Modern Slavery Policy

OVERVIEW

OAC recognises that modern slavery distorts global economies, affects corporate social responsibility and has devastating social impacts on the community.

Only About Children (OAC) has a zero-tolerance approach to any imposition of, or connection to, modern slavery and human trafficking. This Policy reflects OAC’s commitment to conducting its business in a manner consistent with internationally proclaimed human rights, including all workers’ fundamental human right to be treated with dignity and respect, and live a life of freedom and opportunity.

PURPOSE OF POLICY

This Policy affirms OAC’s commitment to identifying and addressing risks of modern slavery within its operations and supply chain. This Policy also provides an overview of the approach OAC follows to prevent and reduce the risk of modern slavery within its operations, in accordance with the Australian Modern Slavery Act 2018.

RESPONSIBILITIES

As a team member, you are responsible for:

• familiarising yourself with this policy; and
• managing any risk or instance of modern slavery which is encountered in accordance with this policy.

And if you are a manager, you will also need to ensure you:

• oversee the implementation and adherence to this policy; and
• provide advice to team members in accordance with this policy.

POLICY APPLICATION AND SCOPE

The Policy applies to:

• all current team members; and
• all OAC’s suppliers of goods and services (‘suppliers’).

As part of induction, all team members and suppliers must read and understand this Policy. This Policy is available to all team members on OAC’s website.

OAC expects all team members and suppliers to work together to assist OAC to give effect to the principles set out in this Policy.

DEFINITIONS

‘Modern Slavery’ describes situations where offenders use coercion, threats or deception to exploit victims and undermine or deprive them of their freedom.

‘Modern slavery’ is defined by the Modern Slavery Act (Cth) 2018 to include eight types of serious exploitation and which can be understood as:

• trafficking in persons, which is the recruitment, harbouring and movement of a person for the purposes of exploitation through modern slavery. Exploitation also includes the prostitution of others or other forms of sexual exploitation, forced labour or services, slavery, or practices similar to slavery, servitude or the removal of organs.
• slavery, which is where the offender exercises powers of ownership over the victim.
• servitude, which is where the victim’s personal freedom is significantly restricted, and they are not free to stop working or leave their place of work.
• forced labour, which is where the victim is either not free to stop working or not free to leave their place of work.
• forced marriage, which is where coercion, threats or deception are used to make a victim marry or where the victim does not understand or is incapable of understanding the nature and effect of the marriage ceremony.
• debt bondage, which is where the victim’s services are pledged as security for a debt and the debt is manifestly excessive or the victim’s services are not applied to liquidate the debt, or the length and nature of the services are not limited and defined.
• the worst forms of child labour, which involves situations where children are: exploited through slavery or similar practices, including for sexual exploitation; or engaged in hazardous work which may harm their health or safety, or used to produce or traffic drugs; and
• deceptive recruiting for labour or services which is where the victim is deceived about whether they will be exploited through a type of modern slavery.

Modern slavery may involve the exploitation of debt and the use of violence and/or threats of violence (psychological or physical), isolation, deprivation of liberty and the withholding of critical identification documents such as passports.

In this Policy, we use the term ‘modern slavery’ to encompass all of the practices to which the Modern Slavery Act refers.

Modern slavery occurs in a wide range of industries and businesses across the world, including in Australia. Certain groups within the community, such as migrants, women and children, are particularly at risk of modern slavery.

‘Suppliers’ is defined as any organisation or person who provides OAC with goods or services, including their subcontractors, agents, related entities and consultants.

‘Supply chains’ is defined as the products and services (including labour) that contribute to OAC’s own products and services. This includes products and services sourced in Australia or overseas and extends beyond direct suppliers.

 

OAC’S APPROACH TO LIMITING THE RISK OF MODERN SLAVERY PRACTICES

OAC is committed to ensuring:

• its operations and supply chain do not cause, involve or contribute to modern slavery; and
• its suppliers and any others organisation we engage with respect and share OAC’s commitment to minimising the risk of modern slavery.

1. Supply chain

OAC expect all existing and new suppliers to uphold high standards of human rights and operate in full compliance with the laws and regulations in the jurisdiction where the goods are sourced, procured or services are performed.

Suppliers must use best endeavours to ensure that there is no modern slavery in their supply chains and operations (which includes completing risk assessment, audits, due diligence, having reporting and grievances processes in place, etc.).

In the event OAC’s suppliers identify any occurrence of, or material risk of modern slavery in their supply chains or operations they are to take practical and effective steps to address that occurrence or risk.

Suppliers must notify OAC as soon as practicable of any occurrence of, or material risk of modern slavery they have identified and notify relevant authorities where appropriate. Suppliers must also notify OAC of the corrective action plan put in place to remediate identified modern slavery and keep OAC informed of the effectiveness of these measures.

 

2. Operations

Modern Slavery Policy

OAC maintains a Modern Slavery Policy (this Policy) outlining our approach to reduce the risk of modern slavery practices within our operations and supply chain. This Policy provides guidance on the steps OAC takes to work with suppliers to reduce risks and the range of support available for when an OAC team member or supplier becomes aware that someone is at risk of or affected by modern slavery practices.

Incorporating modern slavery into our policies

OAC has reviewed and incorporated modern slavery protection into the following policies and relies on them to assist in managing the risks of modern slavery:

• Code of Conduct and Ethics Policy;
• Whistleblower Policy;
• Grievances and Dispute Resolution policy; and
• Dealing with Complaints Policy.

Human Resources

OAC is committed to ensuring the health, safety and wellbeing of our team members and we maintain a suite of policies that are informed by and compliant with Australian workplace and occupational health and safety law. These policies are regularly reviewed by OAC.

OAC also conducts regular audits of wages, salaries and employment conditions of our team members to ensure compliance with Australian workplace laws. We also ensure that our volunteers are engaged on a truly voluntary and non-exploitative basis.

Communications and Training

OAC’s team members and suppliers are provided communication and training opportunities to enhance their understanding of the causes and humanitarian impact of modern slavery, what is required to identify, assess and address modern slavery, their responsibilities under this Policy and OAC’s approach to limiting the risk of modern slavery within its operations and supply chain.

Promoting awareness of modern slavery enables OAC’s team members and suppliers to identify modern slavery risks more easily so that OAC can respond appropriately to those risks.

Continuous improvement approach to reducing the risk of modern slavery

OAC is committed to applying a continuous improvement approach to how we reduce the risk of modern slavery practices within our supply chain and operations.

In addition, OAC publishes annual modern slavery statements in accordance with the Modern Slavery Act 2018 (Cth). The statements contain information about potential risks of modern slavery in our supply chain, due diligence, procedures we undertake to manage risks, and the effectiveness of such measures.

 

REPORTING CONCERNS OF MODERN SLAVERY

The often hidden nature of modern slavery practices means it can be difficult to identify and can be difficult for people to report.

However, OAC encourages its team members, suppliers and others to feel empowered and safe to speak up and raise their concerns with our Legal team at [email protected] if they become aware of any action or decision which is inconsistent with this Policy or a suspected instance of modern slavery within OAC or its supply chain.

Reports of concerns about modern slavery can be made anonymously and are responded to in accordance with the OAC Whistleblower Policy. The reporting team member or supplier will be protected from retaliation and information will be kept confidential.

 

BREACH OF POLICY

Any breach of this Policy, as varied from time to time, will be taken seriously and conduct in contravention of this Policy may be regarded as misconduct, leading to disciplinary action up to and including termination of employment. An individual may also be exposed to criminal or civil liability for breaching the law.

DOCUMENT HISTORY

Policy #
Owner	Legal
Scope	All team members, contractors, consultants, suppliers
Related policies	Code of Ethics and Conduct Grievances and Dispute Resolution policy Whistle Blower policy Dealing with Complaints Policy
Effective Date	June 2021
Review Date	June 2024
History	Date	Description of Update
	June 2021	New policy created by HR and Legal & Compliance
	September 2022	Reviewed.
	June 2023	Minor updates and change to email address for reporting.