At Audacix, we are committed to operating sustainably, responsibly, and in a way that produces positive impact for our stakeholders; including our clients, the communities we work in, employees, suppliers, and our shareholders.
A core component of this commitment is identifying and counteracting modern slavery in global supply chains with the end goal of ending modern slavery.
The UK's Modern Slavery Act 2015, Australia's Modern Slavery Act 2018 (Cth) and the Australian Government’s Explanatory Memorandum defines modern slavery as trafficking in persons, slavery, slavery-like practices (including forced labour and forced marriage) and the worst forms of child labour.
Slavery-like practices can include underpayment of wages, excessive working hours, debt bondage and confiscation of personal documents.
Modern slavery practices are major violations of human rights. We consider modern slavery as a crime and a morally reprehensible act that deprives a person's liberty and dignity for another person's gain. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Tens of millions of people today are in situations of slavery, including in nearly all industries and countries.
We have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operations and supply chains. We are taking concrete steps to tackle modern slavery, as outlined in this statement which sets out actions we are taking to see where we may be exposed to modern slavery, and to help protect the people in our supply chains.
We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial inputs and outcomes.
Our supplier selection and on-boarding procedure includes due diligence of the supplier's reputation, respect for the law, compliance with health, safety and environmental standards, and references.
To date, Audacix has not identified or become aware of any instances of human trafficking or slavery within our operations or supply chain.
Should this happen, we will act immediately to report our findings to all relevant authorities and work with the supplier to protect the people involved. We acknowledge that rapid offboarding of suppliers involved in human rights violations may not be in the best-interest of vulnerable people within that supply chain, and therefore we use this as a measure of last resort.
Core Elements Of Our Anti-Slavery & Human Trafficking Policy
Consistent with the legislation referred to above, there are 6 core elements of our approach to ensuring that we not only comply with legislation in the countries that we operate, but we also fulfil our moral obligations to ourselves and our communities in helping to stamp out slavery and human trafficking.
Responsibility
Audacix has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
Supplier due dilligence
Audacix conducts due diligence on new subcontractors and suppliers during on-boarding and on existing suppliers at regular intervals. We require subcontractors and suppliers to complete a due diligence checklist to ensure that they conform to our policies and procedures.
We require subcontractors and suppliers to attest that:
- They do not use any form of forced, compulsory or slave labour;
- Their employees work voluntarily and are entitled to leave work;
- They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment;
- They do not require employees to post a deposit/bond and do not withhold their salaries for any reason; and
- They do not require employees to surrender their passports or work permits as a condition of employment.
Compliance
All our team members and contractors must read, understand and attest to their ongoing compliance with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.
All our team members and contractors are required to avoid any activity that might lead to, or suggest, a breach of this policy.
All our team members and contractors must notify your line manager OR a company Director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
If our team members and contractors are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, they must raise it with your line manager or company Director as soon as practical.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers 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 own business or in any of our supply chains.
If our team members and/or contractors believe that they have suffered any such treatment, they should inform your line manager or company Director immediately.
Communication & awareness
Audacix raises awareness of modern slavery issues by ensuring this Anti-Slavery and Human Trafficking Policy is focused specifically on modern slavery is made available to staff and explains:
- Our commitment in the fight against modern slavery
- Red flags for potential cases of slavery or human trafficking
- How employees should report suspicions of modern slavery
Measurement of progress
Audacix has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These include:
- How many employees have completed mandatory training?
- How many suppliers have rolled out an awareness and training programme that is equivalent to ours?
Breaches of this policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
