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).
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 operates nationally with physical offices in New South Wales, Queensland, Victoria and Western Australia, without international presence, does not own or control any other entities and has 70 employees.
SALA is a provider of:
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 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 recognises the complexity of Modern Slavery risk, and in particular the variety of ways in which it can manifest in operations and supply chains.
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.
SALA purchases goods and services from approximately 2,500 suppliers. In the year ended 31st March 2021, SALA spent approximately $192.6 million with suppliers in Australia and overseas, with our largest areas of spend being vehicle purchasing, maintenance, fuel and registration.
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 case of repeated or serious instances, we will give consideration to the 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:
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 the 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.
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 receive training annually on Modern Slavery and Human Trafficking and the requirements of the Modern Slavery Act 2018.
SALA is has introduced into place policies and procedures designed to ensure that:
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 in Fiscal Year 2021 which may include:
During this reporting period SALA implemented a Modern Slavery policy and all staff members signed a declaration that they understood and agreed to abide by this policy, in addition, all newly hired staff members went through an induction program which includes an introduction to our Whistleblower Procedure as well as compliance training, this has ensured staff engagement on modern slavery issues with potential suppliers up front to ensure that SALA’s position to modern slavery is communicated at the outset. This provides us with assurance that modern slavery is front of mind for our supplier.
SALA acknowledges that addressing the challenges of modern slavery is an evolving process and in Fiscal Year 2021 we will assess our effectiveness by:
The impact of COVID-19 on our operations resulted in all four offices being closed during Fiscal Year 2020 at various stages and employees directed to work from home until it was safe to return. As at the date of this statement two offices are 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 various periods 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.
As described above, SALA does not own or control other reporting entities. No consultation process was required.
This statement is approved by the Board of Directors on 29th September, 2021 and signed by the President of SALA – Masahiro Ozamoto.