HR PRO11 Modern Slavery Procedure

Modern Slavery Procedure

Purpose

condemns modern slavery and is dedicated to ensuring that our business operations, practices and supply chains do not contribute to, or support, any form of exploitation or forced labour. The purpose of this procedure is to outline ways we can ensure we achieve our moral and legal responsibility to uphold human rights and social justice.

Scope

The Modern Slavery Policy and Procedure applies to all employees, contractors, suppliers, partners, labour hire suppliers, and stakeholders associated with and our supply chains, and covers behaviour that occurs in work-related contexts.

Deﬁnitions

Modern Slavery

The term ‘modern slavery’ describes situations where coercion, threats or deception are used to exploit victims and undermine their freedom. Coercion, threats and deception can be explicit or implicit

Procedure

The Modern Slavery Act requires businesses earning greater than $100 million in annual revenue to:

Develop & implement a Modern Slavery Act Action Plan; and
Annually prepare & submit a Modern Slavery Act Statement (FOR39) for publication on the public register. (https://modernslaveryregister.gov.au/)

The Modern Slavery Act action plan for includes:

Mapping our operations and supply chains;
Recognising potential modern slavery risks;
Taking actions to address these risks; and
Assessing the effectiveness of the actions taken.

Modern slavery can occur in every industry and sector, but some sectors, industries and types of work are associated with higher risks of exploitation and slavery practices. When considering whether our supply chain may have modern slavery risks, we consider:

Higher risk sectors, products, services and raw materials;
Types of work and entities with a poor track record;
Geographical location; and
Low-cost goods and services.

Indicators of Modern Slavery

To assist in the prevention of Modern Slavery, all employees and those covered by the scope of this policy, should be aware of indicators of Modern Slavery, including but not limited to:

Where a person does not possess their own passport and travel documents;
Where a person does not appear to have the freedom to travel on their own;
Where a person is always dropped off and collected from work;
Where a person does not appear to have freedom to express themselves, and needs another person or persons to speak on their behalf;
Where a person has little or no control over their finances;
Where a person’s living arrangements and social context appears to be controlled by the business for which they work;
Where a person appears to be working in an environment that is controlling and exploitative;
Where a person appears to be living in poor conditions;
Where a person appears to be exploited in their living arrangements; and
Where a person’s story and account of their history does not appear to be true.

Reporting

Not all victims may want to receive assistance, and reporting potential modern slavery may place a victim at greater risk. Therefore, unless a person is in imminent danger, initial concerns regarding Modern Slavery should be addressed with an internal Compliance officer or your immediate supervisor.

Anti Slavery Australia can provide access to free and confidential legal and migration advice to anyone in modern slavery. Call 02 9514 8115 or visit www.antislavery.org.au.

To report modern slavery in Australia call the Australian Federal Police on 131 237 or report through their website www.afp.gov.au.

In emergencies, where there is immediate danger, or where the situation involves a child, call Triple 0 (000).