Last Updated: September 2022
Brandsec is committed to respecting and supporting the dignity, well-being and human rights of our employees and those who we engage with through our supply chain. We seek to utilize ethical partners and expect their support in the identification of modern slavery risks throughout our supply chain.
Purpose:
Modern Slavery is a crime and violation of human rights and is defined under the Australian Modern Slavery Act 2018 (the Act) as including eight types of serious exploitation:
- trafficking in persons;
- slavery;
- servitude;
- forced marriage;
- forced labour;
- debt bondage;
- deceptive recruiting for labour or services; and
- the worst forms of child labour which means situations where children are subjected to slavery or similar practices, or engaged in hazardous work.
The purpose of this Policy is to:
- prevent, detect and respond with mitigating controls to the risk of Modern Slavery occurring within Brandsec, its supply chain or in any other business relationships;
- demonstrate Brandsec’s commitment to only doing business with those who fully comply with the Act; and
- ensure compliance with the Act (as may be amended from time to time).
Policy Statement
Brandsec has a zero-tolerance approach to Modern Slavery. We are committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure Modern Slavery is not taking place anywhere in its own business operations or supply chains. We are also committed to ensuring there is transparency in our approach to tackling Modern Slavery throughout the business and supply chains.
The prevention, detection and reporting of Modern Slavery in any part of the Brandsec business and supply chains is the responsibility of all those working for it or under its control. Employees who also include contractors, are encouraged to raise concerns with their manager or Director, about any likely Modern Slavery breaches in any parts of Brandsec’s supply chains or business, at the earliest possible stage. Brandsec expects the same high standards from all of its contractors, suppliers and other business partners.
Policy Framework
Brandsec operates the following policies that support awareness of acceptable practise and behaviour:
- Anti-Fraud Policy
- Whistle-blowing Policy
- Employee Code of Conduct
Procurement – Procurement Policy and Procedure
Brandsec’s procurement framework is the key mechanism whereby partners are engaged by Brandsec. It provides for due diligence on these suppliers and their compliance with the Act. Procuring goods and services will, as far as reasonable, be conducted in a way as to ensure that Brandsec sources goods and services from entities that comply with their obligations under the Act. The extent of the due diligence conducted in the procurement process will depend on the types of goods or services being sourced. Some examples of the due diligence that may be conducted include requesting:
- self-assessment/attestation that the supplier complies with various provisions in the Act;
- a copy of the supplier’s most recent Modern Slavery statement (if applicable);
- details of structure and operations of their supply chain; and/or
- details of the actions taken by the supplier to manage and address modern slavery risks in their supply chain. If a proposed contract is included as part of the procurement, consideration must be given to a provision ensuring compliance with the Act.
Reporting
Brandsec is committed to ensuring adherence to this policy as part of its goal in preventing, detecting and reporting modern slavery in any part of our supply chain. We encourage all those working on the Company’s behalf to avoid any activity that might lead to, or suggest, a breach of this Policy. Any suspected instances of modern slavery should be reported. Staff may report to their one-up manager; General Manager; HR or Director. Staff and other reporting persons external to the business may also report using the Whistleblower communication procedure.
Responsibility for this Policy
The Directors of Brandsec have overall responsibility for ensuring this policy facilitates compliance with our legal and ethical obligations, and that all those under our control comply with it and are responsible for approving our annual modern slavery statement (if required by Australian Modern Slavery Legislation).
The Head of Operations will be responsible for the day t0 day monitoring, internal controls and procedures to identify risks of modern slavery practices, including reporting, training and developing measures to assess and address any risks of modern slavery practises, including through due diligence in our contractual relations.
Management at all levels is responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains, including any areas of our business and supply chains that are identified as at risk of modern slavery practises.
Breaches of this Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy
For further information please email info@brandsec.com.au