1 PURPOSE
The purpose of this policy is to:
(a) Ensure that the goods and services purchased through the Sancell supply chains and in connection with the manufacture and sales of Sancell’s entire product offering are ethical and eradicate Modern Slavery risks; and
(b) Set out the responsibilities of Sancell Pty Ltd, its employees, suppliers, business partners and development partners in observing and upholding Sancell’s position on Modern Slavery, including meeting obligations under the Modern Slavery Act 2018 (Cth).
2 APPLICATION
(a) This policy applies to all employees.
(b) Suppliers, business partners and development partners when supplying goods and services to Sancell.
3 RESPONSIBILITY
It is incumbent on the Leadership team to lead by example and also to ensure all relevant team members understand the Modern Slavery Policy.
4 DEFINITIONS
For the purpose of this Policy, Modern Slavery is defined as follows.
(a) slavery (the condition of a victim over whom any or all of the powers attaching to the right of ownership are exercised, including where such a condition results from a debt or contract made by the victim)
(b) servitude (the condition of a victim who provides labour or services including sexual services and because of the use of coercion, threat, or deception, they are not free to stop working or leave their place of work and are significantly deprived of personal freedom)
(c) forced labour (the condition of a victim who provides labour or services and because of the use of coercion, threat, or deception, they are not free to stop working or leave their place of work)
(d) deceptive recruiting (the condition of a victim being deceived about whether they will be exploited through a form of modern slavery)
(e) forced marriage (where coercion, threats or deception are used or where the victim does not understand or is incapable of understanding the nature and effect of the marriage ceremony which causes the victim to marry without their free or full consent)
(f) debt bondage (the condition of a victim’s services being pledged as security for a debt, the debt is manifestly excessive, the reasonable value of the victim’s services are not used to liquidate the debt, or the length and nature of the victim’s services are not limited and defined)
(g) trafficking in persons (the recruitment, transportation, transfer, harbouring or receipt of persons, by means of coercion, threat or deception, for exploitation through modern slavery)
(h) the worst forms of child labour including:
(i) where children are exploited through slavery or practices similar to slavery, such as the sale and trafficking of children, debt bondage, serfdom and forced or compulsory labour.
(ii) the use, procuring or offering of a child for prostitution, to produce pornography or for pornographic performances.
(iii) the use, procuring or offering of a child for illicit activities, for the production and trafficking of drugs; and
(iv) children are engaged in work which is likely to harm their “health, safety or morals”; and
(v) offences relating to use of children for production of child abuse material and to the production, dissemination, or possession of child abuse material.
5 POLICY
Sancell commits to abide by the provisions and guidelines set out in the Modern Slavery Act 2018 (Cth). The Company Management, personnel, and supply chains will comply with all Modern Slavery laws, within our operations, endeavouring to ensure:
(a) employment is freely chosen.
(b) child labour is not used.
(c) All individuals are paid within state and federal government guidelines as a minimum.
(d) individuals are not required to work excessive hours; and
(e) any actions taken in response to any instances of modern slavery are in the best interests of the suspected victim or victims.
5 PROCEDURE
Sancell’s expectations, as set out in this Policy, shall be communicated to all suppliers, business partners and development partners at the outset of our business relationship with them.
Personnel who have concerns regarding the conduct of a supplier, business partner or development partner that they believe may constitute Modern Slavery, or a breach of laws related to Modern Slavery or prohibited business practices, must notify Senior management
Failure to comply with the Code of Conduct Policy may result in disciplinary action, including up to termination of employment.
Modern Slavery Enquiries
If any queries or complaints are to be raised about this Modern Slavery Policy, please contact Sancell at:
25-31 Colemans Road, Carrum Downs, VIC 3201
www.sancell.com.au
Telephone: 1800 624 900