1.0 Introduction and Purpose
Compassion Australia (“CAU”) works in the Christian public benevolent tradition of assisting children and their families living in poverty regardless of their beliefs, gender, or background. The poor from developing countries are at a disproportionally higher risk of being subjected to modern slavery practices.
This policy supports CAU’s commitment to identify, prevent, mitigate, and where appropriate, remedy modern slavery practices in its operations and supply chain. Specifically, CAU considers that modern slavery is inconsistent with the Christian faith and breaches the fundamental freedoms and human rights of individuals. Modern slavery is never acceptable in any of its forms.
2.0 Who this Policy applies to
This policy applies to all:
(a) Board members;
(b) employees;
(c) any business in CAU’s supply chain;
(d) anyone else involved with CAU.
3.0 Policy Statement
3.1 CAU commits to taking meaningful action to reduce modern slavery including-
3.1.1 undertaking risk-based assessments and due diligence of its supply chains and operations to identify and address the risks of modern slavery, and
3.1.2 engaging with its suppliers to gain a proper understanding of the controls they have in place to identify and address the risks of modern slavery, as informed by risk-based assessments, and
3.1.3 including specific modern slavery provisions in contractual documentation with suppliers, according to risk-based assessments and as appropriate for the engagement, and
3.1.4 promoting awareness of modern slavery through training for staff and supporting staff, suppliers and contractors in identifying and addressing modern slavery.
3.2 Officers and staff of CAU are required to take all reasonable steps to ensure that there are no modern slavery practices in CAU’s operations and supply chains, including-
3.2.1 participating in all training required by CAU in relation to modern slavery, paying close attention to the common indicators of modern slavery and any high risk areas identified, and
3.2.2 complying with CAU’s policies, processes, procedures, and instructions regarding modern slavery, and
3.2.3 reporting concerns about modern slavery to legal@compassion.com.au, and
3.2.4 reporting concerns under CAU’s Whistleblower Policy where appropriate.
3.3 Suppliers and contractors, by choosing to support CAU, are expected to
3.3.1 demonstrate their commitment to identifying, assessing, and addressing modern slavery in their operations and supply chains in the jurisdictions in which they operate, and
3.3.2 work collaboratively with CAU to prevent, mitigate and, where appropriate, remedy modern slavery in their operations and supply chains, and
3.3.3 notify CAU of any suspected or actual incident of modern slavery as soon as practicable after becoming aware of it via legal@compassion.com.au and under CAU’s Whistleblower Policy where appropriate; and
3.3.4 take reasonable steps to facilitate compliance with this policy even if this policy is not part of any contract they have with CAU.
4.0 Definitions
“Modern Slavery” means situations where a worker is severely constrained in their ability to refuse or cease work because of coercion, threats, or deception. Modern slavery can be complex and multi-faceted and can be difficult to spot, taking many forms including:
(a) trafficking in persons, as defined in article 3 of the Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children;
(b) the worst forms of child labour, as defined in article 3 of the ILO Convention (No. 182) concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour;
(c) forced labour - forcing a person to work by coercion or threats (and servitude is when that person’s freedom is significantly restricted);
(d) forced marriage - a marriage without free and full consent – for example, due to lack of understanding or duress/coercion;
(e) 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;
(f) 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;
(g) child labour - not always unlawful but not tolerated by us when it involves exploiting children, depriving them of education, making them work in unsafe working environments.
5.0 Non-compliance with Policy
A breach of this policy may have the following consequences –
5.1 for officers and staff – disciplinary action may be taken, up to and including termination of appointment, engagement, or employment, and
5.2 for suppliers and contractors – breach of this policy may prejudice the relationship with CAU and may constitute a breach of contract. CAU may end its relationship with a supplier or contractor if they do not take any steps reasonably required to detect or reduce modern slavery because of the criminal nature of human trafficking and modern slavery activities and the seriousness with which CAU views such criminal behaviour.
Approved by the board of Compassion Australia June 2022.