Modern Slavery Risk Assessment and Supply Chain Review

Anthesis supported TOMRA to strengthen modern slavery risk management, improve due diligence and enhance reporting transparency.

The Situation

TOMRA Collection Australia (TOMRA), specialises in reverse vending machines (RVMs) and container deposit scheme infrastructure. Its network of reverse vending machines, bulk sorting equipment, and modern depot facilities operates across hundreds of locations around Australia, including retail car parks, shopping centres, and dedicated recycling centres.

Seeking to further strengthen its approach to modern slavery, TOMRA Collection Australia partnered with Anthesis on three targeted workstreams designed to enhance risk visibility, strengthen reporting and support ongoing improvement.

Our Solution

Gap Assessment: Reviewed TOMRA’s previous Modern Slavery Statements to identify opportunities for improvement and benchmark disclosures against leading practice. Stakeholder interviews helped build a clearer understanding of existing approaches to identifying and managing modern slavery risks.

Modern Slavery Statement Development: Modern Slavery Statements were developed in line with the seven mandatory reporting criteria, incorporating best practice disclosures to strengthen transparency and reporting.

Supply Chain Risk Assessment: A risk assessment of the FY25 supply chain was completed to evaluate modern slavery risks across suppliers, industries and geographies and determine where further due diligence may be required.

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Anthesis delivered a highly professional and insightful engagement, providing a comprehensive Modern Slavery Gap Assessment and Supply Chain Risk Assessment that exceeded expectations. Their team demonstrated strong technical expertise, a clear understanding of regulatory requirements, and a pragmatic approach to identifying risks and improvement opportunities. The resulting outputs were clear, robust, and highly actionable, providing meaningful insights that have and will continue to strengthen our governance framework and enhanced transparency across our supply chain.ā€

Martin Lamb, TOMRA, Head of Finance APAC

Impacts of the Project

Stronger foundation for managing modern slavery risks

A clearer view of strengths, gaps and improvement opportunities has created a stronger foundation for managing modern slavery risks and enhancing future disclosures.

More targeted due diligence

Greater visibility of modern slavery risks across suppliers, industries and geographies enables due diligence efforts to be focused where they can have the greatest impact.

Enhanced reporting transparency

Enhanced reporting quality and transparency has strengthened alignment with Australian Modern Slavery Act requirements and provided stakeholders with a clearer understanding of TOMRA’s approach to managing modern slavery risks.

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