1 INTRODUCTION

1.1 Purpose

Modern slavery is a crime and a violation of fundamental human rights. SUSTENA does not tolerate the existence of modern slavery in its business or supply chain.

This policy sets out the process by which SUSTENA will strive to ensure there is no modern slavery present in its business or supply chain and the manner in which employees of SUSTENA can report any suspected instances of modern slavery.

1.2 Scope

This policy applies to all permanent SUSTENA employees.

2 DEFINITIONS

2.1 What is modern slavery

Modern Slavery is as defined in accordance with any applicable legislation in the various regions in which we operate.

However generally, modern slavery could encompass any or all of the following conduct: servitude, child labour, forced labour, human trafficking, debt bondage, forced marriage, deceptive recruitment for labour or services, and other conduct as defined by applicable legislation from time to time.

3 ADDRESSING MODERN SLAVERY

3.1 Review of supply chain

In accordance with applicable legislation in the areas in which we operate, SUSTENA will conduct any required audits of our supply chain to try and eliminate modern slavery practices if found.

3.2 Modern Slavery statement

In accordance with applicable legislation in the areas in which we operate, SUSTENA will publish any required statements or notifications in relation to our efforts to address modern slavery in our business or supply chain.

3.3 Prohibition on engaging in certain conduct

All employees of SUSTENA must not engage in any conduct which would amount to a breach of any applicable modern slavery legislation in the region they work in.

 

 

 

3.4 Reporting modern slavery

All employees of SUSTENA are responsible for being alert to any modern slavery practices that they may become aware of in our business or supply chain.

If any employee reasonably believes or suspects that modern slavery may be present in our supply chain or business, they must notify the Director People & Culture, or SUSTENA’s General Counsel, as soon as possible.

3.5 Training

All employees of SUSTENA will have access to documents on understanding what modern slavery is, ways to spot modern slavery, and how to report modern slavery. It is each employee’s own responsibility to notify their manager if they are unable to completed or access this training so that alternative options can be made available for them.

CONFIDENTIAL INFORMATION

This document is made available to the recipient on the express understanding that the information contained in it be regarded and treated by the recipient as strictly confidential. The contents of this document are intended only for the sole use of the recipient and should not be disclosed or furnished to any other person.

DISCLAIMER OF LIABILITY

The information contained in this document is provided under direction from the nominated client and addresses this direction. Any third party reviewing the content of this document needs to make their own assessment on the appropriateness of the information contained. SUSTENA Management Pty Limited makes no assurance the information meets the needs of a third party and as such accepts no liability for any loss or damage incurred by third parties whatsoever as a result of using the information.