Modern Slavery Policy
1. Purpose
The Douglas Group Limited (DG) and its related bodies corporate are committed to supporting ethical labour practices and preventing the existence or prospect of modern slavery within our organisation and supply chains through the continuous improvement of our policies and engagement with suppliers.
Respect is fundamental to DG’s values, the sustainability of our business, and the wellbeing of the communities in which we operate. At DG, this means doing business in a way that acknowledges and respects the rights of our people, customers, suppliers and contractors to be free from practices of modern slavery.
This policy forms part of DG’s ongoing commitment to limit the risks of modern slavery in its business and supply chains. Under the Modern Slavery Act 2018 (Cth), DG is required to report on the risks of modern slavery in its operations and supply chains.
2. Who does this policy apply to?
This policy applies to all persons (individuals, corporations and other legal entities) involved in DG’s supply chain, including DG’s employees, directors, officers, labour hire staff, contractors or other representatives of DG.
3. What is modern slavery?
Modern slavery is depriving a person of freedom for commercial gain 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 can occur in any industry. It is often linked to other crimes and activities that adversely impact human rights, such as corruption and environmental damage.
The Modern Slavery Act 2018 (Cth) defines modern slavery as including eight types of serious exploitation:
- Trafficking in persons – trading in slaves or financing slave trading;
- Slavery – owning a person;
- Forced labour – forcing a person to work by coercion or threats;
- Servitude – significantly restricting a person’s freedom and forcing them to work;
- Forced marriage – a marriage without free and full consent;
- 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, deceives a person about personal freedom or their ability to leave the job; and
- Child labour – exploiting children, depriving them of education or making them work in unsafe working environments.
The types of exploitation can be complex, multi-faceted and difficult to spot. Examples of risks that could arise in DG’s business may include:
- underpayment, indentured workers and exploitation of migrants in all tiers of construction projects, including subcontractors in cleaning, security services and business services; and
- labour conditions and child labour in the supply chain of manufactured goods, such as building materials, electronic equipment, uniforms and vehicles.
4. What are DG’s responsibilities?
DG is working on implementing effective systems and controls to understand, manage and minimise instances of modern slavery within our business and supply chain. This includes:
- publishing an annual modern slavery statement in accordance with modern slavery legislation;
- conducting modern slavery due diligence risk assessments to identify, prevent, and mitigate modern slavery risks in our operations and supply chains;
- developing a supplier code of conduct for implementation within our operations and supply chain;
- contractually requiring our subcontractors, subconsultants and suppliers to take reasonable steps to identify and address modern slavery risks;
- raising awareness of modern slavery risks, including training tools and communications; and
- continuously improving our existing processes to tackle slavery.
5. What are your responsibilities?
If this policy applies to you, you must take all reasonable steps to ensure DG’s business and supply chain are free of modern slavery practices.
Your responsibilities include:
- complying with this policy and reasonable requests regarding DG’s modern slavery procedures;
- reporting reasonably suspected cases of modern slavery;
- participating in modern slavery training;
- leading by example and making appropriate checks on employees, recruitment agencies, suppliers, etc;
- remaining alert to indicators of slavery; and
- paying close attention to risk areas in our supply chain such as outsourcing in jurisdictions without adequate safeguards.
6. How to report slavery concerns
If you have a reasonably held suspicion of modern slavery practices, you can discuss your concerns with DG’s Legal team. You may also make a disclosure under DG’s Whistleblower Policy.
If there is immediate danger, call the police — do not tackle a situation on your own.
It is important to consider that not all victims may want to be helped and some actions can put a potential victim at risk. Therefore, it is recommended that you share your concerns with the perceived victim before taking further action, unless there is immediate danger.
7. Non-compliance with this policy
A breach of this policy will be taken seriously and will need to be dealt with on a case by case basis. This may include:
- investigating a supplier’s practices and preventing further engagement or otherwise working together on the steps required to remedy the breach;
- providing assistance to relevant parties in remediating a situation;
- employee disciplinary action where appropriate. (Note this policy is not intended to form part of a contract of employment.)
8. Who is responsible for maintaining this policy?
DG’s board of directors is responsible for maintaining this policy and will review reports of material slavery concerns. The policy will be reviewed regularly to ensure it continues to evolve and protect the people connected to DG.
