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Modern Slavery Statement for the Financial Year ended 31 March 2020

This statement is made and published in accordance with section 13 of the Commonwealth Modern Slavery Act 2018, it sets out the risks and actions taken by Summit Auto Lease Australia Pty Ltd ABN 87 054 704 737 (SALA).

Group Structure

SALA was established on December 20th, 1996 and is a subsidiary company of Sumitomo Mitsui Auto Service Company Ltd (SMAS) incorporated in Japan.

It trades under the business name Summit Fleet Leasing and Management and its head office is at Unit 7, 36-48 South Street, Rydalmere NSW.

SMAS shareholders are

At the core of SMAS lies the Company’s Business Philosophy.  The Corporate Mission Statement is based on this philosophy and represents SMAS fundamental and ultimate value standard stating an “utmost respect for the individual” and placing a prime importance on integrity and sound management.

As a subsidiary company of SMAS, SALA shares its parent company’s core values and abides by them through its governance, policies and procedures.

SALA’s Business

SALA operates in New South Wales, Queensland, Victoria and Western Australia, without international presence, and has 76 employees.

SALA is a provider of:

SALA’s stance on Modern Slavery and Human Trafficking

SALA supports the principles of the Commonwealth Modern Slavery Act 2018 in the areas of Human Rights, labour standards, environment and anti-corruption measures.

SALA complies with the applicable laws and regulations covered within this Act through its governance, policies and procedures outlined in further detail below.

SALA believes that it has an ethical responsibility to promote human rights by showing respect for human rights through its own behaviour, and by sharing this ethos with its customers.

SALA is committed to maintaining and improving systems and processes to mitigate the risk that it might be involved, wittingly or unwittingly, in the commission of Modern Slavery and Human trafficking in any part of its operations, customers and supply chain (including contractors and suppliers), products, services and staff activities.

SALA expects its staff, suppliers and business partners to adhere to similar high standards and to take reasonable steps to ensure that other third parties they do business with adhere to similar standards.

Supply Chain

SALA performs due diligence on suppliers and contractors, which includes an analysis of the activity carried out and a detailed review of any publicly available information, in order to identify instances that may give rise for concern in relation to Modern Slavery and Human Trafficking.

SALA takes a collaborative approach to our relationship with our supply chain and encourages transparency by encouraging whistleblowers to report instances of unethical, unlawful or undesirable conduct in accordance with the Whistleblower Policy of SALA. Should issues be reported as a result of our due diligence, we will give guidance and support to our suppliers and contractors to help identify and work through an appropriate resolution.

In the instances of repeated or serious instances, we will give consideration to termination of our relationship accordingly.

Our supply chains include

SALA’s procurement activities take place in Australia and our Suppliers and Contractors are predominantly Australian based.

We expect all companies we engage with to ensure their goods, materials and labour-related supply chains:

In assessing risk within our supply chain, we consider the following risk factors:

  1. Supplier location;
  2. Nature of goods/services provided;
  3. The strength of our relationship with the supplier; and
  4. The level of corporate governance of the supplier.

Suppliers with evidence of non-compliance with the Modern Slavery Act 2018 in connection with SALA supply chains will be encouraged to follow the reporting procedure outlined within our Anti-bribery and Corruption Policy.

In any event of repeated or serious instances, we will give consideration to termination of our relationship accordingly.

As part of the on boarding and periodic due diligence reviews performed on customers, assessment is made to determine if they fall within the scope of the Modern Slavery Act 2018, and if so, a copy of their Anti-Slavery Statement is sought and retained.

Staff

All employees of SALA and contractors are encouraged to identify and report immediately via SALA’s whistle blower policy, without fear of retaliation, any conduct that the employee knows or reasonably believes would be contradictory to regulatory requirements or ethical standards, which include, but are not limited to internal policies and guidance in respect to human rights.

In addition, in order to ensure proper understanding of the risks posed by Modern Slavery and Human Trafficking, the employees and contractors of SALA will receive training annually on Modern Slavery and Human Trafficking and the requirements of the Modern Slavery Act 2018.

SALA’s policies and due diligence processes for modern slavery and human trafficking

SALA is currently putting into place policies and procedures  designed to ensure that:

  1. Its supply chain reflects SALA’s values and respect for the importance of the protection and advancement of human rights;
  2. There are improved due diligence processes in relation to modern slavery and human trafficking in its business and supply chain;
  3. It can identify the parts of its business and supply chains where there is a risk of modern slavery and human trafficking taking place, and implement steps it has taken to assess and manage that risk;
  4. The policies and procedures are effective in ensuring that modern slavery and human trafficking is not taking place in its business or supply chains or is at least reported so that an appropriate response can be implemented by SALA and its suppliers;
  5. There is adequate training about modern slavery and human trafficking available to its employees and suppliers; and
  6. It is the intention of SALA to establish a dedicated committee in Fiscal Year 2020 to address modern slavery in its supply chains and ensure continued compliance with the Act.

As this is our first year, we can see that there is more we can do to detect, manage and reduce the risk of modern slavery and human trafficking. Whilst we are confident that we operate in a relatively low risk business sector and our management and processes minimise the risk of modern slavery or human trafficking occurring, we are committed to further improvements and will continue to review and enhance our approach to addressing human rights risks by taking further steps which may include:

COVID-19

The impact of COVID-19 on our operations resulted in all four offices being closed at the beginning of the pandemic and employees directed to work from home until it was safe to return.  As at the date of this statement one office is still operating under COVID19 guidelines with some employees continuing to work remotely, whilst other employees have returned to the office.  COVID-19 had a profound impact on many of the manufacturers who supply the vehicles we purchase, resulting in the closure of their operations for a period causing prolonged delays in the supply of new vehicles for our customers. During this period, we continued to collaborate with customers and suppliers by extending the orders over time and avoiding varying contracts unreasonably or seeking discounts from suppliers.

Approval

This statement is approved by the Board of Directors on 21st December 2020 and signed by the President of SALA – Masahiro Ozamoto.