Macquarie1 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 (UNGPs), 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 (together, our human rights framework) to identify, mitigate, and where relevant, remediate potential and actual human rights impacts, including modern slavery, in our value chain.
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 MGL 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, practices and performance. Management is responsible for the implementation of the ESG framework.
Under the Code of Conduct, all our people are expected to identify, assess and manage material environmental and social risks in all business activities and comply with applicable laws, regulations and policies. In relation to environmental and social issues in products and services, our people are supported by the Environmental and Social Risk (ESR) team within the Credit Risk division of the RMG, which oversees application of Macquarie’s ESR Policy. The ESR team provides periodic reporting to the Chief Risk Officer (CRO) and the BGCC on environmental and social risk management policies, practices and performance. 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 Service Provider Risk Management 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 Service Provider Risk Management Framework to include enhanced visibility through the supply chain.
Our Service Provider Risk Management Policy and associated framework brings under governance direct suppliers2 that have heightened risk across various factors including cyber and information risk, resilience and business reliance, regulatory, ESR and others. Heightened ESR suppliers are those that may lead to increased exposure to 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.
Operating or Central Service Groups that procure goods or services own their supplier relationships and are responsible for assessing each supplier relationship to determine whether they meet the heightened ESR criteria. If so, suppliers are required to be centrally procured and undergo risk assessment and due diligence with internal approvals obtained prior to contract execution and ongoing governance.
Under our Principles for Suppliers, we request suppliers to cascade human rights and modern slavery standards down their own supply chains.
The ESR Policy includes a due diligence approach to identify and manage human rights risks, including the risk of modern slavery, in transactions (e.g., investments, financing, leasing and advisory mandates) and in the screening of 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, for investee companies with high inherent human rights risk, the investee company human rights good practice principles are applied to support Macquarie representatives who sit on the boards of investee companies to oversee and manage human rights risks.
The Macquarie Group Foundation drives social impact work for Macquarie Group. Recognising that many people around the world face systemic barriers to employment, the majority of the Foundation’s grants and social impact investments are focused on breaking down these barriers and building effective pathways to employment. Each region concentrates 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 high inherent modern slavery risk. The questionnaire and further diligence help identify potential modern slavery risks, actions to address those risks and improve transparency.
Grant making is overseen by the Macquarie Group Foundation Committee (Committee). There is an escalation and approval pathway to the Committee if material modern slavery concerns are identified, which are considered alongside other material financial and non-financial risks.
Targeted training is provided to staff in key functions across Macquarie’s Operating and Central Service Groups to support the identification and management of labour and human rights issues, and where relevant.
Refer to our Modern Slavery Statements for further information on training.
Staff and external parties (including former staff, current or former consultants, contractors, third party providers, auditors, brokers, associates and suppliers) are able to report concerns under the Whistleblower Policy by contacting the Integrity Office, an internally independent and confidential function that oversees Macquarie’s Whistleblower Program, or the Integrity Hotline, an external, dedicated service which is available for staff and external parties to confidentially report a concern about improper conduct in relation to Macquarie.
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 2025 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 Complaints web page.
Macquarie’s Customer Advocate office is separate to the Operating and Central Service Groups including our internal dispute resolution teams. The Customer Advocate office reports directly to the CEO and provides regular reporting to the BGCC.
Macquarie recognises there are different ways in which an enterprise can cause, contribute or be directly linked to an adverse human rights impact and the associated remediation action.3 Our ESR Policy establishes processes for identifying, assessing, managing, mitigating, remediating (via the internal Incidents and Issues process) and reporting material environmental and social risks, including modern slavery risks. In line with the UNGPs, if Macquarie identifies we have caused or contributed to adverse human rights impacts, we would provide for, or cooperate in, remediation through legitimate processes. Where Macquarie is directly linked to a human rights breach, while not responsible for providing remedy, Macquarie would seek to use its leverage to influence remediation.
Through our Principles for Suppliers and our supplier ESR assurance programme, we are committed to working with our suppliers to remediate issues as required. Audit findings are issued with time-bound corrective action plans outlining the steps to resolve identified issues, and agreed by both the auditor and supplier.
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, Australian Modern Slavery Act 2018 (Cth) and the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act 2023. 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 child labour.4 Macquarie’s latest Modern Slavery Statement is linked below.
Note the 2025 and 2024 Modern Slavery Statements are published to comply with the Canadian Act in May each year, then updated in September to include Reporting Entities captured under the UK and Australian Acts.
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 sustainability 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 remain committed to working with our suppliers to remediate these non-conformances through time-bound corrective action plans, and to ensure success through follow up audits as recommended by the auditor. The findings and associated actions are tracked through Macquarie’s supplier governance technology platform, as well as recorded by the auditor in the SEDEX platform (for the suppliers’ visibility). Please refer to our Modern Slavery Statements and our Supplier Portal for more detail.
Macquarie controls or has significant exposure to companies (investee companies) which operate in a range of sectors and jurisdictions, some of which may be exposed to high inherent human rights (including modern slavery) risks.
In 2021, Macquarie developed investee company human rights good practice principles and guidance (good practice principles) to support Macquarie representatives who sit on the boards of investee companies (Nominee Directors) to oversee and manage human rights risks. They were developed with reference to international good practice guidance, with a focus on the UN Guiding Principles on Business and Human
Rights. The good practice principles comprise the following three principles, underpinned with detailed guidance:
In 2022, we commenced a risk-based approach to implement the good practice principles across Macquarie’s investee company portfolio, which included the following steps:
The good practice principles risk rating process is embedded in new transaction due diligence and is being embedded in annual ESR reporting from the Nominee Directors to Macquarie, which will include reporting on the progress of working with their investee company board to encourage alignment with the good practice principles.
Note that it is the role of each investee company’s board to set strategies and broad frameworks for identifying, preventing, and remediating human rights impacts, and to hold management accountable for implementation. Ultimately, the investee company Board is responsible for the company’s management of human rights issues.
The good practice principles are not intended to be prescriptive or exhaustive and a continuous improvement approach is supported, acknowledging that uplifting human rights risk management is a complex and ongoing task.
