MODERN SLAVERY ACT STATEMENT

“As a values-based global organization of 270,000 team members in nearly 50 countries, we believe that it is our duty to apply technology for the good of society and the planet in an ethical, inclusive and responsible manner. This Ethisphere recognition, for a 9th year running, acknowledges Capgemini as a benchmark organization for the exemplary ethical mindset and behaviors that are embedded in our practices every day. These have been more important and evident than ever during this last exceptional year.”

Aiman Ezzat,

CEO, Capgemini Group

This Modern Slavery Statement is published by and on behalf of Capgemini Australia Pty Limited ACN 092 284 314 and its wholly owned subsidiary1 in compliance with Australia’s Modern Slavery Act 2018 (Cth). It describes the steps taken by Capgemini Australia in the financial year ending December 2020 to assess and address modern slavery practices within its operations and supply chains.

Introduction

The Capgemini Group’s greatest asset is its people. Since its foundation in 1967, the Capgemini Group has conducted its business on an ethical foundation, encouraging and enabling its employees and suppliers to operate within the same principled framework.

In 2021 and for the 9th time in a row, Capgemini has been recognized as one of the World’s Most Ethical Companies® by the Ethisphere® Institute. This is an acknowledgment of our ethical behaviour that makes us an employer of choice and responsible player in the eyes of our clients, shareholders, and the wider community.

Capgemini has a zero-tolerance approach to bribery, corruption, and human rights abuse. We do not accept that it is necessary for grave human rights abuses such as forced and compulsory labour, slavery, servitude, and human trafficking to be part of today’s modern businesses and supply chains. We are committed to our employees, our clients, and our suppliers to taking appropriate steps to do what we can to eradicate modern slavery in our operations and our supply chains.

About Capgemini’s structure, operations, and supply chains

“While addressing the tough challenges of 2020, we saw companies lead – above all other institutions – on earning the trust of stakeholders through resilience and a commitment to ethics and integrity. As an honoree for a 9th consecutive year, Capgemini has continued to demonstrate an unwavering commitment to the highest values and positively impacting the communities it serves.

Congratulations to everyone at Capgemini for earning the World’s Most Ethical Companies designation.”

Timothy Erblich,

Ethisphere CEO

Structure and operations

Capgemini Australia is an Australian proprietary company limited by shares and is a wholly owned subsidiary of Capgemini S.E., a French listed company with headquarters in Paris, France.

Capgemini creates and delivers business, technology, and digital solutions to achieve innovation and competitiveness. With more than 270,000 people, Capgemini Group of companies is present in nearly 50 countries and represents over 120 nationalities. Of these, approximately 2000 are based in Australia.

We understand that business value cannot be achieved through technology alone; it starts with people. We believe this human centred approach to technology enables our clients to respond successfully to complex and unpredictable challenges. A deeply multi-cultural organisation, Capgemini has developed its own way of working, the Collaborative Business Experience™, and draws on Rightshore™ – its worldwide delivery model.

Supply chains

Capgemini Australia uses a purchase order policy and a central purchasing system which gives us a very precise and clear view of our procurement activity.

Our supply chains support both the delivery of our services to a diverse portfolio of clients and the running of our day-to-day operations. In these activities we uphold our own Group ethical principles and meet the standards of our clients.

As a services organisation, Capgemini’s operations involve the direct employment or engagement of skilled workers for the provision of services to our clients. Additionally, Capgemini works with suppliers of products and services including for the leasing and use of real estate, the procurement of personal computing devices, office equipment and technology, and for services to manage our operational facilities.

We recognise that our supply chains present some risks and challenges and that we must exercise vigilance in respect of all human rights violations including modern slavery and human trafficking. Our sourcing activities are required to meet a wide range of differing needs that are constantly changing. We recognize that our suppliers have their own suppliers and this makes for complex supply chains that affect our business and our clients’ businesses.

Risks of modern slavery practices in operations and supply chains

Capgemini acknowledges that it has the potential to cause, contribute to, or be linked to modern slavery practices through its operations and supply chains and strives to do what it can to minimise any such risks.

Operations

A risk may arise through Capgemini’s use of skilled labour in the provision of services to its clients. We do not however, consider this risk to be significant given that the individuals who work in the IT and consulting arena are skilled, with greater control over their professional careers. The geographical risk is also somewhat reduced given that our immediate work force is based in Australia and New Zealand.

Supply chains

The use of specialist contractors or skilled IT consultants to complement our people centred approach is made possible by leveraging our renowned Rightshore™ model which ensures that other members of the Capgemini Group through whom we engage resources, share the same ethical principles as Capgemini Australia. Other but less common types of temporary personnel are engaged through external agencies who go through the same rigorous procurement due diligence as any other supplier.

Additionally, Capgemini sources products and services from suppliers for the running of our day to day operations. There are a number of factors which may influence the degree of risk associated with these businesses such as the degree of protection of human rights in the geographies in which they operate or source from, and the manner by which they seek to hire and outsource labour.

All Capgemini’s purchases are governed by our 12 Core Principles of Sustainable Procurement

Actions taken to assess and address risks, including due diligence and remediation processes

Due Diligence

In 2020, and as part of our commitment to modern slavery due diligence and remediation, Capgemini Australia commenced the review of potential modern slavery risks by engaging a third party to support in an initial risk assessment of our suppliers and a subsequent desk-top audit of selected higher-risk priority suppliers.

The initial risk assessment was able to plot the likely slavery risks in our supply chain by tier up to tier 10 and highlighted the top 50 suppliers and top 15 risk industry categories with the greatest likelihood of modern slavery, considering both known industry risk and our total spend. These plots are the platform for Capgemini to prioritise due diligence processes by considering the risk of modern slavery and the leverage that we have over our suppliers.

The subsequent desk-top audit carried out for Capgemini allowed us to navigate some of the physical restrictions resulting from the COVID-19 pandemic and instead, looked at key data points for our selected higher-risk suppliers such as the type of goods and services provided, geographical area of operation, whether each supplier has an internal governance framework for addressing modern slavery issues, and any evidence of internal education and awareness raising for modern slavery issues.

The audit results provide a useful springboard to more meaningful and targeted supplier engagement on modern slavery issues, and can be used by Capgemini in conjunction with other recognised steps, such as supplier self-assessment surveys, and the provision of educational and awareness-raising resources to suppliers as appropriate.

Remediation processes

Capgemini is committed to implementing an ongoing process to support an ethical supply chain framework. This includes engaging with selected suppliers to identify, prevent, and mitigate potential adverse human rights impacts in its operations and supply chains, including modern slavery. Key elements of Capgemini’s existing and proposed approach are outlined below.

Supplier Standards of Conduct

Capgemini’s Supplier Standards of Conduct2 set the minimum commitment expected of suppliers with respect to corporate social responsibility, ethics and anti-bribery, regulatory compliance and business relationship standards. All Capgemini suppliers are expected to adhere to the Supplier Standards of Conduct with no exception, and regardless of the type and value of the business that is done.

The standards contain Capgemini’s principles with regards to compliance with international, national and local law, human rights, labour rights and modern-day slavery and also outline the obligation of our suppliers to conduct their business with the highest standards of integrity, avoiding all forms of corruption, bribery, extortion or embezzlement, and unfair business practices.

Global and local policies

Guided by our Seven Values3, the Capgemini Group plans to continue to forge trusted, long-term business relationships and lead the way into an ethical future. In 2010, we set up a formal ethics program at Capgemini, with our values at its core. This extensive program was crucial for the success of a diverse, decentralized Group like ours, with multi-cultural teams operating in more than 50 countries.

In addition to the Supplier Standards of Conduct, and to support Capgemini’s ethical ambitions are Capgemini’s policies which support our attitude towards human rights and modern slavery:

• Code of Business Ethics
• Group Conflict of Interest Policy
• Group Anti-Corruption Policy
• Group Competition Laws Policy
• Speak Up Policy
• Group Non-Retaliation Policy
• Code of Ethics for AI
• How to Manage with Integrity
• Capgemini Australia Whistleblower Policy

Sustaining our ethical culture needs constant innovation – in 2020, the Group fully revamped our annual ethics e-learning, we listened to our employees through surveys, strengthened our speaking up culture, and invested in a digital solution for conflict of interest management.

People

Capgemini is committed to providing a safe and inclusive work environment. In the services business, success is powered as much be shared values as by employee skills. Capgemini’s business objectives and shared standards are designed to benefit not only shareholders and employees, but also every other participant in the value chain. It is our firm belief that these objectives can only be achieved through mutual respect and cooperation.

Capgemini Australia’s recruitment and hiring process is designed to support decision-making in accordance with Capgemini’s values and equal employment opportunity legislation and is carried out by a highly qualified team of recruiters and a preferred supplier panel.

Capgemini is committed to equal opportunities for all. In accordance with the requirements of the Workplace Gender Equality Act 2021, Capgemini Australia lodged its annual public report with the Workplace Gender Equality Agency and continues to be deemed compliant.

Our Group Global Charter for Diversity and Inclusion states Capgemini’s commitment to recruit and retain a talented and diverse workforce and is supported by our local Diversity Council who holds accountability for effecting diversity initiatives. In June 2020, Capgemini Australia was named in the Top 3 Australia’s best employers for LGBTQ (Lesbian, Gay, Bisexual, Transgender, and Queer) inclusion and recognised as a Gold Employer for its efforts at the Australian LGBTQ Inclusion Awards.

To support our employees, we have created robust people policies and practices which go beyond compliance and deliver enhanced benefits supportive of work and home life. We offer a range of Health and Wellbeing initiatives to promote good mental and physical health.

At Capgemini we understand the importance of enabling employee voice. Speak Up4 is a 24/7 web and phone-based ethics concerns reporting and incident management third party tool is made available to Capgemini’s staff, customers, suppliers, and business partners and is supported by our Whistleblower Policy. It upholds people’s freedom to raise concerns and empowers Capgemini to put ethics into actual whilst also building and safeguarding Capgemini’s culture of openness and high ethical standards.

Training and development

Capgemini Australia’s success depends on its people and the ability of its people to perform in a collaborative way that will way that will drive business results in line with Capgemini’s values and ambitions.

Capgemini’s Talent, Learning and Development Policy outlines and defines the assistance that Capgemini Australia provides to its staff including mandatory training which is required for team members to complete their roles and responsibilities in accordance with Capgemini’s policies and HR policies both locally and globally. This include mandatory Ethics and Compliance training.

Assessing the effectiveness of our actions

Capgemini recognises that monitoring the effectiveness of our actions is key to assessing progress in addressing modern slavery risks.

Our operations and processes regularly undergo both internal and external audits. We intend to build upon this in 2021 through the establishment of a modern slavery working group who will meet to discuss actions taken as well as provide for regular engagement and feedback between key functional areas.

For our supply chain partners, we are creating opportunities for deeper reviews and assessment through contractual clauses and we will look at strengthening remediation actions and assessing effectiveness by engaging more closely with any high-risk suppliers which are identified via our compliance due diligence process.

Lastly, our Speak Up5 web and phone- based ethics concerns reporting and incident management third party tool and supporting Whistleblower Policy mentioned above, enables the freedom for concerns to be raised while also allowing Capgemini Australia to log and track ethical violations.

Process of consultation

Given that Capgemini Australia’s wholly owned subsidiary was fully operationally integrated with Capgemini Australia in the relevant reporting period, no separate process of consultation was required in the preparation of this Statement.

Looking to the future

Capgemini’s approach to managing modern slavery risks is an ongoing and long-term process.

To build on the initial analysis and due diligence outlined above, Capgemini has commenced a review and update of its standard procurement terms and conditions and well as the development of an Australian Modern Slavery Policy which it will seek to embed within its procurement and onboarding processes.

Capgemini will continue to raise awareness of ethical issues including modern slavery with targeted training and e-learning on Capgemini’s Code of Business Ethics.

These steps will be complimented by the Capgemini Group’s CSR ambition to be recognized globally as a leading responsible company, using our expertise for positive impact.

Our forward and proactive approach to ethical issues including modern slavery, results from insights and collaboration between multiple functional areas within the Capgemini organisation including Procurement, Human Resources, Legal, Ethics, and Compliance.

Capgemini acknowledges the need to strive for continuous improvement in our understanding, oversight and management of modern slavery risks in our operations and supply chains.

This Modern Slavery Statement was approved by the principal governing body for Capgemini Australia, the Capgemini Australia Pty Limited Board of Directors on 17 June 2021 and signed by Capgemini Australia and and New Zealand’s Managing Director.

About Capgemini

Capgemini is a global leader in partnering with companies to transform and manage their business by harnessing the power of technology. The Group is guided everyday by its purpose of unleashing human energy through technology for an inclusive and sustainable future. It is a responsible and diverse organization of 270,000 team members in nearly 50 countries. With its strong 50 year heritage and deep industry expertise, Capgemini is trusted by its clients to address the entire breadth of their business needs, from strategy and design to operations, fueled by the fast evolving and innovative world of cloud, data, AI, connectivity, software, digital engineering and platforms. The Group reported in 2020 global revenues of €16 billion.

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