. Blue Connections is yet to implement a formal process to review and assess its actions. Blue Connections recognises this analysis will be an ongoing and evolving process which it intends to develop over the next reporting period.

Blue Connections recently undertook an organisation wide Audit with International company Intertek to ensure our operations met all standards for Occupation Health and safety and Modern Slavery.

Blue Connections will continue to implement further measures to assess the effectiveness of its actions.

Ongoing Commitments

One of our commitments for the next reporting period is to continue to engage further with our suppliers and continue to develop measures to identify and address modern slavery risks in our operations and supply chains.

Continue to engage with our Tier 1 suppliers

We will continue to engage with our suppliers to better understand their modern slavery risks. This engagement will inform and help to develop our ongoing strategy for our modern slavery compliance framework.

Review of Modern Slavery Policy for Blue Connections

The Blue Connections’ Board has implemented a group wide Modern Slavery Policy. It outlines Blue Connections’ commitment to identifying and addressing risks of modern slavery. The policy described Blue Connections’ expectations for its personnel, and the standards we expect from those in our supply chain.

Some key parts of our policy include the following commitments:

  • adhering to applicable laws and regulations in the countries which we operate

  • continually engaging with our suppliers to better understand their supply chains and any potential modern slavery risks they face

  • continually engaging with our Personnel and suppliers to raise awareness and identify potential risks of modern slavery in Blue Connections’ operations and supply chains. This includes communicating with our suppliers regarding the actions Blue Connections would like them to take and how they can engage with Blue Connections on any modern slavery matters that arise

  • strongly encouraging our suppliers to have modern slavery controls in place (e.g., supply chain mapping, modern slavery due diligence exercises and policies)

  • requiring our suppliers to notify us of details of any actual or suspected occurrence or incident of modern slavery, and working with our suppliers to assess the issue and consider next steps

  • where modern slavery issues are identified, taking appropriate action

  • providing our Personnel with a non-discriminative work environment that is free from harassment or victimisation, and encouraging them to speak up about any human rights or modern slavery risks they become aware of

  • prohibiting engagement in any form of modern slavery, including child labour in its supply chains

Statement version and revision information

This statement was authorised by the Board of Directors, Blue Connections Pty Ltd, October 2021 and signed by Anthony Dunn in his capacity of Finance Director.