Modern Slavery Policy

Purpose of this policy

Nguma Pty Ltd (ABN 36 695 423 851) is committed to limiting the risks of modern slavery practices in our business and supply chain. This policy supports that commitment and underpins our annual modern slavery statement.

Who this policy applies to

This policy applies to you if you are involved in our business, including if you are an employee, director, officer, labour hire staff, contractor or other representative of our business or of any business in our supply chain.

While this policy is not part of any contract you may have with us, you are expected to comply with it. If you do not comply with this policy, we may end our business relationship with you and, if you are an employee, you may be disciplined or dismissed.

What is modern slavery?

Modern slavery is depriving a person of freedom for commercial gain and in violation of fundamental human rights. It describes situations where offenders use coercion, threats or deception to exploit victims and undermine their freedom. Modern slavery involves serious exploitation, not sub-standard working conditions or the underpayment of workers, although those may be unlawful for other reasons.

Modern slavery can take many forms including:

• Slavery — owning a person, trading in slaves or financing slave trading (including human trafficking);
• Forced labour — forcing a person to work by coercion or threats (and servitude is when that person’s freedom is significantly restricted);
• Forced marriage — a marriage without free and full consent, for example due to lack of understanding or duress;
• Debt bondage — a person works to pay off a large debt, for an unlimited time, or where the value of the work is not applied to the debt;
• Deceptive recruiting — a recruiter charges a fee for the job offer, confiscates identity documents, or deceives a person about their freedom or ability to leave the job; and
• Child labour — not always unlawful, but not tolerated by us when it involves exploiting children, depriving them of education, or making them work in unsafe environments.

Indicators of modern slavery

Modern slavery indicators may include where a person:

• is not in possession of their own passport, ID or travel documents;
• is acting as though they are being instructed or coached by someone else, or allows others to speak for them when spoken to directly;
• is dropped off and collected from work;
• is withdrawn, appears frightened, or has physical indicators of abuse;
• has limited social interaction or contact with people outside their immediate environment;
• has few possessions or little or no control over their finances;
• has no access to a bank account, or is being significantly overcharged for their accommodation; or
• is living in a very poorly maintained and overcrowded place.

These indicators are not exhaustive and do not necessarily mean there are modern slavery practices. Sometimes there may be other reasons or circumstances involved.

Our responsibilities

We will endeavour to:

• prepare a modern slavery statement as required by Australian law;
• identify and address modern slavery risks in our business and supply chain; and
• take steps to raise awareness of modern slavery risks, including by having this policy.

Your responsibilities

You must take all reasonable steps to ensure our business and supply chain is free of modern slavery practices. Regardless of your seniority or business relationship with us, you must pay close attention to the high-risk areas identified in our Modern Slavery Statement, particularly supply chain and outsourcing in jurisdictions without adequate safeguards.

Specific responsibilities include:

• participating in all training, including in this policy;
• leading by example by making appropriate checks on all employees, recruitment agencies, suppliers, and others to ensure we know who is working for us;
• remaining alert to indicators of modern slavery;
• using only approved contracts which include modern slavery clauses; and
• obeying our instructions regarding modern slavery.

Turning a blind eye is unacceptable. If you reasonably suspect there may be modern slavery, report it under this policy.

How to report concerns

If you have a reasonably held suspicion of modern slavery practices, discuss your concerns with our Human Resources department at [email protected], who will decide a course of action and provide any further advice.

If there is immediate danger, call the police — do not tackle a situation on your own, as dangerous criminals can be behind modern slavery and human trafficking.

Not all victims may want to be helped and sometimes reporting a suspected case puts the potential victim at risk. Unless there is immediate danger, discuss your concerns with our Human Resources department before taking any further action.

Policy ownership and review

Our board of directors is responsible for this policy and will review reports of material slavery concerns. The policy may be amended, replaced, or removed, and the current version can always be found at nguma.au/modern-slavery-policy.

Contact

Nguma Pty Ltd
Suite 11, 450 Elizabeth Street, Surry Hills NSW 2010
Email: [email protected]
Phone: 1300 423 678