Criteria | Act Requirement |
Threshold | AMSA is an Australian Entity |
Threshold | AMSA has a Consolidated Revenue of at least $100m in the reporting period |
1. Identification | Requirement: Identify the reporting entity |
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2. Organisation | Requirement: Describe the reporting entity’s structure, operations and supply chains |
A. Structure | General Structure AMSA’s organisational structure consists of: - the AMSA Board, appointed by the Minister for Infrastructure, Transport and Regional Development, comprised of:
(i) Chairperson (ii) Deputy Chairperson (iii) CEO (iv) a person occupying an office in the portfolio department; and (v) five other members. - the Executive team, and
- five operational and service areas:
(i) Operations Division (ii) Response Division (iii) Policy and Regulation Division (iv) Corporate Services Division; and (v) Future Operations Taskforce.
Australian Business Number AMSA’s hold the ABN 65 377 938 320 number on the Australian Business Register. AMSA does not own or control any other entities. Registered office and locations AMSA head office is 82 Northbourne Ave Braddon ACT 2612 AMSA has another 20 office locations across Australia. |
B. Operations | Primary Role AMSA is Australia’s national agency responsible for safety of commercial vessels and ships, preventing and responding to ship based marine pollution and marine search and rescue. AMSA’s primary role is to: - promote maritime safety and protection of the marine environment
- prevent and combat ship-sourced pollution in the marine environment
- provide infrastructure to support safe navigation in Australian waters
- provide a national search and rescue service to the maritime and aviation sectors
- provide, on request, services to the maritime industry on a commercial basis
- provide, on request, services of a maritime nature on a commercial basis to the Commonwealth and/or states and territories.
AMSA has a role in ensuring international conventions such as to the Safety of Life at Sea (SOLAS) and the Maritime Labour Convention (MLC) are maintained while international vessels are in Australian waters. Employees and representatives AMSA has approximately 454 employees, including a permanent representative in London, United Kingdom. AMSA also delegates powers to officials within relevant State maritime agencies and police forces to enable compliance activities. Countries of operation While AMSA is primarily based in Australia and servicing Australia’s territorial waters, it also: - conducts education and training campaigns within the Pacific region
- assists in regional search and rescue activities where requested; and
- is responsible for conducting flag State control inspections (Australian ships) in overseas ports; and
It has 21 offices throughout Australia. Investments AMSA has investments with several top credit rated banks to provide a ready source of income in the event of a major pollution incident. AMSA’s Stakeholders AMSA’s stakeholders include, but are not limited to: - our regulated community - domestic commercial vessel industry, shipping industry and seafarers
- Maritime service providers and partners—including navigation, pollution response, maritime and aviation search and rescue and contractors
- Australian Government, state and territory governments and their agencies
- International maritime community; and
- the Australian community
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C. Supply chain | Types of supply chains AMSA’s supply chains are with various suppliers and specialists from Australia and internationally, including those with expertise in search and rescue, environmental emergencies, maintaining aids to navigation, and regulating domestic commercial vessels and international vessels entering Australian waters. Control of supply chains Supply chains are controlled with strict contracting arrangements as defined by the Commonwealth Procurement Rules. Suppliers to AMSA are required to comply with any laws, statutes, regulations, by-laws, ordinances, or subordinate legislation. Disclosures: AMSA contracts valued at or above AUD$400,000 (GST inclusive) are reported on AusTender: https://www.tenders.gov.au/. AMSA contracts valued at or above AUD$100,000 (GST inclusive) are published on the AMSA website biannually as required under the Murray Motion: https://www.amsa.gov.au/about/reporting-and-accountability/tenders-and-contracts. Major suppliers Major services are listed in the table below. These services provide long term and stable supply, enabling AMSA to achieve its objectives. Major service required | Source country (where known) | Aerial Search and Rescue Services | Australia based | Emergency Towage Capability and Aid to Navigation (AtoN) maintenance through a dedicated vessel | Australia based | Travel Services | Australia and international using the whole of Government travel arrangements | Labour hire for call centre ICT and other services | Australian suppliers used for Australian based positions | Contractors for the construction and maintenance of AtoN | Australia based | Material suppliers to contractors for construction of AtoNs | Australian and international including the Netherlands, Singapore, Japan, China and United Kingdom | Provision of office services and supplies, such as cleaning and office furniture | Australia based (WINC is the primary supplier for office supplies) | Provision of corporate clothing | Australian based contractor with potential international supply chains | Provision of IT equipment and supplies | Australian distributors using international companies (Dell, Apple, CISCO, HP, Polycom) |
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3. Risks | Describe the risks of modern slavery practices in the operations and supply chains of the reporting entity and any entities it owns or controls |
| AMSA’s operations and supply chains cross many industries and sectors from call centre labour hire to search and rescue operations, stationery to construction of Aids to Navigation (AtoNs). These industries and sectors have complex multi-tiered downstream supply chains that span various industries and countries. AMSA has conducted a risk assessment on major contracts and supply chains. This assessment is based on the following risk matrix: AMSA Risk Assessment Risk1 | Contracts/supplies | Description | Very Low | - AMSA’s direct operations (i.e., employees)
- Travel Services
- Aerial Search and Rescue
- Emergency Towage Capability
- Dedicated AtoN maintenance
- General AtoN maintenance (various contracts)
- Corporate clothing
- Office furniture
- International sector of the maritime industry
| AMSA has effectively eliminated the risks associated with these contracts /supplies through various means including: - AMSA’s Enterprise Agreement
- Whole of Government arrangements (including panels)
- Generic contractual terms and conditions (including modern slavery clauses)
- Strict procurement activity in accordance with the Commonwealth Procurement Rules
- Working closely with suppliers to address any modern slavery risks
Risks associated with the international sector of the maritime industry are addressed through the Maritime Labour Convention 2006 (the Convention) which sets out standards and regulations for the working and living conditions of seafarers. Note: AMSA is satisfied that, through its operations under the Maritime Labour Convention and the Fair Work Act, that the risk potential to cause, contribute to or be directly linked to modern slavery is very low. | Low | - Materials supplied for AtoN maintenance
- Search and rescue and emergency towage supplies
| A low risk exists regarding parts of vessels that AMSA uses and goods procured overseas (i.e., equipment, vessel parts, unique building materials/minerals etc) – they may include elements of indentured labour. | Moderate | - Provision of ICT equipment and supplies
| The industry which manufactures computer components has a history of indentured labour and servitude which AMSA is aware of. AMSA will continue to look to minimise this risk over time. | High | Nil | N/A | Extreme | Nil | N/A |
It is unlikely that AMSA’s current known and immediate supply chain has risks which meet the threshold for serious exploitation as defined by the Act. Appendix 1 describes a list of modern slavery indicators which can be used to identify the risks of our major suppliers. They consider: - Sector and industry risks
- Product and service
- Geographic risk
- Entity risks
The result of assessing the indicators and applying the Department of Home Affair’s Cause, Contribute and Linked (CCL) model is an internal risk and control table which AMSA will update as it improves its awareness and understanding of the risk of modern slavery. AMSA acknowledges that: - visibility of the risks of modern slavery practices in our full downstream supply chains is limited
- modern slavery risks to AMSA will change over time as operational requirements change and our understanding of our supply chains improves; and
- identified contracts/supply chains include a risk that there may be links to modern slavery further down the supply chain that are outside of AMSA’s control and that are not visible to AMSA.
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4. Controls | Describe the actions taken by the reporting entity and any entities it owns or controls to assess and address these risks, including due diligence and remediation processes |
| Generic Controls AMSA has a range of controls to ensure that where possible our suppliers do not contribute to the risk of modern slavery, including: - inclusion of terms and conditions relating to modern slavery in AMSA request for tender (RFT) and evaluation documentation
- use of AMSA contract terms and conditions by preference identifying specific legislative compliance requirements
- utilising whole of government purchasing agreements and panels including Travel, Digital Marketplace and Fleet leasing
- specific onsite contract management and monitoring of major contracts; and
- specific thresholds established to determine appropriate levels of contract management
Due Diligence and Remediation Process Where a risk of modern slavery is identified AMSA will continue to provide education to staff on any potential risks/impacts and possible controls. This may include closer due diligence over suppliers, any subcontractors and major suppliers. AMSA continues to identify ongoing areas of concern to determine any specific areas that should be more closely monitored, including additional clauses in contracts and other procurement documentation as appropriate. AMSA processes and procedures have helped to assess and identify any potential risks in our approaches to market, contracts and supply chains. Whilst no specific risks or issues have been identified, AMSA is confident that our controls ensure that there is a continued very low risk of modern slavery - and that where risks are present - they will be identified and mitigated. |
5. Evaluation | Describe how the reporting entity assesses the effectiveness of actions being taken to assess and address modern slavery risks |
| AMSA has implemented two key actions - outlined in our first Modern slavery Statement: Actions from 20/21 Statement | Action Taken | Effectiveness of Action Taken | 1. The Procurement Team will develop an additional module in the procurement training program to help staff identify potential modern slavery risks, and will educate applicable staff on: - what modern slavery is
- what modern slavery looks like in Government supply chains
- what AMSA can do to further address modern slavery risks, and
- how to report concerns about modern slavery practices.
| AMSA has included reference to Modern slavery in the procurement training program. Training covers new clauses added to the RFT and contract documents and explains the need to address the risks of Modern slavery practices. | AMSA is confident that there is an adequate understanding of what Modern slavery means, and how to address any related issues. No non-compliances have been identified during tender processes over the reporting period. | 2. In the future AMSA will look to: - streamline and further embed modern slavery considerations into procurement practices
- harmonise data collection and reporting on modern slavery risks and actions to capture, analyse and report with a higher degree of granularity
- undertake more detailed mapping of suppliers, including identification of major shared suppliers
| AMSA continues to streamline and update related procurement processes. If evidence is found of modern slavery AMSA will capture data and report these activities to Australian Border Force as required. | No instances of modern slavery identified within current contracts or AMSA’s supply chain over the reporting period. |
Continuous improvement and future actions AMSA: - will identify occurrences of modern slavery through the specific clauses contained within Approach to Market documents (sourced through Department of Finance ‘Clausebank’). In addition, AMSA contract managers will continue to work with current providers to minimise any issues relating to modern slavery, supported by the Procurement Team
- is committed to providing ongoing procurement training sessions to relevant staff, including information on modern slavery
- maintains a list of potential risks in an internal modern slavery risk and control table, strengthening AMSA’s understanding of, and capacity to, address and mitigate modern slavery risks
- continues to review policies and procedures and consider amendments to include references to modern slavery, including procurement and contract templates
- will establish a mechanism within contracts to support confidential reporting of modern slavery risks and incidences in operations and supply chains
- will provide an approximate breakdown on the largest areas of expenditure, and specific actions implemented in these areas to address modern slavery; and
- will develop specific metrics to demonstrate our performance addressing occurrences of modern slavery and other harmful practices if required.
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6. Consultation | Describe how the reporting entity consulted on its statement with any entities it owns or controls |
| AMSA does not own or control any other entities. |
7. Relevant Information | include information that you think is relevant |
| AMSA has identified our work with the Maritime Labour Convention in the risk assessment under Criterion 3 - Risks. |