Modern Slavery Statement

Introduction

We are proud to publish our first Modern Slavery Statement in accordance with Australia’s Modern Slavery Act (Cth) 2018.

Genea is committed to upholding human rights within our own business operations and supply chain. We respect every individual’s right to live and work freely and this underpins how we do business. We seek to engage with suppliers who share these values and respect human rights within their own operations.

We understand that modern slavery poses an ongoing challenge, both locally and globally, and will strive to achieve accountability and transparency within our own operations and supply chain.

Structure, operations, supply chain

Structure

Joey Holdco Pty Ltd (ACN 658 985 276) is the ultimate parent and reporting entity for the below companies, collectively known as ‘Genea’:

• Joey MidCo 1 Pty Ltd (ACN 658 985 454)
• Joey MidCo 2 Pty Ltd (ACN 658 985 605)
• Joey BidCo Pty Ltd (ACN 658 985 865)
• Genea Pty Ltd (ACN 002 844 448)
• Genea Pathology Pty Ltd (ACN 074 545 681)
• Genea Fertility Pty Ltd (ACN 603 445 889)
• Genea Canberra Pty Ltd (ACN 111 571 870)
• Genea Newcastle Pty Ltd (ACN 074 111 274)
• Genea Perth Pty Ltd (ACN 120 001 443)
• Fertility SA Pty Ltd (ACN 31 141 685 579)
• Genea Thailand Ltd

Operations

Genea is an Australian based business with a growing presence in Thailand, headquartered in Sydney, NSW that has been leading the way in fertility advances for over 30 years. We’ve developed world-class technology that’s used in over 60 countries and 600 clinics around the world, whilst having some of Australia's leading IVF success rates. Genea has 15 clinics across Australia and 1 clinic in Thailand, employing over 400 team members.

Supply Chain

In FY22, Genea had a direct supplier spend of approximately $49m. During FY22, Genea’s Australian business had 452 suppliers across Australia (426), Belgium (1), Canada (1), Finland (1), France (2), Israel (1), New Zealand (1), Singapore (2), Spain (1), The United Kingdom (3), and the United States (13). 94% of our Tier 1 suppliers are based in Australia, ranging from large multinational corporations to small businesses. Our largest categories were on Medical & Laboratory Suppliers (20%), Ultrasound Monitoring (8%) and Fertility Services (7%). In FY22, 97% of our direct spend is with organisations registered in Australia.

Risks of modern slavery 

We undertook a risk assessment of our Operations and a detailed analysis of our Tier 1 supply chain with support from a technical consultant. Risks were assessed based on market leading resources including Global Slavery Index, Global Rights Index (GRI) and the Global Estimates of Modern Slavery published by the International Labour Organisation.
We have identified modern slavery risks within our own operations and Tier 1 supply chain.

Identification of risks within our operations

We have assessed the risk of our Australian business operations to be low as:

• 86% of our employees are hired on a permanent basis
• Contractors we engage with directly as part are generally in highly skilled and professional roles
• Everyone working in our operations is 18 years or older
• All of our employees are paid aligned to awards (unless award free), which are in excess of minimum wage
• Our employees are free to join unions

Identification of risks within our supply chain

This risk analysis examined 397 suppliers within our Tier 1 supply chain and inherent supplier risk was derived based on geographic location, type of product or service procured, and industry risk. These risk weightings were then adjusted based on supplier’s internal controls to minimise modern slavery exposure and criticality of supplier to our business.
While we predominantly use Australian suppliers, we recognise that our goods and services may come from countries other than those of the suppliers’ headquarters or registered place of business.

As an IVF business, we understand that healthcare and medical supply chains are known to have a higher risk of modern slavery and numerous well-documented cases of forced labour. This risk increases further upstream where there is often less visibility and transparency in the raw material sourcing and manufacturing stages of medical supplies. We also understand given the nature of our supply chain, it is likely that its Tier-2 supply chain has a far wider geographic distribution and will derive more heavily from Asia, including in large part China.

Key risks within our Tier 1 supply chain are:

Geographic – Limited variability in geographic risk

• Genea’s Tier-1 geographic slavery risk exposure is concentrated predominantly in Australia, where 97 per cent of the assessed suppliers are located.
• The highest risk location Genea sources its products and services directly from is the United States of America, however this comprises only 1.9 per cent of Genea’s total spend.

Industry

• The high risk industries within our supply chain are:
  • Environmental & Facilities Services
  • Human Resource & Employment Services
  • Diversified Real Estate Services (e.g., property management)
  • Diversified Support Services (e.g., cleaning, storage)
  • Offshore services (e.g. overseas gamete banks)
• These industries have a relatively higher risk of modern slavery due to the prevalence of casual, temporary, or sub-contracted employment of lower-skilled and often migrant workers

Actions taken

We understand that we are at the beginning of our modern slavery risk journey. Our current focus has been undertaking an external modern slavery risk assessment of our operations and supply chain and conducting a gap analysis of our processes and policies. We have developed an action plan based on the findings of this analysis and will be working to implement this over the next three years.

Effectiveness of actions

We are committed to monitoring the effectiveness of our actions and continuously improving our approach to modern slavery risk management. As this is our first statement, over the next twelve months we review the effectiveness of our actions. As such, we will consider:

• Number of risks identified
• Number of employees trained in modern slavery
• Oversight of Tier 1 suppliers

Moving forward we will assess the effectiveness of our actions to ensure they are promoting the rights of workers and reducing the risk of modern slavery in our operations and supply chain.

Planned Activities

We are committed to strengthening the processes to identify and manage modern slavery risks within our own operations and supply chain and will work to embed the following actions.

We acknowledge that the inherent risk within our Thailand operations and supply chains a higher than our Australian operations and will endeavour to undertake an assessment to understand potential Modern Slavery risk in FY24. The Thailand operations is a small part of Genea’s business with revenue contribution < 1% of Group revenue.

Policies and procedures

We plan to implement the following policies to establish internal controls for managing broader human rights and the risk of modern slavery within our business and supply chain:

• Human Rights and Modern Slavery policy sets out our commitment to supporting human rights, our zero tolerance for modern slavery within our operations and expectations for suppliers
• Whistleblower policy outlines our mechanism for reporting of any instances of suspected illegal, immoral, or fraudulent practices, whilst providing protection and measures so that anyone making a report can do so confidentially, without fear of reprisal

Governance

Genea is committed to establishing clearly defined roles & responsibilities of newly formed modern slavery working group.

Due Diligence

Genea will collect more specific data when assessing new suppliers to enhance the assessment of all potential suppliers for their approach to managing modern slavery risk. When we have a new supplier, we also will require them to read and adhere to our Human Rights and Modern Slavery policy.

Remediation

If any issues are uncovered we will work in partnership with our suppliers to remediate the issue. To date, we are not aware of any issues within our own operations or Tier 1 supply chain.

Consultation

The reporting entity, Joey HoldCo Pty Ltd, actively engaged and consulted with all companies we own or control in the development of this Statement.

This statement has been approved by the Board of Directors on 27 September 2023.