Tyre Stewardship Australia has recently adopted a Modern Slavery Impact Statement. CEO, Lina Goodman addresses human rights and related risks along the end-of-life tyres value chain.
“Achieving Sustainable Development Goals is an audacious statement in itself,” Lina Goodman, Tyre Stewardship Australia (TSA) CEO, says.
There are growing calls for the Federal Government to tighten anti-slavery laws. Although the Federal Government is taking a global leadership role in combating modern slavery, corporations are encouraged, and in some instances obliged, to take further action to improve the integrity and quality of their supply chains.
This includes the Australian Modern Slavery Act, which requires large businesses to annually report on how they are identifying, assessing and addressing modern slavery risks in their operations and supply chains.
In February this year, TSA implemented its Modern Slavery Impact Statement.
Goodman says the statement is complimented by the United Nation’s Sustainable Development Goals (SDGs), which also shaped TSA’s 2020-2023 strategy.
“TSA strives to benchmark our goals and activities against the SDGs, as shown by the number of initiatives that TSA has implemented in the past two years,” Goodman says.
TSA also recognises the importance of addressing the social impacts, both positive and negative, of end-of-life tyres (EOLT). This includes ensuring that human rights are respected in the transportation, processing and use of EOLT.
“These accreditation and compliance initiatives are part of a systematic approach to make further inroads to verifying sustainable EOLT management both domestically and globally,” Goodman says.
According to TSA’s impact statement, there are a number of human rights issues that are relevant to EOLT, but one of the most salient issues where industry could have the most severe impacts is modern slavery.
“Modern slavery risks exist at all stages of the tyre lifecycle. The COVID-19 pandemic has further exacerbated workers’ vulnerabilities to exploitation, including modern slavery, around the world,” the statement reads.
TSA has prioritised two areas for action that build on existing Tyre Product Stewardship Scheme guidelines, which aim to promote the development of viable markets for EOLT: workers’ rights in Australian tyre collection and recycling facilities, and labour risks in foreign processing destinations for EOLT.
TSA says that addressing these issues is critical to the Scheme and companies in the EOLT supply chain, as well as the long-term sustainability of the tyre industry.
It also acknowledges recent legislative developments around modern slavery including the Modern Slavery Act.
“These two priority areas are a starting point. If these are met then essentially, they are building blocks to mitigate against modern slavery,” Goodman says.
In 2020, TSA introduced a requirement for accredited collectors and recyclers to complete an annual Employee Entitlements Declaration.
This declaration addresses the priority area of workers’ rights in Australian tyre collection and recycling facilities.
Collectors and recyclers are known to use casual labour on short term arrangements. TSA recognises that this can pose a risk in terms of ensuring workers receive their full entitlements, and create vulnerabilities to labour exploitation, including modern slavery.
“TSA works with accredited entities on keeping their staff, customers and the environment safe,” Goodman says.
Recyclers and collectors are subject to audits which primarily focus on participants’ commitments to support the Scheme, including reporting to TSA’s online reporting platform, downstream vendor management and environmentally sound use of EOLT.
Goodman says compliance is important as it helps put a stop to unscrupulous operators undercutting the compliant operators with unfair and unsafe work practises.
“Where employee entitlements are not met, the chance of unscrupulous operators rises,” she says.
To achieve the second priority area, Goodman highlights the establishment of TSA’s Foreign End Market Verification Program, which ensures that EOLT that leave Australia for further processing do not cause environmental or social harm.
“We do all that we can in any small way to contribute to educating our partners in mitigating against issues around modern slavery,” she says.
However, Goodman highlights that it’s important to note that modern slavery is not just an issue associated with developing economies, it’s an issue for all economies, Australia’s included.
One of TSA’s contributions to the circular economy is in form of market development, whereby over $6.3 million in the past five years has been committed to funding research and demonstration projects with the objective to utilise domestic crumb rubber in a range of projects and applications.
“TSA is encouraged and communicating the innovative concepts our own tyre member brands have introduced in order to show their ongoing commitment to sustainability,” Goodman says.
“From sustainable sourcing and redesigning tyres to keep increase the lifespan of the tyre without diminishing performance.”
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