Modern Slavery Policy
Modern Slavery Policy
Under the Act, large businesses and other entities operating in Australia must report annually on how they are addressing modern slavery risks in their domestic and global operations and supply chains. Entities need to report under the Commonwealth Act if they are an Australian entity or carry on business in Australia with a minimum annual consolidated revenue of $100 million. Although VisaEnvoy does not fall under the above mandatory requirements we submit the below voluntary statement.
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 VisaEnvoy (VE), its supply chain or in any other business relationships;
- demonstrate VE’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).
Scope
This policy applies to all persons working for and with VisaEnvoy or on its behalf in any capacity, including employees, directors, officers, volunteers, interns, external consultants, third-party representatives and business partners.
Policy Statement
VE has a zero-tolerance approach to Modern Slavery.
VE is 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.
VE is also committed to ensuring there is transparency in its approach to tackling Modern Slavery throughout its business and supply chains, consistent with the VisaEnvoy’s disclosure obligations under the Act.
The prevention, detection and reporting of Modern Slavery in any part of the VE’s 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 Governance, about any likely Modern Slavery breaches in any parts of the VE’s supply chains or business, at the earliest possible stage.
VE expects the same high standards from all of its contractors, suppliers and other business partners. VE’s contracting processes will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and expect suppliers to hold their own suppliers to the same high standards.
Policy Program
VisaEnvoy’s Modern Slavery program contains the following elements:
1. Policies
VE currently operate the following policies that support awareness of acceptable practice and behaviour; and the reporting mechanisms to raise concerns of inappropriate behaviour:
- Fraud, Bribery, Foreign Bribery and Corruption Policy
- Whistleblowing Policy
- Migration Agent’s Code of Conduct
2. Procedures
VE will meet the requirements under the Modern Slavery Act in three ways:
1. Procurement of goods and services (Procurement Policy and Procedure)
The procurement framework is the key mechanism whereby suppliers are engaged by VE. The procurement framework 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 VE 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.
2. Contract management and monitoring key suppliers/offshore partners
The adoption of anti-slavery wording in contracts to cover compliance with the Act. The obligations in the clause to include:
- Obligation to comply with the Act;
- A requirement to take reasonable steps to ensure that there is no modern slavery in the contractors supply chains or any subcontractor’s supply chains; and
- A requirement to notify VE if the supplier becomes aware of any actual or suspected breach of the Act.
VE will work collaboratively with key suppliers/business partners to identify and manage modern slavery risks and develop commercial and actionable solutions.
3. Statement Preparation, Endorsement and Approval
The Act requires that an annual statement be prepared and approved for each financial year where the Company has a revenue of at least $100 million. Where required, the annual statement will be approved by VE and signed by all directors.
Definitions
Employees
Individuals employed by VisaEnvoy, including continuing or ongoing, fixed term, casual and contractors.
Responsibilities
Procurement Team
The Procurement Business Partner is responsible for overseeing sourcing activity, ensuring that an assessment of suppliers is conducted (where appropriate) on their compliance with the Modern Slavery Act.
VE directors are responsible for preparing the annual Modern Slavery Statement, supported by the Procurement Team.
Directors
VE directors are responsible for overseeing offshore partnerships and ensuring that an assessment of offshore partners is conducted on their compliance with the Modern Slavery Act.
VisaEnvoy is responsible for addressing modern slavery risks in the recruitment process particularly when dealing with consultants and agencies in the recruitment of personnel and contract workers, consultants, casual workers, interns and others.
Records Management
The Modern Slavery Policy is a Level 1 Governance Policy. The latest approved version of the Modern Slavery Policy will be stored on the Policy Bank on the VE intranet.
The policy owner will maintain a record of issues relevant to the Modern Slavery Policy for consideration at the time of review
Legislation and Standards
Australian Charities and Not for profit Commission (ACNC) – External Conduct Standards
Implementation plan
Step 1: This policy will continue to be made available on the VE website.
Step 2: Training for staff responsible for Procurement/Offshore Partnerships
Step 3: Communication to all staff on new Policy from Directors.
