FY24 Modern Slavery Statement
This Statement is currently being reviewed and is not yet available on the Australian Government's modern slavery register
FY24 Annual Reporting Suite
This Modern Slavery Statement (Statement) has been prepared by Northern Star Resources Ltd ABN 43 092 832 892 (Northern Star) to meet the requirements of the Australian Modern Slavery Act 2018 (Cth) for the financial year ending 30 June 2024 (FY24).
Unless expressly stated otherwise, all references to 'our', 'we', 'us', the Company or Northern Star refer to the Group, as detailed on pages 12 and 13 in Our Corporate Structure. Please refer to the Glossary for the definitions of the capitalised terms used in this Statement.
The percentage figures disclosed in this Statement are subject to rounding and may not add to 100%.
The full 2024 Annual Reporting suite is available at www.nsrltd.com
FY24 Annual | FY24 ESR | FY24 Corporate | FY24 Modern Slavery |
Report | Reporting Suite | Governance Statement | Statement |
Cover photo: Steffi Milling, Geologist & James Thomas, Project Geologist at the Carosue Dam Operations solar farm, Kalgoorlie Production Centre
Acknowledgement of country
Northern Star acknowledges Traditional Owner groups whose land we are privileged to work on, and whose input and guidance we seek and value within the operation of Northern Star's business. We acknowledge their strong and special physical and cultural connections to their ancestral lands and pay our respects to their Elders, past and present.
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Modern Slavery Risks | 16 | |
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| Risk management | 16 |
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| Risk assessment | 16 |
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| Case study: Ongoing renewable energy supply chain assessment | 17 |
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| Our modern slavery risks | 18 |
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| Policies & frameworks | 22 |
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| Training & awareness | 25 |
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| Investigation & remediation | 30 |
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| Collaboration & engagement | 31 |
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Planned Actions for FY25 | 34 | |
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Glossary | 36 | |
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2 | Northern Star Resources Ltd FY24 Modern Slavery Statement | 3 |
Introduction
Highlights
81%
Introduction
Message from the Chair of the ESS Committee
Our Progress
Northern Star is committed to continuous improvement in all aspects of our business operations, and this extends to our commitment to take meaningful steps to identify and mitigate modern slavery risks and maintain responsible and transparent supply chains.
Progress against the planned actions in FY24 committed to in our FY23 Statement:
of key accountable employees have completed awareness training.1
Tier 2
& Tier 3
supplier identification pilot assessment completed. See
the case study on page 17.
10
audits completed on our Tier 1 suppliers' practices.
I am pleased to present Northern Star's FY24 Modern Slavery Statement, which outlines our commitment to mitigating the risk of modern slavery existing in our operations and supply chains.
We are proud of our efforts and continued improvements in this area: increasing the number of on-site audits conducted from previous years, maintaining a sustained focus on growing awareness and educating our employees and suppliers, and enhancing our modern slavery risk management approach.
In FY24 we focussed on advancing our efforts to understand and identify potential risks of modern slavery within our supply chains. We expanded our due diligence practices deeper into our supply chain. An example is the detailed assessment we carried out in relation to the Tier 2 and Tier 3 suppliers of our own Tier 1 supplier of solar panels. The experience and lessons learnt during this pilot assessment will be applied to other suppliers in our supply chain in coming years.
We believe continued advancements are required to achieve lasting impact in this area, and we support the Australian Government's work to further strengthen the Modern Slavery Act 2018 (Cth) (the Act).
We did not identify any suspected or actual instances of modern slavery in FY24 through our due diligence efforts. We continue to strive for year-on-year improvements to our approach and
in FY25 will prioritise improving due diligence response rates through sharing information and resources to build knowledge and capacity in our suppliers, reviewing our Supplier Code of Conduct and educating our suppliers to understand compliance with its requirements, and ongoing assessment of the effectiveness of our actions.
Sally Langer
Chair - Environmental, Social & Safety Committee
Northern Star Resources Ltd 21 August 2024
Expand our human rights training to include more concise general awareness modules for all employees and contractors.
Improve the data we collect and analyse in relation to our supply chain, leading to more SAQ2 responses and a higher understanding of our supply chain.
Strengthen our understanding of our supply chain through assessment of Tier 2 suppliers.
Contribute to the upcoming review of the Act.
Develop a Frequently Asked Questions document to assist our suppliers in better understanding their obligations under our Supplier Code of Conduct.
Increase focus on supplier ESG screening in terms of assessment of information received, to improve the understanding of our supply chain, and potentially improve the quality of our supply chain to further mitigate modern slavery risks in our supply chain.
Complete the SAQ process on our suppliers who were identified as having a medium risk in FY23 risk assessment.
Assist the Board and Executive in enhancing their oversight of modern slavery risks and mitigation actions.
In |
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progress |
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75+25 | ||
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Complete |
| Questionnaire |
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Complete |
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In | & tender |
requirements | |
progress | |
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Complete | Questionnaire |
on page 27 for | |
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Management | |
progress | on page 16 for |
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1 The total number of key accountable employees at 30 June 2024 is 338. The remaining employees have until 31 December 2024 to complete the training.
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| Jundee processing plant, |
4 | Northern Star Resources Ltd FY24 Modern Slavery Statement | Yandal Production Centre |
- Supplier's own self-assessment questionaire.
- Engagement with our suppliers did not identify any common or frequently asked queries that would be beneficial to incorporate into a formal document. Instead, we will commence Supplier Code of Conduct audits and checks to confirm understanding of the document by our suppliers.
5
About this Statement
About this Statement
Consultation with Group entities
This Statement
As prescribed by the Act, this Statement covers:
- reporting entities covered by this Statement;
- company structure, operations and supply chain;
- modern slavery risks in our operations and supply chain;
- actions we have taken to assess and address those risks, including audits and corrective actions;
- how we assess the effectiveness of such actions;
- how we consult with our subsidiary entities; and
- other information we consider relevant regarding our efforts to combat modern slavery in our operations and supply chains.
This Statement has been approved for release by the Northern Star Board of Directors and is current as at 21 August 2024. The Statement is a joint statement by Northern Star for itself and all of its wholly owned subsidiaries (the reporting entity), in accordance with section 14(2)(d) (ii) of the Act.
Northern Star prepared this Statement in consultation with each other reporting entity that this Statement covers (all of
procurement, and social performance). The Statement was reviewed in detail, and recommended to the Board for approval, by the Environmental, Social & Safety (ESS) Committee of the Board.
This Statement is available on our website at: www.nsrltd.comand via the Australian Government's Online Register of Modern Slavery Statements at www.modernslaveryregister.gov.au.
which have three common directors with Northern Star), in accordance with section 14(2)(c) of the Act. Consultation was undertaken by our Group-wide Modern Slavery Working Group, which comprises members of the Procurement, Legal, Company Secretarial and ESG Engagement teams, who engaged with key areas of the business (including human resources,
Stuart Tonkin
Managing Director & CEO
Northern Star Resources Ltd 21 August 2024
Mandatory Criteria
This table outlines where the mandatory reporting criteria required by the Act have been addressed in this Statement:
Emeka Odiaka, Geologist at Carosue Dam Operations, Kalgoorlie Production Centre
Criteria
Identify the reporting entity.
Describe the structure, operations, and supply chains of the reporting entity.
Describe the risks of modern slavery practices in the operations and supply chains of the reporting entity, and any entities that the reporting entity owns or controls.
Describe the actions taken by the reporting entity and any entity that the reporting entity owns or controls, to assess and address those risks, including due diligence and remediation processes.
Describe how the reporting entity assesses the effectiveness of such actions.
Describe the process of consultation with any entities that the reporting entity owns or controls.
Any other relevant information.
Section of this Statement |
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About this Statement | pages 6-7 |
Our corporate structure | pages 12-13 |
About Northern Star Resources Ltd pages 8-15
Modern Slavery Risks | pages 16-18 |
Action taken to address risks | pages 20-31 |
Assessing effectiveness | pages 32-33 |
Consultation with Group entities | page 7 |
Introduction | page 4 |
Planned Actions for FY25 | page 34 |
6 | Northern Star Resources Ltd FY24 Modern Slavery Statement | 7 |
About Northern Star Resources Ltd
About Northern Star Resources Ltd
This section details Northern Star's business, operations and supply chains to provide context on potential interactions with modern slavery.
Our Purpose
To generate superior returns for our shareholders, while providing positive benefits for our stakeholders, through operational effectiveness, exploration, and active portfolio management.
Our Company
Northern Star is one of the world's ten largest gold miners, with operating mines and exploration programs located in three production centres in the two world class jurisdictions of Australia and Alaska in the United States of America. Northern Star was incorporated in May 2000, and is a public company limited by shares listed on the Australian Securities Exchange (ASX: NST).
Northern Star Resources Ltd is the parent company for the Group. Full details of the organisational structure can be found on pages 12 and 13.
In our operations we explore for, extract, process and sell gold, as illustrated below.
Our STARR Core Values
Our STARR Core Values are integral to the working lives of all our workers, across all our operations, and form the foundation of everything we do as a business.
Figure 1 Northern Star's Value Chain
Project Development
Exploration |
| Mining |
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Reclamation & Closure | Processing |
Gold dore production
Customers (Refineries)
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Results |
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Respect |
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8 | Northern Star Resources Ltd FY24 Modern Slavery Statement | 9 |
About Northern Star Resources Ltd
Our workforce
At 30 June 2024 our workforce comprised 7,019 workers, of which 4,044 were employees and 2,975 were contractors. Most of our workforce is employed on a permanent basis, with less than 3% engaged on casual contracts.
Our Operations
Northern Star owns and operates three gold production centres:
Kalgoorlie and Yandal in Western Australia and Pogo in Alaska.
Figure 2 Worldwide Operations | Figure 4 Australian Operations |
A detailed breakdown of our workforce information can be found in our FY24 Environment & Social Responsibility - People & Culture Disclosure.
Employees by
employment type
Gender
demographics
Local employment
- Pogo
Local employment
- Kalgoorlie (excl. Carosue Dam)
96% Full-time
2% Casual
2% Part-time
0% Other
76.2% Male
23.4% Female 0.4% Non-binary
56.8% Alaska
38.4% Other US
States
4.8% Other
83.1% Residential
16.9% Other
Figure 3 North American Operations
Alaska
Fairbanks 1
Delta Junction
Anchorage
JUNEAU
Pogo Production Centre
1. Pogo
| Halls Creek | Northern |
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Nanutarra |
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Newman |
| Alice Springs |
| Western |
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Wiluna |
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Leinster |
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Kalgoorlie/Boulder6 5 |
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Coolgardie | 7 |
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PERTH |
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Yandal Production Centre | Kalgoorlie Production Centre | Tanami Project | |||
1. | Jundee | 4. | Carosue Dam | 8. | Central Tanami |
2. | Bronzewing | 5. | Kanowna Belle |
| Project JV (50%) |
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3. | Thunderbox | 6. | KCGM | 9. | Tanami Regional |
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10 | Northern Star Resources Ltd FY24 Modern Slavery Statement | 11 |
About Northern Star Resources Ltd
Our corporate structure
Yandal Production Centre
Kalgoorlie Production Centre
Pogo Production Centre
Tanami Exploration Projects
Infrastructure
Ownership of Shares
Operating Entity/Manager
Ownership of Project Assets
Northern Star Resources Ltd
ACN: 092 832 892
Northern Star Mining Services Pty Ltd
ACN: 149 632 968
Northern Star (Holdings 2) Pty Ltd
ACN: 655 582 415
Northern Star (Bronzewing) Pty Ltd
ACN: 108 513 113
Northern Star (Saracen) Pty Ltd
ACN: 009 215 347
1335088 B.C. Ltd
Northern Star (Yandal
Consolidated) Pty Ltd
ACN: 614 347 303
Northern Star (Echo Mining) Pty Ltd
ACN: 120 974 567
Northern Star (Sinclair) Pty Ltd
ACN: 635 649 606
Northern Star (Thunderbox) Pty Ltd
ACN: 107 154 727
Northern Star (Carosue Dam) Pty Ltd
ACN: 116 649 122
Northern Star (MKO) Pty Ltd
ACN: 135 597 634
Northern Star (Talisman) Pty Ltd
ACN: 601 140 185
Northen Star (Bundarra) Pty Ltd
ACN: 130 964 162
Northern Star (SR Mining) Pty Ltd
ACN: 151 605 417
Yandal
Northern Star (KLV) Pty Ltd
ACN: 004 990 274
Northern Star (Kanowna) Pty Limited
ACN: 010 511 789
Kanowna Mines Pty Limited
ACN: 053 530 037
GKL Properties Pty Limited
ACN: 009 643 234
Northern Star (South Kalgoorlie) Pty Ltd
ACN: 009 271 532
Northern Star (Holdings) Pty Ltd
ACN: 626 052 784
| Northern Star (Saracen Goldfields) |
| Northern Star (Saracen Kalgoorlie) |
| Pty Ltd |
| Pty Ltd |
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| ACN: 637 156 579 |
| ACN: 008 143 137 |
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| Northern Star (HBJ) Pty Ltd |
| Northern Star (Hampton Gold Mining |
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| Areas) Limited | |
| ACN: 127 026 519 |
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| Northern Star (Alaska) |
| Northern Star |
| Incorporated |
| (Alaska) LLC |
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50%
50%
Kalgoorlie Consolidated Gold
Mines Pty Ltd
ACN: 009 377 619
Northern Star (Pogo) LLC
Northern Star (Pogo Two) LLC
Kalgoorlie
Pogo
Stone Boy Inc
Northern Star (Tanami) Pty Ltd
ACN: 603 860 831
Northern Star (GMK) Pty Ltd
ACN: 007 706 863
50%
CTP JV Pty Ltd
ACN: 648 942 652
Northern Star (Power) Pty Ltd
ACN: 065 116 841
Northern Star (NPK) Pty Ltd
ACN: 066 584 807
50%
Goldfields Power Pty Ltd
ACN: 062 186 243
Central Tanami
Project Joint
Venture 50%
Tanami 100%
Power station
asset
50%
12 | Northern Star Resources Ltd FY24 Modern Slavery Statement | 13 |
About Northern Star Resources Ltd
Our supply chain
Northern Star's operations are supported by a centralised Group procurement team that coordinates a global
supply chain with 3,219 active4 Tier 1 suppliers. Our supply chain reflects the location of our operations, with most of our Tier 1 suppliers located within Australia and the United States of America. In FY24, Northern Star spent
- total of $3,925,772,4745 with 2,654 Tier 1 suppliers.
We prioritise use of local suppliers6 where possible while ensuring our supply chain risks are mitigated through strong regional relationships and ongoing analysis of our supply chain. In FY24, $746M representing 19% of total Group spend was to suppliers located locally to our Kalgoorlie, Yandal and Pogo Production Centres.
A focus on diversification of suppliers across our supply chain aids to further mitigate risk associated with goods and services procurement, as illustrated below. In certain circumstances, a reduction in the number of Tier 1 suppliers also assists in mitigating risk. The procurement team is focussed on reducing the number of Tier 1 suppliers where possible and appropriate, to improve efficiencies and reduce risk.
73+24 | ||
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| Australia |
| 1927 | |
| 73% | |
Locations of |
| USA |
Tier 1 suppliers | 641 | |
engaged in FY24 | 24% |
International 86
3%
FY24 Procurement spend by supplier location.
Total spend
$3.9B Canada
5%
Alaska
4.5%
Other USA
6.7%
Other International
(Ireland, Belgium, New Zealand,
Netherlands, Singapore,
South Africa, United Kingdom)
0.1%
Other Australia
9.7%
Western Australia
74%
In previous years we concentrated our assessment of modern slavery risks to Tier 1 suppliers only. Modern slavery can exist at any point in our supply chain, including Tier 2, Tier 3 or any other suppliers deeper into our supply chain. It is important
that we understand the risks of potential modern slavery at Tier 2 and below. This ensures we are taking all reasonable measures to identify any instances of modern slavery within our supply chain. In FY24 we worked with one of our Tier 1 suppliers in a pilot assessment of our Tier 2 and Tier 3 suppliers to better understand the risk and how Northern Star may apply a similar assessment across our wider supply chain. Further information is provided in the case study on page 17.
4
5
6
Active suppliers are those who have issued an invoice within the previous 24 months, to 30 June 2024.
Spend that is related to the provision of goods and services to Northern Star, under the direct influence and management of the procurement department. This excludes spend associated with matters such as royalties, taxes and employee salaries.
Local suppliers means suppliers based in selected post code boundaries in and around the Kalgoorlie region for our Kalgoorlie Production Centre, suppliers based in selected postcode boundaries in and around our operations for our Yandal Production Centre and suppliers based in the State of Alaska for our Pogo Production Centre.
14 | Northern Star Resources Ltd FY24 Modern Slavery Statement | 15 |
Modern Slavery Risks
Modern Slavery Risks
This section provides an overview of Northern Star's approach
Case Study: Ongoing renewable energy supply chain assessment
to modern slavery risk assessment and management practices.
Due to the global demand for solar panels and other green energy related infrastructure, there is some concern about the origin and manufacturing
associated with the manufacturing of that part of our solar panel supply chain.
Risk management
Northern Star is committed to effective identification, monitoring and management of strategic risks presented by our operational and corporate activities. Our risk management activities are guided by Northern Star's risk management framework, comprising a Risk Management Policy and Standard, enterprise risk and assurance system. The framework is aligned to ISO 31000 Risk Management Guidelines and provides a consistent approach to the assessment, management and reporting of risks across Northern Star.
The framework is overseen by the Audit
- Risk Committee, which, as at 30 June 2024 comprised of four of the Company's independent Directors. Modern slavery risks are assessed within this risk framework and are subject to annual reviews by our Chief Financial Officer in leading the procurement and risk functions within Northern Star.
Risk assessment
We assess the modern slavery risks in our operations and supply chains using an inherent risk assessment based on a combination of country risk, product risk, and total spend, with relative weightings appropriate to our risk profile. The assessment targets Tier 1 suppliers each with an annual spend over $100,000 and assesses the risk of modern slavery based on the prevalence of modern slavery within the supplier's country of operation and primary product/service provided by the supplier.
In FY24 we completed an inherent risk assessment on all Tier 1 suppliers onboarded between 1 June 2023 to 31 December 2023, who had not been captured by previously completed inherent risk assessments. A total of 85 suppliers were assessed, with 0 returning
a critical risk rating, 16 returning a high risk rating, 54 returning a medium risk rating, and 15 returning a low risk rating.
The inherent risk ratings inform the type of due diligence undertaken for each Tier 1 supplier. Those returning high or critical inherent risk assessment are flagged for immediate participation in self-assessment questionnaires (SAQs) and potential audits. Those Tier 1 suppliers with a medium or low inherent risk rating are required to participate in SAQs at varying frequencies. The SAQ results help to inform selection of Tier 1 suppliers to be audited. Full details on assigning due diligence practices is provided
on pages 26 and 27.
We intend to complete an inherent risk assessment around July each year to capture any new Tier 1 suppliers onboarded, or Tier 1 suppliers who have met the $100,000 spend threshold during the previous 12 months.
of renewable energy components and the risk of modern slavery within these supply chains.
Northern Star is currently expanding its renewable energy installations across multiple operations in Western Australia, including installation of solar panels at one of our Yandal operations. Given the general concern around modern slavery existing in renewable product supply chains, we approached the Tier 1 supplier responsible for our solar array installation and requested their support in undertaking a deep dive into their supply chain, representing Northern Star's Tier 2 suppliers. The aim of this pilot assessment was to understand the modern slavery risk in the supply chain for the production and supply of the solar panel components being installed at our operations. We examined a subset of the total supply chain related to the production, supply and delivery to our operations of the solar panels only.
The Tier 1 supplier was highly engaged and cooperated fully with our independent external consultant to map their suppliers (i.e. our Tier 2 suppliers) and verify risks of modern slavery within the solar panel supply chain. In our initial assessment the Tier 1 supplier identified six Tier 2 suppliers related to solar panel procurement, all based in Australia, one of which was a third party distributor. This necessitated us also examining
the suppliers to that Tier 2 supplier (i.e. our Tier 3 suppliers), to ensure we captured modern slavery risks
With assistance from our Tier 1 supplier, our independent external consultant approached the distributor (our Tier 2 supplier) about completing a similar assessment, looking at their suppliers of solar panel components and manufacturing (our Tier 3 suppliers). Once again, our request was received positively, and full support was given. Following a supply chain mapping and inherent risk assessment process we were able to identify 31 manufacturing plants and component suppliers (our Tier 3 suppliers) based in China with a critical or high risk of modern slavery.
We are continuing to work collaboratively with our Tier 1 supplier to further investigate the risks of modern slavery at these 31 facilities. Initially, this will be via a detailed SAQ process undertaken on a selection of ten suppliers, verified by an independent external consultant. We have shared the questionnaire we currently use with the Tier 1 supplier, for their
use both now and in any future modern slavery due diligence they decide to undertake.
It was also identified that the Tier 3 supplier assessment omitted transportation and shipping companies related to solar panel delivery from the supply chain mapping and inherent risk assessment process. Further work is being done to rectify this. Details on the verification work and transportation and shipping related Tier 3 suppliers will be provided in the FY25 Statement.
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Ron Webb, Process Controller, KCGM, Kalgoorlie Production Centre
Tier 3 suppliers
16 | Northern Star Resources Ltd FY24 Modern Slavery Statement | 17 |
Modern Slavery Risks
Our modern slavery risks
We use the UN Guiding Principles on Business and Human Rights (UNGPs) and its continuum of involvement (cause, contribute, directly linked) to inform our understanding of exposure to modern slavery risks within our operations and supply chain.
Cause | A company can cause modern slavery | Hypothetical example in the |
| where its actions directly result in | extractive industry |
| modern slavery occurring. | A company exploits workers at their |
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| mine site by withholding pay. |
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Contribute | A company can contribute to | Hypothetical example in the |
| modern slavery where its actions or | extractive industry |
| omissions facilitate or incentivise | A company negotiates excessively low |
| modern slavery. | |
| rates with a labour hire supply company | |
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| that can only be met if the labour hire |
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| company exploits employees. |
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Directly linked | A company may be directly linked to | Hypothetical example in the |
| modern slavery through the activities | extractive industry |
| of another entity it has a business | A company purchases mobile phones |
| relationship with. For example, a joint | |
| or computers from a supplier that were | |
| venture partner or supplier. | produced by a sub-supplier with cobalt |
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| sourced from mines using forced labour. |
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Haul Truck at Thunderbox Operations, Yandal Production Centre
Operations risk
Our corporate office, mine sites, and exploration projects are exclusively located in Australia or Alaska in the United States of America. The known prevalence of modern slavery in these jurisdictions is relatively low risk, in part due to companies being subject to robust labour laws protecting employees from being exploited by employers. Despite this, the potential for instances of modern slavery in the gold mining industry within these countries still exists.
We could contribute to modern slavery at our operations if we were to negotiate excessively low rates with a labour
hire supply company. This could lead to the employees of the labour hire supply company receiving exploitative pay rates. Northern Star does not conduct this practice.
We could be directly linked to modern slavery at our operations if a cleaning contractor were to utilise forced labour or debt bondage over its employees. Northern Star has not observed any conduct or obtained any information through its experience on site or in discussion with its cleaning contractors to suggest that its cleaning contractors utilise forced labour or debt bondage over their employees.
Our operations are subject to legislation, human resources policies, management practices and procedures that govern labour hire practices across our business. This compliance is supported by access to training and grievance mechanisms.
Supply chain risk
Our highest exposure to modern slavery risks exists in our supply chain, through which we procure a variety of goods and services. Some countries have a higher prevalence of modern slavery and where our supply chain exists within such countries, Northern Star is at risk of modern slavery occurring within its supply chain.
Modern slavery can also result in supply chains if companies put commercial pressure on suppliers to such a level that the supplier exploits its workers by requiring long hours and low rates of pay.
We could contribute to modern slavery within our supply chain if we were to place impractical expectations on a supplier regarding delivery timeframes for particular goods, that could only be met by exploiting workers. Northern Star does not conduct this practice.
We could be directly linked to modern slavery if we were to source uniforms or personal protective equipment, such as gloves, from a supplier who uses forced labour, even if this occurred within our deeper supply chain. Northern Star's continuing efforts in identifying risks and the selection of Tier 1 suppliers to be audited is intended to ensure that this risk in our supply chain is mitigated. To date no suspected or actual instances of modern slavery have been identified.
Understanding where modern slavery risks may exist in our supply chain is imperative to being able to identify any actual instances of modern slavery. To better understand our supply chain, we conduct due diligence practices with support from an independent external consultant on our Tier 1 suppliers and select Tier 2 and Tier 3 suppliers.
18 | Northern Star Resources Ltd FY24 Modern Slavery Statement | 19 |
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Northern Star Resources Ltd. published this content on 21 August 2024 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on September 04, 2024 at 10:46:01 UTC.