Brand Services Modern Slavery Policy

Brand Services is committed to limiting the risk of modern slavery occurring within its own business, infiltrating its supply chains or through any other business relationship.

The policy applies to all persons working for or on behalf of the Company, in any capacity, including employees, directors, officers, agency workers, contractors, consultants and any other third-party representative.

Brand Services expects all who have, or seek to have, a business relationship with the Company to familiarise themselves with this policy and to act in a way that is consistent with its values.

The Company will only do business with organisations who fully comply with this policy, or those who are taking verifiable steps towards compliance.

This policy will be used to underpin and inform any statement on slavery and human trafficking that the Company is required to produce further to the transparency in supply chain requirements of the Modern Slavery Act 2018 (MSA).

What is Modern Slavery?

The term modern slavery is used to describe situations where coercion, threats or deception are used to exploit victims and undermine or deprive them of their freedom. The Australian Modern Slavery Act 2018 (the Act) defines ‘Modern Slavery’ as eight types of serious exploitation: trafficking in persons; slavery; servitude; forced marriage; forced labour; debt bondage; deceptive recruiting for labour or services; and the worst forms of child labour. The worst forms of child labour means situations where children are subjected to slavery or similar practices, or engaged in hazardous work.

How Brand Services seeks to Embed the Modern Slavery Policy in Practice

To underpin the commitments laid out in this policy, Brand Services continues to implement the following measures:

• We continue to conduct risk assessments to determine which parts of the business and which supply chains are most at risk from modern slavery so efforts can be focused on the areas that are most ‘at risk’
• Where appropriate, as informed by the risk assessment, we will engage directly with new suppliers in respect of the Modern Slavery Policy in order to gain a proper understanding of the measures they have in place to ensure that modern slavery is not occurring within their own businesses.
• Our contractual documentation will incorporate specific prohibition against slavery or servitude, the use of forced, compulsory or trafficked labour, and the use of child labour in line with this policy.
• We also make provision for our contracted suppliers to hold their own suppliers to the same standards. We also reserve the right to terminate any contractual arrangement if there is breach of this policy.

Responsibility for This Policy

The Management Committee has overall responsibility for this policy and in ensuring that the Company complies with all its legal and ethical obligations.

The General Manager has the primary day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place, and amended as appropriate, to ensure it can operate effectively.

All line managers are responsible for ensuring that their staff and relevant colleagues comply with the provisions of this policy in the day to day performance of their roles.

Communication and Employee Awareness Training

Line Managers will ensure that relevant colleagues receive adequate training on this policy and any supporting processes applicable to their role.

Breaches of This Policy

The breach of this policy by an employee, director or officer of the Company may lead to disciplinary action being taken in accordance with the Company’s Disciplinary Procedure. Serious breaches maybe regarded as gross misconduct and can lead to immediate dismissal.

All colleagues will be expected to co-operate to the fullest extent possible in any investigation into suspected breaches of this policy or any related processes or procedures.

If any part of this policy is unclear, clarification should be sought from the General Manager.

Status of This Policy

This Modern Slavery Policy will be reviewed by the Management Committee on a regular basis.

This notice reflects the Company’s current practice. Brand Services will update the notice from time to time to reflect legal and operational requirements.

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This policy is endorsed and signed by
Steve Lewis in his role as Director of Brand Services Group Pty Ltd. 
20 December 2023