Appendix C

Modern Slavery Statement

The following disclosures are made in accordance with the Commonwealth Modern Slavery Act 2018. Landcom meets the threshold for a reporting entity, as outlined in the Act. This Statement has been approved by the Landcom Board, and signed by John Brodgen Chief Executive Officer.

Landcom chooses to include its required Statement as a component of our annual Sustainability Report, which also provides comprehensive details on our approach to Human Rights.

This Modern Slavery Statement is third party assured against the requirements and criteria set out in the Act.

Content in this Statement is set out to provide an overview of Landcom’s approach and response to the Mandatory Criteria outlined in the Act. For further detail on Landcom’s approach to Modern Slavery, including our commitment to continuous improvement, refer to Accountable & Collaborative Places Overview. 

Links to Global Reporting Index, United Nations Global Compact or other related content within the body of the FY20 Sustainability Report are also provided, in order to give the reader access to relevant or complementary detailed content in respect to Landcom’s management of Human Rights and Modern Slavery.

John Brogden signature

John Brogden
CEO, Landcom

Mandatory Criteria
Landcom Response

Criteria 1: Identify the reporting entity.

Landcom Response

This Statement covers Landcom as the reporting entity.

Criteria 2: Describe the structure, operations and supply chains of the reporting entity.

Landcom Response


Landcom is a NSW Government State Owned Corporation, created by the Landcom Corporation Act 2001.

Landcom sits within the NSW Department of Planning & Environment cluster, however is not part of a larger corporate group of entities, and does not control or own any other entities.

Landcom annual disclosures regarding Ownership and Legal Form is presented in GRI 102-05.

Landcom’s annual disclosures regarding Information on Employees and Other Workers is presented in GRI 102-08.


Landcom is the NSW government’s property development organisation. Landcom’s leadership intent is to create more affordable and sustainable communities.

We act as a master developer, developer and builder where appropriate to
achieve outcomes for our stakeholders. This includes partnerships with the NSW Government departments and external commercial entities to maximise our impact for the benefit of NSW communities.

As a masterplan developer we use a variety of structures to deliver projects. The key types of project structures that we use are:

  • Owner/Master Developer

  • Project Delivery Agreement (PDA)

  • Reverse Project Delivery Agreement (RPDA)

  • Joint Ventures (JV)

For further information on these types of structures, and a map of our current projects refer to Reporting Boundaries and Landcom Places.

Other operations that complement, however may not be specific to a particular development project, includes research and development investment via Landcom’s Roundtable (refer to Research Investment).

Landcom does not have any formal charitable interactions. 

Supply Chains

Products provided by suppliers

Products provided to Landcom are predominantly corporate in nature, such as office furniture and supplies, and basic kitchen amenities such as tea and coffee for staff.

Services provided by suppliers

Landcom’s main supply chain consists of services provided by suppliers that enable master development and building projects. This can be split into two generalised categories of:

Corporate services: includes but is not limited to legal and specialist consultant services related to the planning and development of land.

Project development services: includes but is not limited to services at project development sites such as principal contracting, civil and landscape services.

Products and services used by indirect suppliers in supply chains

Indirect products and services related to Landcom’s operations include but are not limited to related corporate services (e.g. specialist consultants and their labour force), project development sub-consultant services provided to principal contractors, and raw or manufactured materials and machinery that enable development works to occur.

Landcom’s annual disclosures regarding Supply Chain, including our Management Approach and Performance Targets is referred to at GRI 102-08.

Criteria 3: Describe the risks of modern slavery practices in the operations and supply chains of the reporting entity.

Landcom Response

The property and construction industry has extensive supply chains that can extend to multiple, international tiers. By undertaking a Human Rights Salience Assessment, Landcom has initially identified supply chain forced labour and materials sourcing as the dominant areas of risk to modern slavery.

Landcom staff are employed under an award or senior management contract. Our day to-day work is predominantly office based. Services such as planning and design, or construction, is undertaken as identified above in our supply chain disclosures.

Landcom’s two offices tenancies are leased in reputable commercial property developers that are also reporting entities under the Act. As such, Landcom’s immediate operations have are considered low risk to modern slavery.

Criteria 4: Describe the actions taken by the reporting entity to assess and address those risks, including due diligence and remediation processes; and

Criteria 5: Describe how the reporting entity assesses the effectiveness of such actions.

Landcom Response

A range of actions have already been undertaken, or are planned, as part of our commitment to continuous improvement.

Where we are today

Assessing effectiveness


  • Completion of Human Rights Salience Assessment by independent experts to understand Landcom’s key areas of modern slavery risk exposure.
  • Establishment of internal working group to inform and recommend business approach.
  • Adoption of Modern Slavery Management Plan to guide action, including identification, management and remediation approach.
  • Founding consortium member for the Property Council of Australia Supplier Platform, designed to engage multitiered supply chain and assess for risks of modern slavery.
  • Engaged suppliers via the Supplier Platform to determine and verify salient modern slavery risks.



  • Engaged independent expert to review Modern Slavery Management Plan, and provide guidance to continuous improvement.
  • Modern Slavery Management Plan scheduled for review on internal audit plan.
  • Reviewed disclosures made by Landcom suppliers engaged via the Supplier Platform and validated inherent risk to modern slavery compared to Human Rights Salience Assessment.
  • Monitored the rate of response to supply chain engagement via the Supplier Platform (refer to Human Rights Performance Results).


Future priorities 

  • continue to deliver on our Modern Slavery Management Plan
  • continue engagement with tier one high risk suppliers to understand their level of modern slavery risk and management maturity
  • collaborate with tier one suppliers to increase transparency of their own supply chains (Landcom’s tier 2 and beyond supply chain)
  • progressively expand our engagement and collaboration to medium and low risk suppliers
  • adopt supplier pre-qualification requirements for modern slavery disclosures
  • continue to educate our staff and stakeholders about modern slavery and how to identify potential risks
  • partner with industry experts, non-profits and organisations to adopt appropriate notification and remediation processes
  • improve existing modern slavery disclosures and requirements from entities that purchase Landcom projects to support a comprehensive risk and reputation management approach (noted this is beyond the scope of the Act). 

Landcom’s annual disclosures regarding modern slavery, including further detail on our Management Approach and Performance is presented here

GRI 408 – 412 and UN Global Compact Principles 1-5 also provide related content.

Criteria 6: Describe the process of consultation with any entities the reporting entity owns or controls.

Landcom Response

This criterion does not apply to Landcom, as the organisation has no additional owned or controlled entities. We continue to engage within our organisation, industry and our supply chain as disclosed.

Criteria 7: Include any other information that the reporting entity considers relevant.

Landcom Response

Landcom continues to proactively manage the risks of modern slavery within our operations and supply chain. We are committed members of the United Nations Global Compact, report our contribution to the Sustainable Development Goals, and have been addressing Human Rights and Modern Slavery has been part of our Sustainable Places Strategy since 2017.

Landcom’s annual disclosures regarding Modern Slavery, including further detail on our Management Approach, supply chain engagement, and continuous improvement is presented here.

Landcom’s contribution to the Sustainable Development Goals, including those related to Human Rights, is presented at APPENDIX D: Sustainable Development Goals Alignment.

Landcom’s United Nations Global Compact ‘Communication on Progress’ disclosures are presented within APPENDIX F: GRI Content Index.