Firebrand Australia Pty Ltd (FB AU) values human rights and is committed to ensuring that all business is conducted according to ethical, professional, and legal standards in a fair, honest, and open manner. It is vital for us to maintain this reputation as it generates confidence in our business.
Modern Slavery (as defined in Divisions 270 and 271 of the Criminal Code 1995 (Cth) (Modern Slavery) is a crime and a violation of fundamental human rights. It takes various forms, such as:
- slavery: one person treats another as though he or she owns that person and that person is deprived of his or her freedom.
- servitude: a person is coerced to provide services, is forced to live on another person’s property and cannot change his or her condition.
- forced labour: a person is forced to involuntarily work or to provide a service without remuneration under the menace of a penalty.
- trafficking in persons (including trafficking of orphanage children): a person arranges or facilitates the travel of another person to be exploited, without that person’s knowledge or consent. This can be even where the person consents to the travel as they may have been deceived or unduly influenced.
- forced marriage: a person enters into a marriage without freely and fully consenting, because he or she was coerced, threatened or deceived or otherwise incapable of understanding the nature and effect of the marriage ceremony.
In addition, the definition of “modern slavery” in the Modern Slavery Act 2018 (Cth) (Modern Slavery Act) includes:
- child labour: children below 12 years of age undertaking at least one hour of economic activity or 28 hours of domestic work or children aged between 12 and 14 years of age undertaking at least 14 hours of economic activity or 42 hours of domestic work and economic activity combined.
- debt bondage: a person’s pledge of labour or services as security for the repayment of a debt or other obligation, but there is no hope of repaying the debt. The services required to repay the debt, or the time in which to repay the debt, may be undefined.
- other slavery-like practices.
The Modern Slavery Act applies to all FB AU operations and its supply chain.
This document is directed to assisting FB AU to comply with its obligations under the Modern Slavery Act and reducing the modern slavery risks posed to its business and its supply chain.
FB AU takes its compliance with its statutory obligations seriously. As noted above, this document is directed to (amongst other things) assisting FB AU to comply with its obligations under the Modern Slavery Act.
FB AU has a zero-tolerance approach to Modern Slavery within its business and supply chain and 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 in its own business or in any of its supply chain.
This Anti-Slavery Policy (Policy) applies to all directors, officers, and employees of FB AU.
It is critical that you comply with the obligations set out in this document. Modern Slavery can cause genuine and significant harm to the individuals affected and there are significant reputational, financial, market and operational risks for FB AU if Modern Slavery risks are not properly detected and addressed.
This document sets out important information as to the steps that FB AU will take in response to identifying a Modern Slavery risk. You must familiarise yourself with this document to assist FB AU in effectively carrying out its duties in compliance with the Modern Slavery Act.
The Ethical Standards Officer
Our Ethical Standards Officer is responsible for the administration and maintenance of this Policy.
Our Ethical Standards Officer also has primary and day-to-day responsibility for implementing this Policy, monitoring its use and effectiveness, dealing with any queries about it, auditing internal control systems and procedures to ensure they are effective in countering Modern Slavery. The Ethical Standards Officer is entitled to call upon any resources that he or she considers necessary to assist the Ethical Standards Officer in the performance of their role.
The Ethical Standards Officer is the Company General Manager, Bobby Sevdimbas and can be contacted on +61 2 8822 8900 or at [email protected]
Management at all levels are responsible for ensuring those reporting to them understand and comply with this Policy and are given appropriate training on it and the issue of Modern Slavery in supply chain.
This document will be reviewed on an annual basis or when required as a result of relevant legislative amendments, changes to regulatory guidance, relevant court decisions or as a result of the identification of improvement opportunities during the course of a post-incident review. All employees will be made aware of this document and key personnel will be provided with sufficient training so as to enable them to fulfil the role(s) which are relevant to them.
FB AU prohibits all forms of Modern Slavery and seeks to educate and influence its employees and suppliers to ensure that no form of Modern Slavery is taking place in its own business operations or in its supply chain.
FB AU employees, contractors, subcontractors, vendors, suppliers, partners, representatives, agents and others through whom FB AU conducts business must not engage in any practice that constitutes any form of Modern Slavery. This includes, but is not limited to, the following activities:
- Engaging in any form of trafficking in persons.
- Using forced labour in the performance of any work.
- Destroying, concealing, confiscating, or otherwise denying access by an individual to the individual’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority.
- Using misleading or fraudulent practices during the recruitment or offering of employment/contract positions to candidates; such as failing to disclose, in a format and language accessible to the potential candidate, basic information or making material misrepresentations during the recruitment of candidates regarding the key terms and conditions, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs, any significant cost to be charged to the candidate, and, if applicable, the hazardous nature of the work.
- Using recruiters that do not comply with local labour laws of the country in which the recruiting takes place.
- Charging applicants / candidates recruitment fees.
- If required by law or contract, failing to provide return transportation, or failing to pay for the cost of return transportation upon the end of employment.
- If required by law or contract, failing to provide or arrange housing that meets the host country’s housing and safety standards.
- If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing.
FB AU is committed to the Policy and has diligently put, or is putting, measures in place that are designed to prevent and detect Modern Slavery in our business and our supply chain. The FB AU programme in this regard contains the following elements:
- A policy which articulates the commitment of FB AU to prevent violations of the Modern Slavery Act and the Modern Slavery offences within the Criminal Code 1995 (Cth) within its operations and supply chain, being this Policy.
- Communication of this Policy and all relevant elements of the programme to all employees throughout FB AU and to our business partners and supply chain.
- The assessment of Modern Slavery risks within FB AU operations and supply chain and the development of effective, efficient, and transparent controls to reduce exposure to those risks.
- The conduct of appropriate due diligence on business partners, agents, contractors, consultants, subcontractors, and suppliers coupled with a requirement that they implement procedures which incorporate the principles of the Modern Slavery Act.
- Training of all relevant individuals throughout FB AU so that compliance with this Policy is the duty of all relevant employees at all levels and so that individuals can recognise Modern Slavery practices and take steps to avoid the same.
- FB AU is also committed to ensuring there is transparency in our own business operations and in our approach to tackling Modern Slavery throughout our supply chain, consistent with our disclosure obligations under the Modern Slavery Act.
- In addition, FB AU provides safe and fair working conditions for all its employees and ensures that no child labour is employed, in line with minimum age laws, within the countries that it operates. FB AU expects the same standards from all its suppliers which includes specific prohibitions against the use of forced, compulsory or trafficked labour or anyone held in slavery or servitude, whether adults or children and we expect that our suppliers will hold their own suppliers to the same standards.
The Ethical Standards Officer will report to the Director at least annually on the measures to prevent and detect Modern Slavery in its business operations and supply chain.
Investigations and Audits
FB AU will perform investigations and internal or external audits to verify that business is being conducted in compliance with this Policy.
All of FB AU’s employees and third parties through whom FB AU conducts business are required to fully and promptly cooperate with the internal and external auditors and investigators of FB AU, and must respond fully and truthfully to their questions, requests for information, and documents. Any failure by an employee to completely cooperate, or any action to hinder an investigation or audit, including for example, hiding or destroying any information or documentation, providing false answers or false information, or deleting emails or other documents, may be grounds for disciplinary action, up to and including termination, subject to applicable law.
Internal reporting is critical to the success of FB AU and it is both expected and valued. You are required to be proactive and promptly report any suspected violations of the Policy or any illegal or unethical behaviour that you become aware of. Complaints will be kept confidential and will be dealt with appropriately. You will not experience retribution or retaliation for a complaint made in good faith.
If you believe that a breach of this Policy has occurred or is likely to occur, you must notify your manager and the FB AU Ethical Standards Officer as soon as possible.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of a FB AU supply chain constitutes any of the various forms of Modern Slavery, your query should be raised with your manager and the FB AU Ethical Standards Officer.
FB AU aims to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if those concerns turn out to be mistaken. FB AU is committed to ensuring staff do not suffer any detrimental treatment as a result of reporting in good faith their suspicion that Modern Slavery of whatever form is or may be taking place in any part of our business or in any of our supply chain. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the FB AU Ethical Standards Officer immediately.
Crisis Management and Business Continuity
When confronted with a potential Modern Slavery incident or risk, the Ethical Standards Officer should consider whether the incident or risk may give rise to obligations under FB AU’s crisis management and business continuity plans.
Breaches of this Policy
The Ethical Standards Officer will arrange an investigation into reported breaches of this Policy. The investigation may utilise internal and external resources that the Ethical Standards Officer considers necessary. The outcome of the investigation included recommended actions will be reported to the FB AU Director.
Any employee who breaches this Policy by engaging in or conspiring to engage in any Modern Slavery conduct will face disciplinary action. This could, in the most severe circumstances include immediate dismissal for misconduct or gross misconduct and, if warranted, legal proceedings may be brought against the employee. FB AU may terminate its relationship with individuals, organisations and suppliers working on its behalf or engaged by it if they breach this Policy.
If you have any questions about this Policy, please contact the Ethical Standards Officer. The key contact details are outlined below.
Ethical Standards Officer:
Phone: +61 2 8822 8900 | Email: [email protected]
Version 1 – FB AU 001
This policy was lasted updated in January 2021 and will be reviewed January 2022.