Modern Slavery refers to exploitative practices including human trafficking, sexual exploitation, forced labour, forced criminality, domestic servitude, child exploitation and forced organ removal.
ANA accepts a responsibility to ensure that no such exploitation occurs within ANA.
ANA also accepts a responsibility to take reasonable actions to mitigate the risk of such exploitation occurring in its supply chain, at any level. This includes other businesses and organisations that supply ANA, and their respective supply chains. Responsibility is not restricted by national boundaries.
The purpose of this policy is to ensure the work of ANA never uses or encourages products or services which are in any way facilitated by Modern Slavery practices.
Modern slavery is defined by the Modern Slavery Act (Commonwealth 2018) to include eight types of serious exploitation:
- 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.
- Deceptive recruiting for labour or services, where the victim is deceived and subsequently subjected to a type of modern slavery.
Modern slavery can also extend to:
- entering into a commercial transaction involving a slave;
- exercising control or direction over, or providing finance for, any commercial transaction involving a slave or act of slave trading;
- conducting a business involving servitude or forced labour (including exercising control over the business or providing finance to it).
3. Areas of risk
The policy applies to all ANA activity in all areas, however we have identified our supply chain as our main risk of exposure to modern slavery. Following are identified as higher risk:
- Purchase of products or services sourced from overseas, especially high-risk regions such as conflict zones or repressive regimes.
- Purchase of products or services from Australian suppliers, where that supplier may receive inputs from overseas, especially high-risk regions.
This policy minimises the risk of ANA inadvertently supporting modern slavery by buying from sources that use or benefit from modern slavery.
This policy does not restrict ANA or ANA staff goodwill activities such teaching or advising on sector development in regions which may have a high risk of modern slavery. Direct, positive action can be a strong force for good including in relation to modern slavery.
ANA is committed to limiting the risk of modern slavery within its own business, within its supply chains or through any other business relationship.
This commitment covers everyone who works for or on behalf of ANA in any capacity, including suppliers, employees, directors, officers, agency workers, contractors, consultants and any other third-party representatives.
- Contractors includes secondees, consultants and partners (whether paid or unpaid).
- Suppliers applies to all of goods and services (whether paid or unpaid) and any employees of a supplier.
5. Statement of principles
No employment with ANA is coerced.
ANA does not use or condone child or forced labour in any of its operations or premises and works to ensure these practices are not present in its supply chain.
ANA does not tolerate any form of unacceptable treatment of workers, including exploitation of children, physical punishment or abuse and involuntary servitude.
ANA abides by all laws and regulations regarding pay practices and the classification of employment according to job level and status.
ANA will fully investigate any complaints, allegations or indications of modern slavery practices within its business and supply chains and resolve any issue in accordance with the values embodied in this Policy.
ANA conducts risk assessments to determine which parts of the business and supply chains are most at risk from modern slavery to ensure focus on those areas. All purchases of goods and services from overseas suppliers are subject to automatic review for modern slavery risk.
6. Supply chain compliance
ANA expects its Suppliers to have similar values to the Company in relation to modern slavery. ANA expects that all who have or seek a relationship with ANA will familiarise themselves with this policy and to act in a way that is consistent with its values.
ANA will only engage with suppliers who are fully compliant with this policy or taking clear steps towards compliance.
- New ANA suppliers are subject to due diligence checks via ethical/compliance self-audits.
- Existing suppliers are being brought into the audit net including at contract renewal.
- All suppliers are required at contact or on contract renewal to self-assess their risk of exposure to modern slavery, including in their supply chains, and to report their findings to ANA.
- All suppliers are required at contact or on contract renewal to commit to and provide a modern slavery policy that as a minimum is broadly aligned with this policy.
- All suppliers are required at contact or on contract renewal to confirm in writing that they take reasonable measures to ensure they and their supply chain are not at risk of modern slavery.
- All suppliers are required at contact or on contract to confirm in writing that they will not employ, buy from or otherwise engage with any person or body reasonably assessed to be at risk of modern slavery.
Any breach of this policy will be taken seriously and dealt with on a case by case basis.
7. Obligation to report
All ANA people and suppliers are expected to report any reasonable suspicion of possible modern slavery to their manager or the CEO.
8. Policy review and maintenance
This policy will be periodically reviewed and updated by ANA’s CEO.