Modern Slavery & Human Trafficking

This policy outlines our approach to combating modern slavery and human trafficking,  serving as our framework for compliance with international laws and standards.

Background

• Modern Slavery Act 2018 (AU)
• Modern Slavery Act 2015 (UK)
• Combating Trafficking in Persons - 48 CFR § 52.222-50 (US)
• Directive 2011/36/EU on preventing and combating trafficking in human beings and protecting its victims (EU)

We expect the same high standards from all of our contractors, suppliers and other business partners.

Scope

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners (for ease of reference throughout this policy, “employee”).

Indicators of modern slavery

Modern slavery indicators may include where a person:

1. Is not in possession of their own passport, ID or travel documents.
2. Is acting as if they are being instructed or coached by someone else.
3. Allows others to speak for them when spoken to directly.
4. Is withdrawn, appears frightened or has physical indicators of slavery, such as injuries.
5. Unable to contact friends or family freely.
6. Has limited social interaction or contact with people outside their immediate environment.
7. Acts with hostility or has difficulty in concentrating due to trauma.
8. Has few possessions.
9. Has little or no control over their finances or no access to a bank account, or they are being significantly overcharged for their accommodation.
10. Is living in a very poorly maintained and overcrowded place.

These indicators are not exhaustive and do not necessarily mean there are modern slavery practices.  Sometimes there may be other reasons or circumstances that indicate that something is not right.

Responsibilities

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all of those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Some areas of the business are likely to have more exposure than others, including procurement and sourcing, human resources, finance, risk, sustainability, projects, legal and leadership.

Examples of specific responsibilities include:

1. Participating in all training, including in this policy.
2. Leading by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc. to ensure we know who is working for us.
3. Using only approved contracts which include modern slavery clauses.

Turning a blind eye is unacceptable and if you reasonably suspect there may be modern slavery, report it under this policy.

You must report any conduct that you believe to be a violation of this policy to the Company’s People Team. Reports may also be made through the Company’s Whistleblower System, WhistleB, which allows anonymous reporting as permitted by applicable law.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

Employees who fail to report actual or suspected misconduct may be deemed in violation of this policy. 

Disciplinary actions

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or unfavourable treatment connected with raising a concern. If you believe that you have suffered such treatment, you should inform the People Team immediately. 
Any violation of this policy may be grounds for disciplinary action, up to and including dismissal for gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.¹

Our commitment

Compliance with laws and regulations
Our Company will comply with all applicable anti-slavery and human trafficking laws and regulations in the countries in which we operate.

This may include:

1. Preparing a Modern Slavery Statement where required by law.
2. Identify and address modern slavery risks in our business and supply chain.
3. Take steps to raise awareness of modern slavery risks, including having this policy.
   

Due diligence
Supply Chain: The Company will assess and monitor its supply chain to identify and address risks related to slavery and human trafficking. We will encourage our suppliers to adhere to the same principles by including relevant clauses in our contracts and agreements.

Continuous Improvement: The Company will continuously review and enhance its efforts to combat modern-day slavery and human trafficking. This includes setting objectives, implementing improvement plans, and promoting transparency.

People Team: The Company will conduct thorough checks on all employees and contractors to verify their eligibility to work in accordance with local laws.

Training and awareness

The Company, from time to time may provide training and awareness programs to employees and suppliers to ensure they understand the risks of slavery and human trafficking and know how to report concerns or suspicions.

1.  Violation of Modern Slavery Laws may also result in the criminal prosecution of responsible individuals.