Voluntary modern slavery and ethical sourcing policy

The Modern Slavery Act 2018 (Cth) (“the Act”) does not apply to AHP (“we”, “us”, “our”).

Nevertheless, we are committed to the respect and protection of human rights through the eradication of modern slavery.

Modern slavery encompasses situations where the freedom and rights of victims are exploited by the use of coercion, threats or deception and can include, human trafficking, slavery, servitude, forced marriage, debt bondage and child labour.

We recognise that modern slavery is a complex, global problem that requires a collaborative commitment to eradicate and we are committed to working with our business stakeholders to achieve this.

We are committed to the highest standards of conduct, transparency and ethical behaviour in all of its business activities.

Pursuant to section 6 of the Act, we have volunteered to comply for the making of annual reports on the business strategies we have in place to mitigate risks of modern slavery in our operation and associated supply chains.

The purpose of this Policy is to ensure, we:

  • operate in accordance with local, national and any other applicable laws and regulations;
  • sources product and services ethically and work collaboratively with suppliers to achieve improvement in social and environmental business practices;
  • implements appropriate actions to prevent, reduce and wherever possible eradicate any modern slavery in our operations or supply chain; and
  • voluntarily meet the legal and regulatory obligations under the Act.

This Policy applies to all directors, Employees and agents of AHP. It should be read in conjunction with the Whistleblower Policy.

Policy

Each separate legal entity and business of AHP must:

  • establish and adopt policies and procedures to ensure ethical sourcing and adequately address the risks of modern slavery;
  • ensure, to the extent possible, that all supplier contracts entered into from the date of this Policy or that are subject to renewal/extension from the date of this Policy:
    • include specific terms relating to compliance with the Act and any foreign modern slavery laws that may be applicable in the location in which they operate;
    • meet the Minimum Requirements as defined in Schedule 1 of this Policy;
    • provide termination rights if the supplier is unable or unwilling to meet the Minimum Requirements;
  • use risk assessment to consider factors such as product type and country of origin, in order to monitor suppliers for compliance with the Minimum Requirements;
  • provide accountability for management of any risks and/or issues of modern slavery in respect of each of AHP legal entities and businesses;
  • demonstrate due diligence in the onboarding process of any new supplier to determine their risk level in relation to modern slavery and ethical sourcing;
  • ensure that appropriate training in the procedures regarding ethical sourcing and modern slavery as defined in this policy and implemented by the division/business unit, is provided to any relevant roles within the division or business unit;
  • work collaboratively with suppliers to address any breach of this policy; and
  • monitor and perform an annual audit of the effectiveness of the risk management processes outlined above.

Reporting

It is imperative that all Employees and AHP suppliers feel free and safe to come forward when they have reasonable grounds to suspect that there is evidence of unethical behaviours or a breach of laws and obligations relating to modern slavery or ethical sourcing.

Reports can be made by:

  • Utilisation of the Whistleblowers Policy;
  • Contacting the Australian Federal Police who are responsible for investigating suspected cases of modern slavery. To discuss or report a suspected case they can be contacted 131 237.
  • If someone is in immediate danger or it is an emergency, if you are in Australia, please telephone (000) for police assistance.

All reports of Reportable Conduct submitted under the Whistleblower Policy will be investigated by a Whistleblower Protection Officer on a timely basis. Appropriate corrective action will be taken as warranted by the investigation.

Distribution of this Policy

This Policy is available to the public, current Employees of AHP suppliers on our website or upon request.

Amendment to this Voluntary Modern Slavery and Ethical Sourcing Policy

This Policy may be amended at any time and from time to time with the approval of the directors of AHP.

Adoption of Policy

This Policy was adopted by AHP on the 23 February 2021 and takes effect from that date.

Definitions

In this Voluntary Modern Slavery and Ethical Sourcing Policy:

“Act” means the Modern Slavery Act 2018 (Cth).

“AHP” means each legal entity described in the Legal Notices.

“Child Labour” means work that is mentally, physically, socially or morally dangerous, harmful to children and/or interferes with their schooling by depriving them of the opportunity to attend, obliging them to leave school prematurely or requiring them to attempt to combine school attendance with excessively long and heavy work.

“Employee” includes any director, secretary, officer, employee (current or former employees who are permanent, part-time, fixed-term or temporary), volunteer, secondee or contractor (or employee).

“International Labour Organisation” (“ILO”) means the tripartite U.N. agency, consisting of 187 member States , who set labour standards, develop policies and devise programmes promoting decent work for all women and men.

“ILO Convention 138” means the Minimum Age Convention, 1973 as set out on the ILO website.

“Reportable Conduct” has the same meaning given to that term in the Whistleblower Policy.

“Whistleblower” means an Employee or Eligible Discloser (as defined in the Whistleblower Policy) who alerts the AHP and/or a regulatory authority to Reportable Conduct within AHP.

“Whistleblower Policy” means AHP’s current Whistleblower Policy available on the AHP website.

Schedule 1 - Minimum Requirements

No Child Labour

  • Suppliers will comply with all applicable local laws in regard to minimum legal working age in the country in question. If not legislated, then Convention 138 of the International Labour Organisation (ILO) shall apply.
  • Suppliers must verify and document the age of all employees.

No bonded or forced labour

Suppliers must:

  • Not use any kind of forced labour (any work demanded under threat of penalty or not freely agreed to by the worker).
  • Not use any bonded labour (any work with little or no pay received by the worker, but in repayment of a debt owed by themselves or another person.

Working conditions, wages and record keeping

  • Wages, overtime and benefits must be compliant with all applicable local laws.
  • Prior to commencement of employment, workers must be provided with clear written information relating to their conditions of employment, wages and benefits.
  • Record keeping must be accurate and transparent.
  • Working environment should be safe for workers to perform their duties.

Hours of Work

  • Working hours must be compliant with local law and must not exceed the maximum working hours mandated by those laws.
  • If working hours are not legislated, then the applicable ILO convention should be applied.
  • Overtime will be agreed not mandated and must:
    • not be excessive in hours or regularity; and
    • compensated in compliance with applicable local laws.

Discrimination

Employment should be based on individual ability and suitability for the role. Conditions of employment must not be based on gender, race, religious or personal beliefs, sexual orientation, age, disability, marital status or political views

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