Modern Slavery Notice for the year ended 30 June 2022

19 December 2022


For the year ended 30 June 2022, NESS Super Pty Limited ABN 28 003 156 812, as Trustee of NESS Super ABN 79 229 227 691 (the Fund) is not required to publish a Modern Slavery Statement.  However we provide this notice to state the Trustee views and activities to manage Modern Slavery concerns.

Many of the business operations of the Trustee have been outsourced to external service providers.  Key among these are our administrator, custodian and investment consultant. Other professional services that are outsourced include accounting, legal and auditing to assist with our obligations.

For a list of our material service providers please visit our website

Our investments

For the year ended 30 June 2022, the Trustee has chosen to have its assets managed through partnerships with a number of investment managers investing in unitised listed and unlisted products.

The Trustee recognises that when invested in unlisted assets, the Investment Manager’s investment process will determine how it invests. The investment consultant incorporates ethical, social and governance (ESG) factors into their investment manager selection processes. The integration of ESG requires that the impact of any ESG issues on the value of a company is included in the valuation process and the understanding of the long-term sustainability of the company.

The current exclusions that may apply to equities include the exclusion of investing in companies that:

  • produce components that are dedicated to the production of anti-personnel mines and/or cluster munitions;
  • manufacture tobacco products; or
  • are involved in the production of the core nuclear weapon system, or components/services of the core nuclear weapon system, that are considered tailor-made and essential for the lethal use of the weapon.

Our investment managers have advised us they are incorporating modern slavery considerations into their investment options including their pooled vehicles.

The Trustee recognises that the risks in modern slavery are evolving. We will continue to work with our Investment Consultant to incorporate responsible investing and consider modern slavery risks throughout the investment process and to offer investment options, within listed and unlisted products to meet current requirements.

Our risk process and assessment

  • Risk in Operations

The Trustee operates in a heavily regulated Australian financial services environment and has frameworks and procedures in place in relation to employment practices / conduct, governance, risk management, whistleblowing, and due diligence. Our employees are primarily white-collar professionals and the risk of modern slavery in our operations are low.

  • Risk in our Supply Chain

The Trustee’s supply chains generally include those related to professional services, corporate and operational procurement, such as investment consulting, custody services, administration services, banking, legal and tax advisors, information technology and stationery. Generally, the risk in our supply chain is low since all suppliers of material services are based in Australia and relate to high-skilled and professional industries with low labour-related risks.

We confirm that all our material services suppliers either have assessed or are in the process of assessing modern slavery risks and conduct due diligence that considers modern slavery risk management in investee entities’ operations and supply chains.

The Trustee also has a robust risk management framework in place. If any modern slavery risks are identified they will be incorporated into the risk assessment process and managed accordingly.

Measuring effectiveness and remediation

We have built frameworks around how to reduce exposure to modern slavery in our policies, processes and the workplace.

To continually improve our programme of work on modern slavery we have pursued the following:

  • Continued review and strengthening the Modern Slavery framework.
  • Continued raising awareness of Modern Slavery.
  • Developed the supplier’s due diligence program.
  • Monitored and assessed the Modern Slavery Risks.

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