Modern Slavery

Purpose

The purpose of this policy is to:

prevent, detect, and respond with mitigating controls to the risk of Modern Slavery occurring within Duroworld Pty Ltd, its supply chain or in any other business relationships;
demonstrate Duroworld Pty Ltd.’s commitment to only doing business with those who fully comply with the Act; and
ensure compliance with the Act (as may be amended from time to time).

Scope

This policy applies to all persons working for Duroworld Pty Ltd or on its behalf in any capacity including the Managing Director, employees, contractors, interns, external consultants, third party representatives and business partners (collectively referred to as personnel on this policy).

Meaning of Modern Slavery

The term ‘modern slavery’ describes situations where coercion, threats or deception are used to exploit victims and undermine their freedom. Coercion, threats, and deception can be explicit or implicit.

The Modern Slavery Act 2018 (Cth) ‘Act’ defines modern slavery as including eight types of serious exploitation; trafficking in persons, slavery, servitude, forced labor, forced marriage, debt bondage, the worst forms of child labor and deceptive recruiting for labor or services.

The worst forms of child labor means extreme forms of child labor that involve the serious exploitation of children, including through enslavement or exposure to dangerous work. The worst forms of child labor does not mean all child work.

Under Australian law, modern slavery is defined in the Act. In the event of any inconsistency, the definitions in the Act take precedence over this policy.

Policy Statement

Duroworld Pty Ltd has a zero-tolerance approach to Modern Slavery.

Duroworld Pty Ltd is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure Modern Slavery is not taking place anywhere in its own business operations or supply chains.

Personnel are encouraged to raise concerns with the Managing Director about any likely Modern Slavery breaches in any parts of Duroworld Pty Ltd.’s supply chains or businesses, at the earliest possible stage.

Duroworld Pty Ltd expects the same high standards from all of its suppliers, contractors and other business partners. Duroworld Pty Ltd.’s contracting processes will include specific prohibitions against the use of forced, compulsory or trafficked labor, or anyone held in slavery or servitude, whether adults or children, and expect suppliers to hold their own suppliers to the same high standards.

Responsibilities

The Managing Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under their control comply with it.

The Managing Director has primary and routine responsibility for implementing this policy, monitoring its use and effectiveness, and dealing with any queries about it. The Managing Director’s responsibilities extend to:

monitoring, consulting, and auditing internal controls and procedures to identify risks of modern slavery practices in our operations under Australian modern slavery legislation, including in our subsidiary organisations;
monitoring and consulting with our suppliers, contractors, and business partners to identify risks of modern slavery practices in our supply chains;
developing measures to assess and address any risks of modern slavery practices, including through due diligence in our contractual relations;
monitoring the effectiveness of those measures; and
developing appropriate training materials and programs for our employees to comply with this policy.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains, including any areas of our business and supply chains which are identified as at risk of modern slavery practices.

Training and Communication

This policy will form part of the induction process for all individuals who work for Duroworld Pty Ltd, whether as an employee or a contractor, and will include training on how to identify and report modern slavery practices.

How to Raise a Concern

The Company supports and encourages personnel to raise genuine grievances about Modern Slavery matters, whether identified by, or affecting them, in the workplace. We encourage our personnel and suppliers to report any instances that suggest that there is a risk, potential or actual, of Modern Slavery occurring in the supply chain, activities, or operations of Duroworld Pty Ltd or its suppliers or third parties.

Duroworld Pty Ltd seeks to ensure that its personnel can raise concerns without fear that their future employment prospects will be adversely affected. If you wish to report a concern in relation to Modern Slavery, including any conduct that may be or result in a breach of this policy, you may raise it with your manager or the Managing Director.