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Modern Slavery Policy

Introduction

Phyllis Song is committed to ensuring that modern slavery does not exist within our business operations or supply chains. We support human rights and align with the values of respect, equality, and integrity.

This policy outlines our approach to identifying and preventing modern slavery and human trafficking within our business and our supply chains, in accordance with the Modern Slavery Act 2018 (Cth)

Purpose

The purpose of this policy is to:

  • Ensure compliance with the Modern Slavery Act 2018.

  • Outline Phyllis Song's commitment to preventing slavery, servitude, forced labour, and human trafficking.

  • Provide a framework for identifying, managing, and mitigating modern slavery risks in our operations and supply chains.

Scope

This policy applies to all employees, contractors, suppliers, and business partners who work with or on behalf of Phyllis Song. It extends to all areas of our operations, including supply chain management, procurement, and partner selection.

What is Modern Slavery?

Modern slavery encompasses situations where coercion, threats, or deception are used to exploit individuals and deprive them of their freedom. This includes:

  • Forced Labour: Coerced work under threat.

  • Human Trafficking: Recruitment or transportation of people for exploitation.

  • Debt Bondage: Forced to work to pay off a debt.

  • Child Labour: Exploitation of children through work that deprives them of their childhood or opportunities for education.

Procedure for Identifying and Managing Modern Slavery Risk

1. Risk Assessment

Phyllis Song will conduct regular risk assessments to identify areas where modern slavery risks are most prevalent. This will include:

  • Reviewing supply chains and operations to assess modern slavery risks.

  • Identifying high-risk suppliers and industries.

  • Working with suppliers to improve their understanding of modern slavery.

2. Due Diligence
We will undertake appropriate due diligence to assess the risk of modern slavery in our supply chains. This includes:

  • Screening suppliers and partners for their modern slavery practices.

  • Requiring suppliers to provide evidence of their compliance with anti-slavery laws.

  • Contractually obliging suppliers to adhere to modern slavery policies.

3. Supplier Code of Conduct

All suppliers must adhere to our Supplier Code of Conduct, which includes:

  • A commitment to preventing modern slavery.

  • Ensuring fair wages and working conditions for employees.

  • Transparency in business operations and supply chains.

4. Employee Training

We will provide regular training for employees to:

  • Raise awareness of modern slavery.

  • Identify signs of forced labour or exploitation.

  • Understand reporting procedures for suspected violations.

5. Reporting Concerns

If you suspect modern slavery or human trafficking, you must report it immediately. Employees and contractors are encouraged to report any concerns, anonymously if desired, through the following channels:

  • Internal Reporting: Contact the Compliance Officer at [Contact Details].

  • Anonymous Reporting: Use the Phyllis Song whistleblower hotline at [Hotline Details].

We ensure that all reports are treated confidentially and investigated thoroughly.

Procedure for Identifying and Managing Modern Slavery Risk

Phyllis Song commits to monitoring the effectiveness of this policy. This includes:

  • Regular audits of suppliers.

  • Annual reviews of our modern slavery risks and procedures.

  • Public reporting on our progress in accordance with the Modern Slavery Act.

Consequences of Non-Compliance

Non-compliance with this policy may result in disciplinary action, termination of contracts, or further legal action against individuals or organisations involved in modern slavery practices.

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