Modern Slavery

Obviously we are not on board with modern slavery. Even traditional slavery. Slavery in general — huge, emphatic no from us.

We've also put together this pretty official statement to make it super clear how we stand as a business on modern slavery.

Modern Slavery

Objective

This Is A Conversation Starter Pty Ltd (the “Company”) rejects modern slavery in all its forms. Modern slavery is unlawful under various laws within Australia and we are committed to ensuring the health, safety and wellbeing of our workforce, and to implementing and enforcing effective systems and controls to reduce the risk of modern slavery in our business and in our supply chains.

This document sets out the policy of The Company to:

• ensure The Company is compliant with Australian and international laws and regulations in the areas in which we operate;

• demonstrate our commitment to addressing modern slavery in all its forms; and

• promote awareness of concerns surrounding modern slavery to our Workers and suppliers.

Scope

This policy applies to all directors, officers, employees, contractors, consultants, labour hire staff or other workers, subcontractors and suppliers of the Company. It also applies to any other representatives of our business or of any business in our supply chain.

If you do not comply with this policy, we may end our business relationship with you and if you are an employee, you may be disciplined or dismissed.

What is modern slavery?

Modern slavery describes situations where offenders use coercion, threats or deception to exploit victims and undermine their freedom.

Practices that constitute modern slavery can include:

• human trafficking - the recruitment, harbouring and movement of a person for exploitation through modern slavery;
  
  
• slavery - where the offender exercises powers of ownership over the victim, including the power to make a person an object of purchase and use their labour in an unrestricted way;
  
  
• servitude - 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 - where the victim is either not free to stop working or not free to leave their place of work;
  
  
• debt bondage - 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;
  
  
• forced marriage - 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;
  
  
• deceptive recruiting for labour or services - where the victim is deceived about whether they will be exploited through a type of modern slavery; and
  
  
• the worst forms of child labour, which describes situations where children are:
• exploited through slavery or similar practices, including for sexual exploitation;
• engaged in hazardous work which may harm their health, safety or morals; or
• used to produce or traffic drugs.

Indicators of modern slavery include where the suspected victim or victims:

• are living at the workplace, or another place owned/controlled by their employer;
  
  
• are underpaid, not paid at all or required to work excessive hours;
  
  
• are confined in the workplace or guarded at work or in their accommodation;
  
  
• are isolated in remote locations that are difficult to access and/or restricted from contacting or interacting with people outside the workplace;
  
  
• are managed by an intermediary or third party who ‘holds’ or ‘invests’ their money for them;
  
  
• are subject to different or less favourable working conditions than other workers because of their country of origin, gender or other factors;
  
  
• are unable to terminate their employment at any time;
  
  
• are servicing a debt to an employer or a third party (such as a recruitment agent);
  
  
• are personally or through their family subjected to, or threatened with, violence, emotional, sexual, verbal or physical abuse and/or degrading treatment in connection with their employment;
  
  
• appear to have false travel or personal documents (or are not allowed access to these documents) or generally do not have permission to work in the country;
  
  
• are not informed of, or do not appear able to understand the conditions of their employment; and
  
  
• are not provided with any protective equipment, training or means to refuse to participate in dangerous work practices.

Responsibilities

What are The Company’s responsibilities?

We will comply with local, national and other applicable laws and regulations in the jurisdictions where we operate. We will endeavour to:

• identify and address modern slavery risks in our business and actively and progressively improve our understanding and oversight of all tiers of our supply chain; and
  
  
• take steps to raise awareness of modern slavery risks within The Company and in our supply chain, including by having this policy.

The Directors have overall responsibility for this policy and in ensuring that The Company complies with all its legal and ethical obligations.

What are Workers’ responsibilities?

You must take all reasonable steps to ensure our business and supply chain is free of modern slavery practices.

However senior you are and regardless of your business relationship with us, you must pay close attention to the high risk areas as may be identified in our Modern Slavery Statement, particularly supply chain and outsourcing in jurisdictions without adequate safeguards.

Examples of specific responsibilities include:

• participating in all training, including in this policy;
  
  
• leading by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc to ensure we know who is working for us;
  
  
• remaining alert to indicators of slavery (see above); and
  
  
• obeying our instructions regarding modern slavery.

Turning a blind eye is unacceptable and if you reasonably suspect there may be modern slavery within The Company or within a supplier’s business you must report it under this policy.

What are Suppliers’ responsibilities?

Suppliers must use best endeavours to ensure that there is no modern slavery in their supply chains and operations. In the event suppliers identify any occurrence, 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 The Company as soon as practicable of any occurrence, or material risk, of modern slavery they have identified and notify relevant authorities where appropriate. Suppliers must, at their own cost, undertake all remediation activities required by the Company to address modern slavery or material risks of modern slavery in their operations.

Reporting concerns of modern slavery

It is important that our employees and others involved in our business feel free to speak up where there are reasonably held concerns of modern slavery within our business or a supplier’s business.

If you have a reasonably held suspicion of modern slavery practices, discuss your concerns with Daniel Allen who will decide a course of action and provide any further advice.

Breaches of this policy

A breach of this policy by an employee, director or officer of the Company may lead to disciplinary action being taken in accordance with our disciplinary procedure. Serious breaches may be regarded as gross misconduct and can lead to immediate dismissal.

All employees, directors and officers of the Company will be expected to report any instances of modern slavery within the Company and to cooperate fully in any investigation into suspected breaches of this policy or any related processes or procedures.

If this policy is breached, we will act as quickly as practicable to remedy all adverse impacts on workers, individuals, and communities. The relevant police authorities may also be notified.

If an issue is identified with a supplier, we will work with them to prepare a corrective action plan and resolve all violations within an agreed time period. We reserve the right terminate our relationship with individuals and organisations in our supply chain if they breach this policy or if they are unwilling or unable to work towards full compliance with this policy.