1.0 Introduction

Risk Advisory Services Pty Ltd (the Company) has operations in five states (NSW, VIC, ACT, SA and WA) across Australia. The Company engages with third party outsourced support services for:

• IT Support;
• Finance and Accounting Support;
• Legal and Compliance Support;
• Marketing Support;

These services are provided by companies and people based in Australia and predominantly in NSW where the Company has its head office.

2.0 Purpose

The purpose of this policy is to:

• express the commitment of the Company against modern slavery; and
• establish the Company’s voluntary commitment to review its supply chain and make improvements to remove the risk of modern slavery.

The policy sets out our overall approach to managing the risks associated with modern slavery and the Modern Slavery Act 2018 (Cth).

This policy will provide information on:

• What is modern slavery
• How to report suspected instances of modern slavery
• How the Company will ensure compliance with the Modern Slavery Act 2018 (Cth)
• How this policy will be made available

3.0 Publication

This Policy will be made available on the Company’s internet website as well as its internal intranet site.

4.0 Policy Statement

The Company is committed to taking steps to ensure that modern slavery is not taking place:

• in any part of its own business; or
• in any of its supply chains.

The Company expects all members of staff:

• To work with the Company as it takes steps in pursuit of removing the risk of modern slavery;
• To remain vigilant in identifying circumstances where there is a risk that modern slavery might be occurring in any part of the Company’s business or in any of its supply chains;
• To report any such circumstances in full and without delay; and
• To conduct duties in such a way to ensure that they are in no way connected with modern slavery.

5.0 What is Modern Slavery

The term modern slavery is used to describe situations where coercion, threats or deception are used to seriously exploit victims and undermine or deprive them of their freedom. This can include:

• Human Trafficking;
• Slavery;
• Servitude;
• Forced Marriage;
• Forced Labour;
• Debt Bonding;
• Deceptive Recruiting;
• Child Labour

5.1 Reporting Suspected Instances of Modern Slavery

There are two reporting avenues available in the event someone suspects an instance of modern slavery whether it be in the operations or supply chain of the Company.

Reporting avenues are:

  1. Making a notification in writing to the Director of Operations or Managing Director; or
  2. By making a notification in line with the Company’s Whistleblowing Policy

6.0 Compliance with the Modern Slavery Act 2018 (Cth)

The Act requires qualifying Companies (minimum annual consolidated annual revenue of $100M) to prepare annual statements covering its reporting period.

The Company does not fall within the remit of The Act as minimum annual consolidated revenues are less than the threshold specified in The Act ($100M).

The company will voluntarily undertake certain steps set out in the essential criteria of The Act as part of its operations. At present the company has a low risk profile with a simple supply chain structures typically utilised by boutique management consulting firms.

The Company has undertaken a review of its top five suppliers and deemed them a low risk. The Company will continue to monitor existing suppliers and will ensure that future major suppliers are aware of their obligations.

7.0 Related Policies

Other organisational policies that should be read in conjunction with this policy:

• HRPOL 02 Code of Conduct Policy
• HRPOL 03 Respect in the Workplace Policy
• HRPOL 17 Grievance Policy
• HRPOL 21 Whistleblower Policy

8.0 Changes to this Policy

This Policy may be subject to change at any time, based on factors such as our operations and the current legislative requirements. Company employees are encouraged to check this Policy frequently to stay up to date with any changes we may make.
The Company will formally review this policy at least on an annual basis.

Authority

This policy has been drafted by the Director of Operations.