This statement has been made on behalf of the Catholic Diocese of Maitland-Newcastle.
This Statement covers all entities owned or controlled by the Diocese of Maitland-Newcastle.
Trustees for the Roman Catholic Church and the Diocese of Maitland-Newcastle.
ABN 62 089 182 027
841 Hunter Street, Newcastle West NSW 2302
Approval and signature
On behalf of the Catholic Diocese of Maitland Newcastle, I am pleased to present our sixth Modern Slavery Statement. In 2025, the Church celebrated the Jubilee with the theme “Pilgrims of Hope.” In that spirit, we hold firm to the hope that one day modern slavery will end.
Modern slavery is a violation of human rights and dignity. It takes many forms, including forced labour, exploitation, debt bondage, and other practices that strip away freedom. Sadly, the number of people experiencing modern slavery is not diminishing, with the Global Slavery Index 2023, reporting that there are 50 million people living in situations of modern slavery on any given day. In Australia an estimated 41, 000 people are enslaved.
The Catholic Church has a strong and enduring commitment to eradicating modern slavery, founded in the belief that every person has the indisputable rights to freedom and dignity. The Diocese acknowledge that business activities, including our own, can impact vulnerable people. Therefore, we take practical steps to manage these risks, drive change, and work toward eliminating modern slavery. Our commitment includes transparency, ethical and responsible practices
across all operations, policies, governance, and partnerships.
Our 2025, statement, outlines the actions we have taken to address modern slavery risks within our operations, guided by the Church, Australian and NSW Government frameworks, and with the support of the Australian Catholic Anti-Slavery Network (ACAN). Together, we strive for meaningful change.
This Modern Slavery Statement was approved by the principal governing body of the Diocese of Maitland Newcastle as defined by the Modern Slavery Act 2018 (Cth) (“the Act”), being the Trustees of the Roman Catholic Church for the Diocese of Maitland Newcastle, on 20/06/2025.
Yours sincerely in Christ,
Bishop Michael Kennedy, Diocese of Maitland-Newcastle
June 2026
The Diocese of Maitland Newcastle represents the Catholic community across a geographic region extending from Lake Macquarie in the south to Taree in the north, and west to Merriwa and Murrurundi in New South Wales. A diocese is a community of the faithful entrusted to the pastoral care of a Bishop and forms part of the broader mission of the Catholic Church.
The Diocese serves the Hunter and Manning regions and supports a Catholic population of more than 148,000 people through an extensive network of parishes, pastoral ministries and diocesan agencies. These agencies deliver a broad range of services, including education, social welfare, early childhood education, out of school hours
care, housing, community development and financial services. Key agencies include Catholic Schools (Diocese of Maitland Newcastle), CatholicCare Social Services, St Nicholas Early Education and OOSH, the Catholic Community Fund, and Hunter Community Housing.
The Diocese employs approximately 5,400 staff across its agencies and operations. Diocesan governance, financial administration and central support functions are coordinated through the Diocesan Head Office, located at 841 Hunter Street, Newcastle West, NSW 2302.
For the reporting period, the Diocese of Maitland Newcastle had an annual consolidated revenue of $675,020,984.
Our Vision and Mission
VISION
To live the joy of the gospel and share it with the world.
MISSION
We are committed to serving all in the community so that they may experience life to the fullest.
58 schools with over 21,450 students
40+ clergy members undertook annual safeguarding training with the OoSG
1,079 employees completed the Office of Safeguarding (OoSG) Advanced Safeguarding
4,100+ completed the OoSG ‘Safeguarding Children & Vulnerable Adults’ online module
30 St Nicholas OOSH services with 5,100+ students enrolled
12 St Nicholas Early Education centres serving more than 1600 children
2,900+ clients and families supported through CatholicCare
17,200+ counselling and assessment sessions provided by CatholicCare
Tier 2
Community Housing Provider
849 members
Overall responsibility for compliance with the Modern Slavery Act 2018 (Cth) sits with the Governance Department of the Diocese of Maitland-Newcastle. In mid-2025, the Diocese undertook governance reforms, transitioning from the former CEO-led structure to a Curia-based model to better integrate church structures and pastoral mission. Under this new structure, the Moderator of the Curia, appointed by the Bishop, provides overarching leadership, with the Vicar General, Chief Operating Officer, Chief Governance Officer and Chief Financial Officer reporting directly to the Moderator. This governance transition strengthened central oversight and reinforced a more integrated approach to compliance and risk management across diocesan operations. Within this framework, the Governance Department continues to provide central coordination, policy oversight and assurance in relation to modern slavery risk management. As the Diocese’s modern slavery program matures, a key focus remains on strengthening organisational capability to identify, assess and respond to modern slavery risks. This is achieved through the development of clear processes, practical tools
and guidance to support diocesan agencies and departments. The Governance Department also provides ongoing advice and support to senior leaders and key stakeholders across the Diocese to ensure a consistent and informed approach.
Responsibility for managing modern slavery risk is embedded within day-to-day operations and governance processes. Modern slavery risks, mitigation actions and program progress are monitored and reported through established governance channels, including regular reporting to the Diocesan Leadership Group.
To further enhance governance oversight, the Diocese has re-established and rebranded the Modern Slavery Liaison Committee (MSLC). The refreshed MSLC strengthens whole-of-Diocese coordination and reinforces collective responsibility for modern slavery risk management. Bringing together representatives from each diocesan agency and Curia department, the MSLC supports consistent practice, shared accountability and continuous improvement. The MSLC operates as an advisory body, is accountable to the Moderator of the Curia, and reports to the Diocesan Leadership Group.
The Diocese of Maitland-Newcastle serves the Hunter and Manning regions which have a population of more than 148,000 Catholics.
We provide pastoral, educational, social welfare, and community development services through various agencies in a region extending from Lake Macquarie to Taree and as far inland as Merriwa and Murrurundi, including:
Catholic Schools, educating more than 21,450 students in our 58 schools.
CatholicCare Social Services Hunter-Manning provides care, counselling, clinical and support services along with community food programs to support children and vulnerable people.
Hunter Community Housing, a nationally registered Tier 2 Community Housing Provider offering supported independent living for young people transitioning from out of home care, as well as group homes, affordable housing, and a residential market program.
Parishes, the core structure of the Diocese, nourish the lives of the people in our region spiritually, pastorally, educationally and through outreach, social justice and community support initiatives. The Diocese has 37 parishes across 74 locations.
St Nicholas, provides high quality care and education for children aged up to five years across 12 locations, as well as Out of School Hours care in 30 locations. Alongside this care, St Nicholas Pathways program supports study and career options for early education.
Catholic Community Fund, assisting with the management of Diocesan finances and providing retail customers a range of investment products.
In addition to our agencies, we also have a diverse range of departments that form part of the Diocesan Curia to support our agencies serve the mission of the Diocese:
Mission & Evangelisation is an outward-looking team that shares the message of the Gospel with the contemporary world. It provides Diocese-wide leadership in accompaniment and resourcing for Catholic formation, training, and encounter. The three teams are: Mission & Evangelisation Partners, who accompany and support the Diocese and parish communities into the future; the Directorate who supports the Partners with shared leadership, resourcing, project planning, communications and administration; and Chaplains who provide accompaniment, pastoral and spiritual care to those in our unique part of the world.
The Office of Safeguarding promotes the safety and wellbeing of children and vulnerable adults in our Diocese through a range of programs and activities including:
• the provision of specialist advice and support
• conducting administrative inquiries into allegations of abuse against Diocesan workers
• supplying online and face-to-face safeguarding training for Diocesan workers
• supporting our parishes and Diocesan agencies to be compliant with Church and statutory safeguarding standards.
Shared Services brings together multiple specialists with varying backgrounds that offer resources and services to support the agencies and parishes. These Shared Services teams include: Administrative Services; Communications and Marketing; Data and Analytics; Finance; Governance; People and Culture; Property; and Technology Services.
148,000+ Catholic Population Diocese of Maitland-Newcastle
The Diocese of Maitland Newcastle procures a broad range of goods and services necessary to support its operations and service delivery across the Diocese. Procurement activities are conducted in accordance with relevant legislative requirements and the Diocese’s procurement policies and procedures.
The Diocese’s supply chains primarily operate within Australia and span a variety of sectors. Key procurement categories include building and construction services, facilities and property maintenance, furniture and office supplies, information and communications technology (ICT) hardware and services, food and beverage supplies, events and hospitality services, and waste management services.
These supply chains support the day to day operations of diocesan agencies and services, including education, early childhood education and care, social services, housing and community programs.
Some of these sectors are recognised as having an increased risk of modern slavery due to factors such as labour intensity, subcontracting and complex supplier arrangements, which informs the Diocese’s ongoing approach to risk identification and management.
The Diocese of Maitland Newcastle applies AS ISO 31000:2018 risk management principles, frameworks and processes to support consistent risk identification, assessment and decision making across its ministries, activities and operations. These principles underpin the Diocese’s approach to identifying and managing modern slavery risks within its operations and supply chains.
The Diocese’s core operations are primarily delivered in the education, social services and pastoral ministry sectors, which are generally regarded as lower risk environments for modern slavery. People and Culture functions, including recruitment and workforce management, are supported by systems and processes designed to comply with applicable labour, employment and immigration laws. Due diligence processes are in place to support fair and transparent recruitment practices, promote equal opportunity, and ensure appropriate remuneration and working conditions.
To support early identification of issues and ongoing assurance, the Diocese engages an independent and anonymous whistleblower service and maintains an internal audit program to monitor the effectiveness of its control environment. Since 2024, the Diocese has had a Whistleblower Procedure under its overarching Whistleblower Policy, setting out the mechanisms for reporting fraud, corruption, maladministration and misconduct.
Building on prior years, the Diocese’s modern slavery actions in 2025 focused on strengthening governance arrangements, systems and operational capability. Key initiatives included continued implementation and enhancement of financial management systems and People and Culture systems, strengthened risk assessment processes, targeted training and development for staff, and a review of procurement practices and supplier engagement approaches.
Improvements and enhancements to systems during the reporting period in the onboarding and recruitment module, learning management system for People and Culture, and procurement module supporting end to end purchasing processes within the finance system. The procurement module has improved controls over purchase approvals and strengthened the linkage between procurement activity, expenditure visibility and budget forecasting.
During 2025, governance frameworks across the Diocese were further strengthened through refinements to the Complaints and Feedback Framework, the Complaints Management Service, and the Risk Management Framework, aligned with enhancements to the Enterprise Risk Management System and associated training. The Policy Management Framework and Delegations Framework were also reviewed, including the introduction of a new diocesan wide platform for the Policy Library and the Delegations Register, and commencement of work on a refreshed Compliance Framework.
Through participation in the Australian Catholic Anti Slavery Network (ACAN) program, the Diocese continues to prioritise engagement with labour intensive suppliers and operational areas that may present an elevated risk of modern slavery. These include the following labour supply chains:
The cleaning and security sectors are recognised through the Australian Catholic Anti Slavery Network (ACAN) as presenting heightened modern slavery risks due to labour intensive work, extensive subcontracting arrangements, and reliance on temporary or migrant labour. Risk factors may include underpayment, excessive working hours, limited access to workplace rights information, and reduced worker visibility. Equipment and consumables used in these sectors are commonly manufactured overseas, including in jurisdictions with a higher prevalence of modern slavery risks.
To strengthen governance and reduce exposure to these risks, the Diocese of Maitland Newcastle has transitioned all cleaning arrangements across its sites to a whole of government contract, ensuring improved oversight, due diligence, and supplier accountability.
Facilities management and property maintenance services may present increased modern slavery risks where work is delivered through layered subcontracting and labour hire arrangements. These structures can reduce transparency and oversight of employment conditions, particularly where migrant or low skilled workers are engaged.
To improve governance and visibility over these risks, the Diocese of Maitland Newcastle utilises its own Property Services Agency, which manages facilities management and property maintenance for most of its properties. This centralised model strengthens oversight, reduces reliance on complex subcontracting chains, and enables more consistent due diligence practices.
Labour hire services are recognised by ACAN as a higherrisk labour supply model due to the engagement of vulnerable worker cohorts and limited worker bargaining power. Risk indicators may include recruitment practices targeting temporary visa holders, international students or recent migrants; unclear contractual arrangements; excessive fees or deductions related to recruitment or migration; and practices that restrict worker mobility or access to support mechanisms. The Diocese of Maitland-Newcastle rarely uses labour hire companies for temporary appointments, with only one person engaged under such an arrangement in 2025. This limited use significantly reduces exposure to the higher-risk characteristics associated with labour hire models.
The waste and recycling sector is recognised as a higher risk environment due to hazardous working conditions,
reliance on subcontracting, and the frequent use of labour hire arrangements. Workers may include migrants and low skilled labour engaged in collection, sorting, and processing activities. Risk factors often mirror those present in cleaning and facilities services, including reduced oversight of employment conditions and subcontractor compliance.
To enhance governance and reduce exposure to these risks, the Diocese of Maitland Newcastle has transitioned all waste management arrangements across its sites to a whole of government contract established by the NSW Treasury Department under Veolia, ensuring strengthened oversight, due diligence, and supplier accountability.
Based on the identified operational and supply chain risk profile, the Diocese of Maitland Newcastle is continuing to strengthen its approach to modern slavery risk management. Priority actions are focused on improving supplier engagement within higher risk labour intensive sectors, strengthening due diligence and procurement controls, building workforce awareness and capability, and enhancing internal reporting and oversight mechanisms. These actions are integrated into the Diocese’s governance, risk and compliance frameworks and are outlined in detail under Criterion 5 of this Statement.
The diversity and scale of diocesan agencies results in procurement across a wide range of goods and services and engagement with a significant number of suppliers. During the reporting period, the Diocese undertook a high level supply chain risk assessment of more than 3671 active suppliers to identify areas of potential modern slavery risk.
Suppliers were categorised by industry sector and assessed using recognised modern slavery risk indicators, including labour intensity, reliance on subcontracting or labour hire, use of migrant or temporary workers, and exposure to offshore manufacturing in higher risk jurisdictions. This assessment was designed to identify sectors with an elevated risk profile, rather than to identify incidents of modern slavery.
Based on this analysis, the Diocese considers the risk that it may cause or contribute to modern slavery in its operations and supply chains to be low. However, consistent with sector guidance, certain procurement categories have been identified as presenting a higher inherent risk of modern slavery due to their structural characteristics.
The following table summarises the relative modern slavery risk rating applied to key supplier categories:
High risk sectors
• Building and construction
• Cleaning and security services
• Facilities management and property maintenance
• Furniture and office supplies
• ICT hardware
• Events and entertainment
• Uniforms and personal protective equipment (PPE)
• Waste management
• Labour hire
These sectors are generally characterised by labour intensive work, extensive subcontracting arrangements and/or complex supply chains involving offshore manufacturing, which can reduce transparency and increase the risk of worker exploitation.
Medium risk sectors
• Advertising and marketing
• Fleet management, consumables and maintenance
• ICT software and network services
• Travel and accommodation
Low risk sectors
• Professional services
• Government and agency fees
Risk ratings are reviewed periodically to reflect changes in supplier profiles, service delivery models and emerging risk indicators.
Following completion of the high level supplier risk assessment, the Diocese undertook a spend based analysis to better understand its exposure within procurement categories assessed as presenting a higher inherent risk of modern slavery. This analysis considered the nature of goods and services procured, labour intensity, reliance on subcontracting or labour hire, and the extent of offshore manufacturing or extended supply chains.
The table below outlines supplier categories assessed as higher risk and the proportion of total spend attributable to each category during the reporting period. The spend analysis has been used as one indicator to support the prioritisation of due diligence activities and supplier engagement, noting that spend level alone does not determine the presence of modern slavery.
Key high risk categories
Building and construction (35.45%)
Building and construction represents the highest proportion of spend within higher risk categories. This sector is recognised as presenting elevated modern slavery risks due to extensive subcontracting, labour hire arrangements, and reliance on low skilled and migrant labour. Risks may arise across demolition, landscaping, painting and specialist trade activities where visibility of employment conditions is reduced.
Facilities management and property management (17.93%)
Facilities management and property maintenance services involve ongoing labour intensive activities, often delivered through multiple subcontractors. Risk factors include reliance on temporary or migrant workers, fragmented service delivery models and limited transparency across supply chains.
Furniture and office supplies (5.22%) and ICT hardware (6.10%)
These categories present modern slavery risks primarily through offshore manufacturing supply chains. Furniture, office supplies and ICT hardware often rely on global production networks that may involve forced labour, exploitative working conditions or child labour, particularly in higher risk manufacturing jurisdictions.
Food and catering services (2.28%)
Food and catering services involve complex supply chains encompassing agriculture, food processing and hospitality labour. Risk drivers may include seasonal labour, migrant workers, low wages and limited oversight across upstream suppliers.
Cleaning and security services (3.30%)
Although representing a lower proportion of spend, cleaning and security services are recognised as higher risk sectors due to labour intensive work, subcontracting arrangements and reliance on vulnerable worker cohorts, including temporary visa holders.
Events and entertainment (1%)
Event related services may involve short term engagements, subcontracting and casual labour, presenting risks where worker conditions and employment arrangements are less visible.
Uniforms and PPE (0.53%), medical devices and supplies (0.46%) and waste management (0.24%)
These categories present modern slavery risks associated with offshore manufacturing, hazardous work environments and subcontracting arrangements. Waste management services may involve migrant or low skilled labour engaged through labour hire firms.
Finance and investments (7.16%)
While the inherent risk of modern slavery within financial services is generally lower, exposure exists through investment portfolios and financed entities. This category is monitored to support responsible investment practices and alignment with ethical investment principles.
spend and risk
The Diocese recognises that higher spend does not necessarily correlate with a higher likelihood of modern slavery occurring. Rather, this analysis is used to identify areas of greater exposure and complexity, enabling a risk based and proportionate approach to managing modern slavery risks across supply chains.
In addition to higher risk categories, the Diocese has identified a number of procurement categories assessed as presenting medium or lower inherent modern slavery risks. These risk ratings reflect the nature of the goods and services procured, typical labour models, level of regulatory oversight, and the transparency and stability of supplier arrangements.
Spend analysis has been used as a supporting indicator to inform prioritisation, recognising that modern slavery risks may still arise in medium and lower risk categories and warrant ongoing monitoring.
Medium risk categories generally involve a combination of service delivery and supply chain complexity, with some exposure to subcontracting, offshore service delivery or extended global supply chains. While these sectors are often subject to regulatory oversight, reduced visibility or indirect labour engagement may increase vulnerability in certain circumstances.
Advertising and marketing (0.56%)
Advertising and marketing services may involve outsourced production, creative services or digital content development, including engagement of contractors or offshore service providers. Risks may arise where labour standards and working conditions are less transparent.
Fleet management, consumables and maintenance (1.31%)
This category includes vehicle servicing, repairs and associated consumables, which may involve subcontracted labour and supply chains for parts and materials.
ICT software and network services (4.10%)
ICT software and network services may include offshore programming, application development or support services. Risks are typically associated with outsourced service models and extended global labour supply chains.
Travel and accommodation (1.99%)
Travel and accommodation services can involve complex labour supply chains across hospitality and tourism sectors, with risks linked to casualised labour, migrant workers and subcontracted services.
Utilities (1.18%)
Utilities include electricity, water and telecommunications services. These sectors generally operate within regulated environments; however, upstream risks may exist in relation to infrastructure development, resource extraction or outsourced service delivery.
risk supply chains
Low risk categories are generally characterised by strong regulatory oversight, professional accountability mechanisms and established market practices. These suppliers typically operate within Australia and involve lower exposure to vulnerable labour cohorts or extended global supply chains.
Government and agency fees (5.02%)
Payments to government agencies, statutory bodies and regulators are assessed as low risk given the nature of the transactions and regulatory environment.
Professional services (5.81%)
Professional services such as legal, accounting, auditing and consultancy services operate under professional standards and regulatory frameworks, reducing inherent modern slavery risk.
Licences and memberships (0.18%)
Fees associated with licences and professional memberships present limited exposure to modern slavery risks.
While these categories are assessed as medium or low risk, the Diocese recognises that modern slavery risks can arise across all supply chains. Accordingly, risk ratings are reviewed periodically, and suppliers across all categories remain subject to broader governance, procurement and compliance controls.
35.45%
Building and construction
17.93%
Finance and investments HIGH
Facilities management and property management
7.16%
6.10%
ICT hardware
5.22%
Cleaning and security services
Furniture and office supplies 2.28%
Food and catering services
1%
Events and entertainment
0.53%
Uniforms and PPE 0.46%
Medical devices and supplies
0.24%
Waste management 3.30%
During the 2025 reporting period, the Diocese of Maitland Newcastle focused on strengthening organisational understanding of modern slavery risks across its operations and supply chains and enhancing its capacity to address and mitigate those risks through improved governance, systems, supplier engagement and workforce capability.
Strengthening systems, governance and procurement controls
The continued rollout of the TechnologyOne (TechOne) platform has significantly strengthened procurement, financial and supplier management processes across the Diocese. Improvements to supplier data, expenditure visibility and approval workflows have enhanced the Diocese’s ability to identify and manage supply chain risks, including modern slavery risks. These system improvements are being progressively extended, including within education and early childhood related procurement activities.
Modern slavery contract clauses continue to be embedded as a standard requirement in all new supplier contracts and contract renewals, reinforcing supplier obligations and expectations. These controls are supported by broader governance reforms implemented during 2025, including updates to the Delegations Framework, Risk Management Framework, Complaints Framework, and rollout of a diocesan wide Policy Management System and Delegations Register.
The Diocese is an active member of the Australian Catholic Anti Slavery Network (ACAN), a collaborative initiative comprising more than 95 Catholic entities nationally across education, finance, health, aged care and social services. Through ACAN, the Diocese participates in a coordinated program to assess and address modern slavery risks in shared supply chains.
During the reporting period, the Diocese participated in the ACAN supplier engagement program, which involved:
• identifying suppliers in higher risk procurement categories using the ACAN Procurement Taxonomy;
• inviting suppliers in these categories to complete the ACAN Supplier Survey;
• supporting suppliers to join Sedex – Supplier Ethical Data Exchange, where appropriate; and
• assessing supplier responses to identify gaps, training needs and opportunities to strengthen risk management practices.
As part of this process, a significantly larger cohort of suppliers participated in the ACAN Supplier Survey compared with previous years. A notable portion were already engaged through platforms such as Sedex, and many completed the Sedex Self-Assessment Questionnaire (SAQ). ACAN Program Managers analysed SAQ outcomes and collaborated with suppliers to strengthen their practices, including building capability and enhancing risk management approaches.
The ACAN program also identified common suppliers shared across multiple Catholic entities, increasing leverage in supplier engagement and reducing duplication across diocesan systems.
Since mid 2021, the Diocese has held membership of Sedex, a global not for profit platform supporting ethical and sustainable supply chain practices. Sedex enables enhanced transparency, collaboration and information sharing with suppliers and buyers.
Through Sedex, the Diocese is able to:
• identify and monitor modern slavery and labour rights risks within supplier profiles;
• validate inherent risk against supplier reported management practices;
• improve visibility into upstream supply chains;
• support screening of new suppliers during tender and onboarding processes; and
• monitor and report on supplier progress over time.
ACAN Program Managers continue to support onboarding of diocesan suppliers to Sedex and facilitate access to relevant training and resources.
Supplier engagement and education formed a key part of the Diocese’s 2025 modern slavery response. ACAN supplier webinars supported suppliers to build understanding of:
• the Modern Slavery Act and business relevance;
• Catholic buyer expectations;
• access to ACAN training resources; and
• Sedex supplier membership and reporting requirements.
Suppliers were provided with clear, consistent guidance on participation steps, including completion of ACAN surveys, participation in webinars, registration with Sedex, and access to ACAN e learning modules.
The Diocese continued to build internal capability and awareness through training and communication initiatives. Modern slavery training is available to all staff via mnpeople, the Diocese’s learning management platform, including the ACAN Modern Slavery 101 module. Modern slavery information is incorporated into staff induction processes, alongside information on the independent whistleblower service.
The Diocese’s Modern Slavery Liaison Officer(s) participated in ACAN teleconferences, workshops and peer collaboration initiatives throughout the reporting period to support continuous improvement and shared learning. Modern slavery updates were provided regularly to diocesan leadership groups to support oversight, accountability and informed decision-making.
In addition to internal capability-building, the Diocese actively promotes awareness and education within the broader community. Each year, the Diocese holds a Feast Day celebration in honour of Saint Josephine Bakhita, the
Patron Saint of Victims of Modern Slavery and Human Trafficking. This event provides an opportunity for prayer and reflection, asking for God’s freedom and justice for all who suffer because of human trafficking, slavery and persecution, and for their dignity, respect and peace to be restored.
The Diocese also provides information and educational resources about Saint Josephine Bakhita through its dedicated St Josephine Bakhita Working Party Group, which engages with schools and parish communities to raise awareness of modern slavery and promote Catholic Social Teaching on human dignity and justice.
The Diocese recognises that managing modern slavery risk is an ongoing process. Supplier expenditure analysis and information gathered through ACAN engagement continues to inform prioritisation of future actions as part of a five year program to deepen understanding of supply chains, strengthen supplier relationships and embed modern slavery risk management into business as usual practices.
The Diocese of Maitland Newcastle has continued to progress its modern slavery maturity journey by strengthening management systems, enhancing governance practices, undertaking risk assessment activities, building workforce capability, and deepening supplier engagement. These focus areas align with the Diocese’s risk based approach and its commitment to continuous improvement in managing modern slavery risks across operations and supply chains.
During the 2025 reporting period, external economic, geopolitical and environmental factors continued to shape the operating environment. Cost of living pressures affected parish communities and service delivery costs, particularly within building, construction and facilities related services. A tight labour market and ongoing workforce pressures also influenced the availability of skilled and qualified staff across education and early education services. These contextual factors reinforced the importance of strong governance, prudent procurement and informed supplier engagement to mitigate modern slavery risks.
Strengthening governance and management systems
Internally, the Diocese implemented and enhanced several diocesan wide governance frameworks to support consistent practice and alignment across agencies.
Key initiatives included:
• continued enhancement of onboarding and recruitment systems to support compliant workforce practices including implementation of a new recruitment and selection procedure;
• improvements to the learning and development management system to support staff capability and awareness;
• ongoing enhancements to the Enterprise Risk Management System to strengthen risk identification, reporting and oversight;
• introduction of a diocesan wide policy and delegation management system to centralise governance instruments and improve accessibility;
• rollout of a centralised procurement system to support supplier engagement, strengthen financial controls, and improve monitoring of budget forecasts and expenditure; and
• review of the Procurement Framework and supplier engagement practices, including completion and publication of a new Procurement and Probity Policy.
As part of continuous governance improvement, the Diocese also reviewed and refreshed its Modern Slavery Framework and re established the Modern Slavery Liaison Committee to strengthen coordination, oversight and accountability across diocesan agencies. In parallel, People and Culture, Governance and Senior Leadership commenced a diocesan wide review of work related policies to ensure alignment with legislative obligations, contemporary standards and risk management expectations.
While workforce and resourcing pressures required adjustments to the pace of some initiatives during 2025, the Diocese continued to implement its five year modern slavery roadmap and maintained a focus on service excellence, quality assurance, compliance monitoring and capability development.
During this period, changes in procurement resourcing presented an opportunity for the Diocese to consolidate existing improvements, reflect on the effectiveness of current arrangements, and assess how best to leverage available systems and governance frameworks. This review period supported a more deliberate and strategic consideration of the systems, procedures and resourcing models required to effectively identify and mitigate modern slavery risks across procurement activities.
This reflective phase has informed broader strategic planning and the development of future priorities, including consideration of how procurement governance, system functionality and roles can best support a risk based approach to supplier due diligence and engagement as the Diocese transitions to its next phase of program maturity.
The Diocese is concluding its original five year modern slavery plan and is commencing planning for a new roadmap covering 2026–2030. This next phase will build on existing foundations, lessons learned and program maturity, with a focus on strengthening supplier due diligence, enhancing data driven risk analysis, deepening workforce and supplier capability, and embedding modern slavery risk management into business as usual governance and procurement practices.
Building on the foundations established during the 2025 reporting period, the Diocese of Maitland Newcastle will continue to strengthen its approach to identifying, assessing and addressing modern slavery risks across its operations and supply chains in 2026.
Key priorities for the next reporting period include embedding modern slavery risk management more deeply into business as usual governance, procurement and contract management practices, with a particular focus on higher risk labour intensive and manufacturing supply chains. This includes strengthening risk based due diligence processes, supplier engagement and contract controls within priority procurement categories.
The Diocese will continue to leverage participation in the Australian Catholic Anti Slavery Network (ACAN) and the use of Sedex to enhance supplier transparency, validate inherent risks against supplier practices, and support continuous improvement across shared supply chains.
A further priority for 2026 will be strengthening the measurement and evaluation of the effectiveness of existing controls and actions, to support informed decision making and continuous improvement. This includes improving data driven insights, monitoring supplier progress over time, and refining governance reporting mechanisms.
The Diocese will also focus on building targeted capability within key operational roles, particularly in procurement, property, People and Culture and governance functions, to ensure staff are equipped to identify modern slavery risks and respond appropriately.
As the Diocese concludes its initial five year modern slavery roadmap, a refreshed 2026–2030 Modern Slavery Action Plan will be developed to build on existing achievements, lessons learned and increasing program maturity, and to support a proportionate, risk based and sustainable approach to modern slavery risk management into the future.
The Diocese of Maitland Newcastle is committed to providing appropriate, timely and effective remedy where people are identified as having been impacted by modern slavery, in accordance with the United Nations Guiding Principles on Business and Human Rights, the Modern Slavery Act 2018 (Cth), and relevant Australian laws.
Consistent with Commonwealth guidance, the Diocese recognises that access to remedy is a fundamental element of a responsible response to modern slavery risks. Remedy focuses on addressing actual harm to individuals, restoring their rights and dignity where possible, and taking steps to prevent recurrence through improved controls and practices.
The Diocese’s remediation approach is guided by the following principles:
• ensuring the safety, wellbeing and protection of people impacted by modern slavery;
• adopting a human rights based approach that prioritises the needs and agency of individuals;
• ensuring that any actions taken are informed, voluntary and undertaken with the full knowledge and consent of the person impacted; and
• maintaining confidentiality and dignity throughout the process.
• Where concerns or incidents are identified, the Diocese seeks to respond promptly through appropriate investigation, escalation and engagement with relevant support services, aligned to the nature and severity of the risk.
Through participation in the Australian Catholic Anti Slavery Network (ACAN), diocesan agencies and parishes have access to independent specialist advice and support provided by Domus 8.7. This support framework strengthens the Diocese’s remediation capability by providing clear pathways for escalation, guidance and coordinated responses.
Agencies and parishes may refer matters where modern slavery is suspected or identified to obtain advice and support on appropriate responses, including engagement with government agencies, victim support organisations and other relevant stakeholders.
Domus 8.7 operates as a confidential and independent service within the ACAN program and supports Catholic entities to respond effectively to modern slavery risks. Its role includes:
• providing guidance and advice to entities that identify or suspect modern slavery;
• supporting coordination with government bodies and specialist victim support services;
• offering a confidential, independent grievance mechanism for reporting suspected incidents;
• supporting the development of internal capability to manage complex modern slavery and human rights issues; and
• facilitating practical, timely and survivor centred responses.
This framework supports the Diocese’s commitment to Catholic Social Teaching and the protection of human dignity, while strengthening its capacity to respond appropriately should modern slavery risks be identified in its operations or supply chains.
As the Diocese of Maitland Newcastle continues to strengthen its approach to identifying, assessing and addressing modern slavery risks, it will build on the foundations established through its initial five year roadmap and progressively embed modern slavery risk management into business as usual governance, procurement and operational practices.
Governance
Organisational commitment
Business systems
Actions and standards
Monitoring and reporting
Awareness and accountability
Policies and accountability frameworks
Training and capability
Labour hire and outsourcing
Procurement and supply chains
Contract management
Screening and traceability
Supplier engagement
Monitoring and corrective action
Risk framework
Beyond 2026, the Diocese’s focus will shift toward deeper integration, stronger measurement of effectiveness, and sustained engagement with higher risk supply chains, guided by a proportionate, risk based approach. The following workstreams outline the Diocese’s intended areas of focus over the next phase of its modern slavery program.
Leadership and Senior Management oversight of modern slavery risk management will continue, with performance, priorities and progress reported through established governance channels. Modern slavery considerations will remain integrated into enterprise risk management and strategic decision making.
Senior leadership will continue to champion the Diocese’s commitment to addressing modern slavery risks and support the ongoing implementation of its modern slavery program across agencies.
Modern slavery risk management will continue to be embedded within key systems, policies and processes, including risk management, procurement, finance, workforce and supply chain systems.
Risk based actions, standards and expectations will continue to be applied to priority supply chains, with progress monitored and reported through existing governance and assurance mechanisms.
The Diocese will continue to collect, analyse and report information on modern slavery risks and actions as part of its continuous improvement and assurance processes, informing future priorities and decision making.
Targeted awareness raising and role based guidance will continue to support staff understanding of modern slavery risks, responsibilities and escalation pathways.
Modern slavery commitments will remain integrated into relevant policies, position descriptions and accountability frameworks, with expectations reflected in recruitment, procurement and contractor engagement practices.
Targeted training and capacity building initiatives will continue to support staff and key stakeholders to identify and respond to modern slavery risks relevant to their roles.
The Diocese will continue to apply and strengthen due diligence and engagement with labour hire and outsourced service providers, particularly in higher risk labour intensive sectors.
Procurement policies, processes and guidance will continue to be refined to support risk based supplier engagement, due diligence and contract management in higher risk procurement categories.
Contract management practices will continue to incorporate modern slavery expectations and review mechanisms for higher risk contracts, supporting accountability and continuous improvement.
The Diocese will continue to strengthen supplier screening and information gathering practices to improve supply chain visibility where practicable, particularly within priority risk categories.
Ongoing engagement with suppliers will continue through participation in ACAN and the use of tools such as Sedex, supporting collaboration, transparency and shared improvement.
Supplier performance and risk indicators will continue to be monitored using a range of tools, with engagement and corrective action undertaken where issues or gaps are identified.
Human rights and modern slavery risks will remain integrated within broader risk assessment and assurance processes, with periodic review of control effectiveness to support continuous improvement.
The Diocese of Maitland Newcastle measures the effectiveness of its actions to assess and address modern slavery risks through a combination of qualitative and quantitative indicators. These measures support ongoing evaluation of governance arrangements, workforce capability, supplier engagement and remediation pathways, and inform continuous improvement of the Diocese’s modern slavery program.
Frameworks and maturity assessment
During the reporting period, the Diocese undertook an initial assessment of its approach to managing modern slavery risks across key domains, including management systems, enterprise risk management, People and Culture functions, stakeholder and supplier engagement, and procurement and supply chains.
As part of its participation in the Australian Catholic Anti Slavery Network (ACAN), the Diocese commenced completion of the ACAN Entity Profile and associated maturity assessment. This marks a transition from an initial foundation building phase to a more embedded approach, with modern slavery risk management increasingly integrated into business as usual governance, systems and processes.
The Diocese has developed a suite of metrics to provide a consistent and objective basis for assessing the effectiveness of its actions over time. These indicators capture both activity based outputs and changes in engagement and capability, supporting an understanding of program reach, areas of progress and opportunities for improvement.
Metrics are reviewed regularly and are used to:
• assess the uptake and reach of staff training and awareness activities;
• monitor supplier engagement in higher risk categories;
• track participation in ACAN and Sedex initiatives; and
• assess the responsiveness and accessibility of grievance and remediation pathways.
During the reporting period, supplier engagement with the ACAN Supplier Survey increased significantly, reflecting stronger participation across a broad range of procurement categories. Suppliers operating in higher risk categories were invited to join Sedex and complete a Self Assessment Questionnaire (SAQ), further enhancing the Diocese’s ability to assess and monitor supplier reported management practices.
A substantially larger group of suppliers is now connected to the Diocese through Sedex compared with earlier reporting periods, providing improved visibility of risk indicators within priority supply chains. This expanded engagement has deepened the Diocese’s understanding of supplier practices and strengthened oversight of potential modern slavery risks.
In addition, many suppliers participated in ACANled capacity building webinars, supporting improved awareness of modern slavery risks, legislative obligations, and supplier responsibilities.
Effectiveness is also monitored through internal capability indicators, including staff participation in modern slavery training, Modern Slavery Liaison Committee activity, and the integration of modern slavery risk considerations into governance and assurance processes. These indicators support ongoing assessment of organisational awareness, accountability and leadership oversight.
The Diocese monitors the effectiveness of its grievance and remediation mechanisms through reporting on access to and use of available channels, including whistleblower mechanisms and Domus 8.7 referrals. During the reporting period, no contacts, referrals or remediation cases related to modern slavery were reported through Domus 8.7.
The absence of reported cases does not in itself indicate an absence of risk. Rather, the Diocese recognises that ongoing awareness raising, accessible reporting pathways and trusted support mechanisms are critical to ensuring concerns are identified and addressed where they arise.
Effectiveness measures are reviewed periodically to ensure they remain appropriate to the Diocese’s evolving risk profile and program maturity. Insights gained through supplier data, system enhancements, audits and ACAN collaboration are used to refine controls, prioritise actions and inform future planning.
The Diocese will continue to strengthen its approach to measuring effectiveness as its modern slavery program matures, with a focus on improving data quality, targeting measures to higher risk areas and strengthening the link between identified risks and mitigation outcomes.
The Diocese of Maitland Newcastle consults with entities it owns or controls through established governance, coordination and engagement mechanisms to support a consistent and coordinated approach to managing modern slavery risks across the Diocese.
The Diocese has established and re established a Modern Slavery Liaison Committee (MSLC) comprising representatives from diocesan agencies and Curia departments. The MSLC provides a key forum for consultation, information sharing and collaboration on the development, implementation and ongoing refinement of the Diocese’s Modern Slavery Action Plan. Through this forum, agencies contribute to identifying operational and supply chain risks, sharing insights, and supporting consistent application of modern slavery policies and procedures across the Diocese.
The activities set out in the Modern Slavery Action Plan are designed to embed the management of modern slavery risks into the day to day operations of diocesan agencies. Consultation occurs through agency representation on the MSLC, participation in ACAN initiatives, and engagement in governance and risk management processes that apply across the Diocese.
In addition, consultation and engagement are supported through communication and capability building initiatives. A refreshed and updated ACAN Modern Slavery 101 training module has been embedded within the Diocese’s learning management system and is available to all staff via self enrolment. This supports consistent awareness raising and understanding of modern slavery risks and expectations across diocesan entities. Targeted communications and resources have also been implemented to promote awareness and support improved practices for identifying, assessing and managing modern slavery risks across the Diocese.
In addition to the actions outlined in this Statement, the Diocese of Maitland Newcastle continues to engage with broader sector initiatives and shared learning opportunities to strengthen its understanding of modern slavery risks and emerging trends.
Throughout the reporting period, the Diocese actively participated in the Australian Catholic Anti Slavery Network (ACAN) webinar series. These regular sessions provided timely updates on legislative developments, emerging risks, sector insights and practical tools to support effective modern slavery risk management. Topics included the rollout of new ACAN systems,
updates to training and e learning resources, supplier engagement and due diligence practices, and guidance on Sedex and reporting expectations.
Participation in these forums supports continuous professional development, knowledge sharing and alignment with best practice approaches across Catholic entities nationally. Insights gained through ACAN engagement inform the Diocese’s ongoing program development, workforce capability building and supplier engagement activities.
A summary of ACAN webinar topics attended during the reporting period is provided below.
Feb Modern Slavery Updates - New online system introduced called ROTA
Mar Modern Slavery Updates
Apr Modern Slavery Updates - e-Learning module updated and Domus 8.7 Presentation
May
Modern Slavery Updates – Guest Speaker Natasha Murphy - Approved Employer insight - Pacific Australia Labour Mobility Scheme
June Modern Slavery Updates
July Modern Slavery Updates
Aug Modern Slavery Updates - Supplier Engagement Update
Sep Modern Slavery Updates - continued rollout of ROTA: Company Profile now available for completion
Oct Modern Slavery Updates - Help with Sedex: Guest Speaker Alex Walrut
Nov Modern Slavery Updates
Dec Modern Slavery Updates - 2025 Statements timeline