Anti-Slavery Policy
This is a Controlled Document
In line with Vaxa's governance framework, changes to controlled documents must be approved or merged by a code owner. All contributions are welcome and encouraged.| Version | Effective | Reviewed | Next review due |
|---|---|---|---|
| 1.0.0 | 2021-08-02 | 2024-08-02 | 2025-08-02 |
Purpose
This policy outlines Vaxa’s commitment to ensuring, to the best of our ability, that there is no modern slavery in any part of our business operations or supply chain. We are dedicated to acting ethically and with integrity in all business dealings and relationships, in compliance with the Modern Slavery Act 2018 (Cth).
Scope
This policy applies to all employees, contractors, suppliers, service providers, and any other parties working on behalf of Vaxa.
Roles & Responsibilities
| Role | Responsibility |
|---|---|
| Management | Implement anti-slavery measures and ensure legislative compliance. Include anti-slavery clauses in contracts and assess supplier compliance. |
| Employees | Report any concerns or suspicions regarding modern slavery practices. |
Policy Statement
We are committed to:
- Prohibiting Modern Slavery: Including specific prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude, in all our contracts.
- Ethical Expectations: Expecting our service providers, suppliers, and contractors to share our commitment to act lawfully and ethically, ensuring modern slavery does not occur within their organizations or supply chains.
- Due Diligence: Conducting due diligence on suppliers to assess their compliance with anti-slavery measures.
- Training: Providing training to employees on modern slavery risks and indicators.
- Reporting Mechanisms: Encouraging the reporting of any concerns related to modern slavery.
Under the Modern Slavery Act 2018 (Cth) ‘Act’, we are not required to publish a Modern Slavery Statement as we have an annual consolidated revenue of less than $100 million. However, we are committed to ensuring that modern slavery does not occur within our operations or supply chain.
Definitions
The term ‘modern slavery’ describes situations where coercion, threats or deception are used to exploit victims and undermine their freedom. Coercion, threats and deception can be explicit or implicit.
The Act defines modern slavery as including eight types of serious exploitation; trafficking in persons, slavery, servitude, forced labour, forced marriage, debt bondage, the worst forms of child labour and deceptive recruiting for labour or services.
The worst forms of child labour means extreme forms of child labour that involve the serious exploitation of children, including through enslavement or exposure to dangerous work. The worst forms of child labour does not mean all child work.
Under Australian law, modern slavery is defined in the Act. In the event of any inconsistency between this policy and the Act, the Act will prevail.
Exceptions
No exceptions to this policy are permitted.
Compliance & Monitoring
We will ensure compliance by:
- Regular Audits: Conducting regular audits of our operations and supply chain.
- Supplier Assessments: Performing supplier assessments and due diligence processes.
- Policy Review: Reviewing and updating the policy annually.
- Reporting: Monitoring reports of any concerns related to modern slavery.
References
- Modern Slavery Act 2018 (Cth)
- Vaxa’s Code of Conduct