Macquarie (Macquarie Group Limited and its subsidiaries) respects fundamental human rights as set out in the Universal Declaration of Human Rights and codified in the International Covenant on Civil and Political Rights, International Covenant on Economic, Social and Cultural Rights, and core International Labour Organisation Conventions. In line with the UN Guiding Principles on Business and Human Rights, we recognise the duty of states to protect human rights as well as the responsibility of businesses to respect human rights.
Macquarie has a framework of policies, programs, and processes in place to identify, mitigate and where relevant, remediate potential and actual human rights impacts, including modern slavery, resulting from our business activities and the relationships connected to those activities (our policy framework).
Where local legislation conflicts with the principles and processes in our human rights framework, Macquarie will comply with the law, while also seeking ways to uphold human rights principles within our sphere of influence.
The Board is responsible for approving Macquarie’s Environmental, Social and Governance (ESG) framework including major ESG policies. In accordance with its Charter, the Board Governance and Compliance Committee (BGCC) assists the Board in adopting appropriate governance standards and reviewing the operation of environmental and social risk management policies. Responsibility for implementation of the ESG framework and related Board approved policies resides with Management.
Under the Code of Conduct, all our people share responsibility for identifying and managing environmental and social issues as part of normal business practice. They are supported by the Environmental and Social Risk (ESR) team, which sits within the Behavioural Risk division of the Risk Management Group and has Group-wide oversight of the Environmental and Social Risk Policy. The ESR team reports to the Chief Risk Officer and to the BGCC on ESG-related matters.
In relation to environmental and social (including human rights) risks in products and services provided to our customers and clients, our people are supported by the ESR team. Operating and Central Service Groups are responsible for the management of their suppliers and are supported by Group Procurement, which operationalises and advises on the Supplier Governance Framework.
Macquarie reviews its human rights framework regularly and uplifts where appropriate. Policies and procedures are reviewed periodically and updated if required.
Macquarie takes a risk-based approach to identifying and assessing human rights risk in our operations, supply chain, customer and client relationships, and grant partners, focusing on salient risks to people.
Macquarie is committed to maintaining a safe workplace that values equal opportunity and is free from discrimination, harassment, and victimisation. We are also committed to maintaining an environment where our people feel comfortable raising issues or concerns and do not experience detriment as a result of speaking up.
We operate in a highly regulated environment and have robust policies and procedures concerning employment screening (including work eligibility checks), employment conditions (including fair pay and hours) and appropriate workplace behaviour. These policies and procedures apply across all employment types. All our people are expected to abide by the spirit, as well as the strict requirements, of the Code of Conduct and applicable policies and procedures.
At Macquarie:
Macquarie is committed to ensuring high standards of environmental, social and governance performance across our supply chain, including human rights. We are committed to maturing our Supplier Governance framework to include enhanced visibility through the supply chain.
Our Supplier Governance framework brings under governance direct suppliers1 that meet heightened risk and/or high value criteria, including ESR. Heightened ESR suppliers are those that may lead to increased exposure of modern slavery risk (amongst other environmental or social risks) and are determined through a combination of ratings accounting for high-risk industries and high-risk jurisdictions, independent of value.
The relevant Operating Group or Central Service Group that procures the goods or services owns the supplier relationship and is responsible for assessing all direct supplier1 relationships to determine whether they meet these triggers and if so, the suppliers are subject to risk assessment, profiling, and ongoing governance. Due diligence on suppliers specific to a transaction is covered by our ESR Policy.
Under our Principles for Suppliers, we request our direct suppliers to cascade human rights and modern slavery standards down the supplier’s own supply chains.
The ESR Policy includes a due diligence approach intended to support the identification and management of potential and actual human rights risks, including the risk of modern slavery in investment decision making and in the screening of new client relationships. The scope of our human rights due diligence varies based on the nature, size and complexity of our activity, as well as the risk of human rights impacts.
The ESR Policy requirements include:
Enhanced due diligence is conducted where risks may be heightened, such as in certain emerging markets or industries with known issues in their operations or supply chains. For example, we have developed guidance documents to support existing human rights due diligence and adverse impact review processes. We have developed the investee company human rights good practice principles and guidance to support nominee Directors in working with their investee company boards on overseeing human rights risks.
The Macquarie Group Foundation drives social impact work for Macquarie Group. We support our people, businesses, and communities to build a better future, and engagement with our people is at the heart of everything we do. The majority of the Foundation’s global grant funding is directed to organisations supporting social and economic opportunities for people in the communities where we live and operate, with each region concentrating its efforts on issues with local relevance.
We employ a risk-based due diligence approach to assessing grant partners. This includes a modern slavery risk questionnaire, completed by all grant applicants with referral to the ESR team to review grant applicants identified as presenting a high inherent modern slavery risk. The questionnaire and further diligence help identify potential modern slavery risks, actions to address those risks and improves transparency.
Targeted training is provided to staff in key Operating and Central Service Groups to support the identification and management of labour and human rights issues.
Refer to the Spotlight below for further information on our human rights e-learning module.
Our people and external parties (including former employees, current or former consultants, contractors, third party providers, auditors, brokers, associates and suppliers) are able to report concerns including human rights impacts and breaches, under the Whistleblower Policy by contacting the Integrity Office, which is an internally independent and confidential function that oversees Macquarie’s Whistleblower Program, at integrityoffice@macquarie.com or by contacting the Integrity Hotline online, or by phone. The Integrity Hotline is externally managed by an experienced and reputable firm and people who make a report can remain anonymous if they wish. The Integrity Hotline is available 24 hours a day, 7 days a week.
Under Macquarie’s Whistleblower Policy, Macquarie will treat all Protected Disclosures confidentially and will take reasonable steps to protect you if you make a Protected Disclosure, including protection of your identity. Macquarie will take all reasonable steps to ensure that staff and external parties will not be personally disadvantaged or subject to any reprisals by Macquarie as a result of reporting a concern.
Reflecting our commitment to our customers, Macquarie Bank Limited subscribes to the Australian Banking Association 2019 Banking Code of Practice (as amended). Macquarie has a robust complaint management framework across our retail banking business to resolve customer complaints quickly and fairly. Customers and the public can raise concerns by completing an online form on the Feedback and Complaints web pages.
Macquarie’s Customer Advocate is separate to the operating, risk and support groups including our internal dispute resolution teams. The Customer Advocate reports directly to the CEO and provides regular reporting to the BGCC.
Macquarie recognises there are different ways in which an enterprise can be involved or linked to an adverse human rights impact and the associated remediation actions. Our ESR Policy establishes processes for identifying, assessing, managing, mitigating, remediating, and reporting material environmental and social risks, including human rights risks. If Macquarie becomes aware of a client or supplier involved in or linked to an adverse human rights impact, we will consult to understand the remediation actions being undertaken and assess the extent to which these actions will remediate the situation and mitigate reoccurrence.
Through our Principles for Suppliers and our supplier ESR assurance programme, we are committed to working with our suppliers to remediate non-conformances identified in onsite audits through time bound corrective action plans.
Clear dialogue with our stakeholders is important to building strong relationships, maintaining trust and enhancing business performance. We regularly engage with a broad range of stakeholders including clients, shareholders, investors, analysts, governments, regulators, staff, suppliers and the wider community.
We are active in a number of external initiatives relevant to addressing modern slavery in the financial sector, including:
Annually, Macquarie reports under the UK Modern Slavery Act 2015 and Australian Modern Slavery Act 2018 (Cth). Modern slavery involves the most serious forms of human exploitation and takes many forms including: trafficking in persons; slavery; servitude; forced marriage; forced labour; debt bondage; deceptive recruiting for labour or services; and the worst forms of child labour. Macquarie’s latest Modern Slavery Statement is linked below.
Macquarie reports under the Australian Workplace Gender Equality Act, the UK Equality Act 2010 (Gender Pay Gap Information) Regulations 2017, and the ASX Corporate Governance Principles and will continue to meet these requirements. In addition, Macquarie publicly reports on our ESG progress annually.
Since 2018, Macquarie has been implementing an Environmental and Social Risk (ESR) based assurance program which involves in-depth onsite assessments with certain direct suppliers in high-risk jurisdictions and high-risk industries to test alignment with Macquarie’s Principles for Suppliers.
We are committed to working with our suppliers to remediate any non-conformances through time bound corrective action plans, and to ensure success through follow up audits as necessary. Please refer to our Modern Slavery Transparency Statements and our Supplier Portal for more detail.
In collaboration with an expert third-party human rights consultant, since FY2021 Macquarie has developed and deployed a human rights (including modern slavery) e-learning module.
The training aims to help staff identify, mitigate and escalate negative human rights (including modern slavery) impacts from clients, investments and suppliers. It covers the key indicators that elevate the risk of human rights (including modern slavery) breaches.
Vulnerable populations include people whose personal characteristics or circumstances may lead them to be more susceptible to harm. For example, children, migrant workers and base-skill workers.
High-risk business models tend to include models with little visibility over labour, opaque entity structures or fronting, subcontracting arrangements, or where significant parts of labour needs are outsourced. For example, complex supply chains or businesses significantly relying on labour hire and outsourcing.
Some specific goods or services are inherently riskier because of the nature of the sector or value chains (for example, construction, facilities management, hospitality, and IT hardware).
High-risk geographies may include countries or areas with a weak rule of law, conflict, corruption, remote locations or where there are large displaced or migrant populations.
