Modern Slavery Framework Initiatives


Modern Slavery Framework Initiatives

Our comprehensive framework of Modern Slavery policies and procedures, as outlined in Table 1 below, promotes an active approach to identifying our risks and understanding our obligations with regard to Modern Slavery[1]

Our Modern Slavery initiatives (listed in table 1 below) are designed to ensure we do not support transactions involving Modern Slavery in any form, including forced labour, child labour, domestic servitude, sex trafficking, workplace abuse and human trafficking.


Table 1 – Policies and Procedures

Policy / Procedure


Modern Slavery Policy

This policy describes the application of appropriate management control systems to detect and prevent Modern Slavery and provides guidance to staff on how to raise a concern.  It also covers how to deal with suspicions, allegations and reports of Modern Slavery received or identified about our customers, operations and supply chain.

Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) Program

This program is designed to ensure that we detect and prevent money laundering and terrorism financing.  From a transactional perspective, it requires detailed due diligence of each new transaction, including a ‘know your customer’ review in accordance with AML/CTF laws.  The program enables us to conduct ongoing customer due diligence.  It also provides a framework for identifying and reporting suspicious activities to AUSTRAC.

Incident Reporting Policy

This policy establishes an internal reporting process for staff members to report incidents.

Procurement and Contracts Governance Policy

This policy sets out how we procure and manage third parties across the engagement lifecycle in accordance with the core principles of the Commonwealth Procurement Rules.  We complete a risk assessment for all new procurements and selected suppliers. 

Public Interest Disclosure Policy and Procedure

This document provides a mechanism for ‘public officials’ (as defined under the Public Interest Disclosure Act 2013 (Act)) to report conduct engaged in by an agency, public official or contracted service provider in connection with a Commonwealth contract that involves alleged wrongdoing or illegal or improper conduct.

Compliance Training

We have a mandatory ongoing training program which our staff must complete annually.  It includes Modern Slavery, anti-corruption, and anti-money laundering and counter-terrorism financing training.


[1] Modern Slavery includes trafficking of persons, slavery, servitude, forced labour, forced marriage, debt bondage, and the worst forms of child labour (including exploitation of children, sexual exploitation, exposure of children to harming their health, safety and morals, use of children to produce or traffic drugs, and deceptive recruiting for labour or services).