Spark New Zealand : 2023 Modern Slavery Statement

Spark New Zealand  Modern Slavery Statement 2023

Modern Slavery

Statement 2023

At Spark, we respect the freedom and human rights of every individual, regardless of who they are, or where they are from. Modern slavery is a complex human rights challenge we are committed to address. It includes the exploitation of any person in any form including through forced labour, debt bondage, forced marriage, slavery, human trafficking or where they cannot leave due to threats, violence or deception.

Our people are at the heart of our business, and we have tools and policies in place to uphold the rights of everyone working for Spark. This means treating every person with respect and ensuring that we provide fulfilling employment that rewards and recognises each individual fairly. While we comply fully with the law, our approach is to go above and beyond compliance by acting professionally, ethically, and responsibly to create an inclusive environment for our people as we deliver customer outcomes, contribute to the community, and create shareholder value.

As a telecommunications and digital services business, our supply chain is vast and diverse, which makes our ability to influence the practices of every organisation outside of our own a challenge. However, we are committed to address issues, and are working with our industry to assess, prevent, mitigate, and remedy human rights impacts across our broader operations and value chain. This means sourcing our products and services from suppliers that provide safe working conditions, treating workers with respect and dignity, and conducting business in an environmentally and socially responsible manner.

This report provides a summary of our approach to addressing modern slavery, including actions taken over the past year to strengthen our systems and processes.

This Modern Slavery Statement is made on behalf of Spark

New Zealand Limited ('Spark' and its subsidiaries, the 'Spark Group') for the period from 1 July 2022 to 30 June 2023. It has been published in accordance with the requirements of the 'Australian Modern Slavery Act 2018' and was approved by the Board on 17 August 2023.

Spark New Zealand Limited (NZX: SPK, ASX: SPK)

Spark is New Zealand's largest telecommunications and digital services company. Our customers range from individual New Zealanders and households to small businesses, not-for-profits, government and large enterprise clients. Across all our services - mobile, broadband, cloud services, digital services and entertainment - we have relevance for almost every New Zealander.

Connectionto

63

retail stores

24

regional business hubs

Active infrastructure on

~1,500

mobile sites supporting more than 2.7 million mobile connections

699k

broadband connections

16

data centres

5,432

New Zealand employees

Fibre Transport Network

Data Centres

Southern Cross Cable

Southern Cross Next Cable

Earth Station Satellite Link

Corporate Offices

Tasman Global Access Cable

Supply

chain risk

management

Risk identification:

Modern slavery risk will be identified through an ongoing human rights due diligence process, aligned to our annual sustainability materiality process, an annual process of supply chain risk identification, supplier self-assessments, independent audits conducted through our membership of the Joint Audit Cooperation Initiative (JAC) and additional local audits where needed. New suppliers are screened for risk as they are onboarded.

Annual

non-financial

reporting

Spark has a combination of policies and systems in place to prevent, mitigate and identify instances of modern slavery or human rights violations as part of our overarching sustainability and risk management approach. This approach, which is outlined in our Modern Slavery Framework (see diagram above), forms part of our broader Toitū Sustainability Framework. Further detail can be found in our Sustainability at Spark overview on our website.

Risk mitigation:

The supply chain risk management process identifies issues to be rectified with suppliers, tracked through our SAP Ariba system and, where relevant, via the shared JAC database. Any non-supply chain risks identified have mitigation actions agreed and tracked by the Environment, Social and Corporate Governance (ESG) squad and through our overarching sustainability governance.

Governance framework:

Modern Slavery reporting is integrated into quarterly reporting to our Leadership Squad, including issues identified and progress against mitigation actions. Our Leadership Squad and Board are also engaged in the preparation of our annual Modern Slavery Statement. Key policies include our Human Rights Policy and our Supplier Code of Conduct.

Reporting:

We report our progress, the effectiveness of our approach and actions, and future improvements in our annual Modern Slavery Statement and in the Our Suppliers section of our Annual Report.

We have high standards of operational performance, corporate governance, and risk management that support our efforts, and our Board regularly reviews and assesses these processes to ensure they remain consistent with international best practice.

Spark's corporate governance policies, practices, and processes, including Spark's Annual Corporate Governance Statement, can be found on the Governance section of our website.

We have a dedicated Human Rights Policy which commits to respecting all internationally recognised human rights and sets clear expectations on how we will address human rights issues across our value chain. This policy also identifies human rights topics that are relevant to our broader value chain and are addressed through our Supplier Code of Conduct.

We have a range of reporting mechanisms for our people to pursue if they are concerned about Spark or any of our people who are not living up to our values, our Code of Ethics, or Human Rights Policy, including any instances relating to human rights violations and modern slavery.

These are set out in detail in our whistleblowing process, which is documented and available to all Spark people. Spark's Honesty Box process is an online reporting tool that enables investigation by specialist employees of any concerns raised, while maintaining the confidentiality of the reporter. We also provide avenues where people can raise concerns without providing any information about their identity at all.

These policies and systems are underpinned by our Values, Tūhono: we connect, Māia: we are bold, Whakamana: we empower, and Matomato: we succeed together. Our values are the cornerstones of our culture and guide our behaviour.