Anti-Slavery Policy

Definitions

Modern slavery: refers to any situations of exploitation where a person cannot refuse or leave work because of threats, violence, coercion, abuse of power or deception.

Modern Slavery Act 2018 (Cth): Commonwealth legislation (the Act) enacted by the Parliament of Australia on 29 November 2018 (and may be amended from time to time).

Risks of modern slavery practices: the potential for ITConsult to cause, contribute to, or be directly linked to modern slavery through its operations or supply chains.

Suppliers: defined as any organisation or person who provides us with goods or services, including their subcontractors, agents, related entities, and consultants.

Supply chain: defined as the products and services (including labour) that contribute to Canary's own products and services.

Purpose

Canary is committed to minimising the risk of modern slavery within its business as well as infiltrating its supply chains or through other business relationships.

Scope

This policy applies to all Canary directors, employees, contractors, officers, agents, consultants and any other third party.

Reviews and Approvals

This procedure will be reviewed from time to time and will be updated in line with the Canary Policy Development and Review Policy.

Access

This Policy, together with all related policies, can be accessed on Canary’s SharePoint Intranet.

Ownership

This process is overseen by the Operations Manager for all reviews, maintenance, and governance. Policy Breach Any Staff found to be in breach of this policy may be subject to disciplinary action up to and including termination of employment as specified in the relevant employment agreement.

Policy

Modern slavery is an ongoing global issue. Modern slavery is a crime and a violation of fundamental human rights and manifest in various ways:

  • Slavery, servitude and forced and compulsory labour;
  • Human trafficking;
  • Committing and offence with the intention to commit human trafficking; or
  • Aiding and abetting, counselling, or procuring any of the above offences.

Modern slavery deprives individuals of their liberty to exploit them for personal or commercial gain.

Through our conduct, Canary is committed to all business relationships based on integrity. Canary will endeavour to:

  • Conduct risk assessments to determine which parts of our business and which of our supply chains are most a risk from modern slavery.
  • Where appropriate, Canary will engage directly with new suppliers in respect of our anti-slavery policy. We will aim gain a comprehensive understanding of the measures in place to ensure that modern slavery is not occurring in their business.
  • Our contractual documentation will incorporate specific prohibition against modern slavery.

When existing policies undergo policy review or new polices are under development, policy owners are required to identify existing modern slavery commitments that can be enhanced, or where modern slavery protections can be incorporated.

Regarding our Human Resources practices, we are committed to ensuring the health, safety, and wellbeing of our workforce and that our processes and procedures are compliant with this policy and other occupational health and safety laws.

We are committed to following a continuous improvement approach to how we reduce the risk of modern slavery practices within our operations and supply chains.

We will solicit feedback from Canary staff, suppliers, partners, and other parties regarding the success or otherwise of the actions we have taken to reduce the risk of modern slavery.

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