Modern Slavery Act

Modern Slavery Act

Modern Slavery Declaration and Pledge

Our company recognises that it has a responsibility to respect and support the protection of internationally recognized human rights in our business operations and supply chains rights to ensure that we are not complicit in any abuses of these basic human rights. To fulfil this commitment, we are dedicated to maintaining fair, ethical, and sustainable business and sourcing practices. We are committed to sourcing quality products and services from local, national, and global suppliers that share our core values.

We have established and maintain systems, controls, and other measures to safeguard against the risk of slavery, servitude, forced or compulsory labour, debt bondage, human trafficking, forced marriage, and the worst forms of child labour (collectively, “modern slavery” practices) occurring in any part of our business operations and supply chains. We pledge to do our part to eradicate the scourge of modern slavery in Australia and around the world.

What We Have Done

We strive to do more than recognise that combatting modern slavery practices is a good cause. We also want to ensure that we have a robust program in place to ensure that modern slavery practices do not exist in any of our operations or at any of our suppliers now or in the future. Our senior management established a formal modern slavery compliance and governance program in 2020 that focuses on three key pillars, internal due diligence, external due diligence, and training and awareness programs.

We have adopted a formal modern slavery policy that recognises our commitment to eradicating modern slavery practices and encourages our employees to report any suspicions of modern slavery practices, whether in their own workplace or in the workplaces of any of our suppliers, to our confidential whistleblower hotline. We provide periodic modern slavery training to our employees to raise awareness of this important issue. This training is provided in person or online, but we have also placed wall posters in break rooms and other areas within our operations with key information on modern slavery and our compliance and governance program. We also require all our suppliers to complete periodic modern slavery training provided by our company.

In 2020, we completed an assessment of the modern slavery risks in our business operations and embedded modern slavery due diligence practices into our new supplier selection process. We also began requiring all of our existing suppliers to complete self-assessment questionnaires to help us understand the modern slavery risks in their operations and supply chains and we will, as needed, work with our suppliers to remediate any identified risks. We plan to complete this initial supplier assessment project in 2021.

What We Will Do

We understand that modern slavery compliance is not a one and done effort. We pledge to periodically conduct assessments of our operations and suppliers to identify modern slavery practices and if found, to proactively remediate those practices. We will continue to work with all of our suppliers to ensure that they are combatting modern slavery practices in their workplaces and in the workplaces of their suppliers. We will also continue to provide various forms of modern slavery training to our employees and suppliers.

We also understand that a good compliance and governance program must measure results. We have adopted a number of key performance indicators to track the results of our modern slavery compliance program over time.

We pledge to build on and enhance our ability to address this important issue and to adapt our program to reflect changes in our business operations, supply chains, legal requirements, and marketplace. We also pledge to continuously improve our program because it matters to us and to the millions of people around the world who are or will be trapped in modern slavery.