Natural Solar Modern Slavery Policy 2021

Natural Solar Pty Ltd ABN 79 160 373 688

Voluntary Statement – Modern Slavery – September 2021

Overview

Natural Solar Pty Ltd ABN 79 160 373 688 (NS) is an Australian private company which was incorporated on 9 September 2012.

NS is Australia’s largest installer of residential solar batteries. In addition, NS focusses on procurement, supply and installation of commercial and industrial scale solar and battery systems.

This statement, made by NS, provides an overview of the actions and undertakings taken by NS to address modern slavery risks in its business and supply chain for the year ending 30 June 2021.

NS is not required to undertake or issue a statement as it does not meet the revenue threshold of the Modern Slavery Act 2018 (Cth) (the Act). It has however chosen to issue this statement on a voluntary basis. This statement has not been formally submitted to Australian Border Force.

Operational Structure

NS is structed as a single operational entity which undertakes sales, administration, engineering/design/project management, installation and maintenance functions.

NS has its head office in Sydney. It maintains branch offices in Brisbane, Melbourne and Adelaide.

In addition to the inhouse qualified electrical team, NS also engages the services of suitability qualified sub-contractors for delivery of its services and installations across Australia.

Modern Slavery Risk in the Operation and Supply Chains of NS

NS’s largest purchases are of solar equipment and batteries, most of which are manufactured overseas. On an international scale NS is a relatively smaller customer of the manufacturers of solar equipment and, to that end, has little or no influence over those manufacturers and their policies.

The large manufacturers are compliant with the equivalent legislation of the Act in their jurisdiction. For these reasons, NS believes that the modern slavery risks in the larger manufacturers is low.

In respect of smaller components (i.e. less value-add components), where price is the key driver of sales, there is an increase of modern slavery risk. NS has mitigated this risk by procuring these components from large suppliers which are compliant with the Act.

Modern Slavery Risk Mitigation Action in the Supply Chains

NS Supply chains

Tier 1 – Major Suppliers (85% of supply chains)

All major suppliers have provided Modern Slavery and company policy statements which have been reviewed by NS’s board.
NS has confirmed that all major suppliers exceed the $100M revenue threshold and are therefore required to have a publicly available Modern Slavery Policy Statement.

Tier 2 – Distributors and other suppliers (10% of supply chains)

All Tier 2 suppliers have provided Modern Slavery and company policy statements which have been reviewed by NS’s board.

Tier 3 – Minor Suppliers (5% of supply chains)

Reviewed existing company policies and statements where applicable and educated those who do not have formalised policies in place of the importance of having such a policy and requesting them to start the process of preparation of a policy.
Consider moving away from minor suppliers who do not have modern slavery policies and procuring from larger companies who exceed the $100million threshold which are mandated to have a policies or entities which have voluntarily participated.

Additional Actions

NS is taking the following actions to assess and address risks associated with modern slavery:

Commitment to train senior management and other key staff members in relation to modern slavery risk in relation to supply chain. .
Continuous consideration and evolution in relation to the identification and assessment of modern slavery risk.
Continuing to monitor existing suppliers to ensure that their annual Modern Slavery statements do not identify any modern slavery risks.
Preparing and improving existing grievance policy and procedures.
Prior to onboarding a new supplier:
- Undertaking detailed checks.
- Investigating whether the new supplier is aware of modern slavery and the measures which they have taken to mitigate their exposure to modern slavery risk.
Creating internal benchmarks and targets around incident reporting and identifying high risk suppliers.

During the relevant period, NS has not identified any incidents of Modern Slavery in its supply chains.

Monitoring and evaluating performance

During the relevant period, NS has commenced the task of developing the processes set out above. As this process matures, NS anticipates further refinement for tracking the effectiveness of the policy.

NS will regularly review with a view to improving its approach to identifying modern slavery risks and addressing those risks.

NS is proud to be leading from the front in making this Policy publicly available and creating awareness and greater understanding around the issue of Modern Slavery. In working with its existing suppliers to ensure ethical purchasing and making educated assessments in relation to onboarding new suppliers, its goal is to ensure greater transparency and certainty for its customers, employees, and trade partners.