Modern Slavery Policy
1. What is Modern Slavery
Modern Slavery is defined by the Modern Slavery Act 2018 (the Act) as including eight types of serious exploitation:
- Trafficking in persons
- Forced marriage
- Forced labour
- Debt bondage
- Deceptive recruiting for labour or services
- The worst forms of child labour, meaning situations where children are subjected to slavery or similar practices, or engaged in hazardous work.
It is important to recognise that modern slavery is prevalent throughout the world and whilst less common, exists in Australia and other developed countries.
‘Associated Entities’ has the meaning given to that term by section 50AAA of the Corporations Act.
‘One Key’ means the One Key Group which consists of One Key Holdings Pty Ltd ACN 150 149 643 and/or any of its Associated Entities;
‘Client’ means any host client to whom One Key places labour hire staff to perform services;
‘Contractors’ means all subcontractors and consultants of or to One Key (whether paid or unpaid);
‘Director’ means a director of One Key;
‘Employee’ means an employee of One Key including internal and labour hire employees;
‘Policy’ means this document or any amendment or replacement document; and
‘Supplier’ means a person who supplies goods and services to One Key (whether paid or unpaid) and any employees of the Supplier.
3. Policy Coverage
This Policy applies to all individuals working for or on behalf of, or providing services to, One Key in any capacity, including all Suppliers, Employees (whether permanent, casual or fixed-term), Directors, officers, or any other person associated with us, or any of our subsidiaries or their employees.
One Key expects that all who have, or seek, a relationship with One Key to familiarise themselves with this Policy and to act in a way that is consistent with its values.
One Key will only do business with Suppliers who fully comply with this Policy, or those who are taking verifiable steps towards compliance.
4. Addressing Modern Slavery Risks
One Key will not tolerate any form of modern slavery within its own operations or within its supply chains.
One Key is committed to promoting a culture of openness and accountability, which is essential in order to preventing modern slavery or human trafficking. You should notify your line manager or HR as soon as possible if you have any concerns, issues or suspicions about modern slavery in any parts of the business or its supply chains. You may also utilise the One Key Whistleblowing portal at https://onekeyresources.com.au/whistleblower/ to report any concerns.
The processes in relation to One Key’s suppliers are set out below.
One Key aims to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. One Key is committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of One Key’s business or its supply chains.
5. Our response to Modern Slavery
All employment with One Key is voluntary.
One Key does not use or condone, child or forced labour in any of its operations and works to ensure these practices are not present in its workforce or supply chain.
One Key does not tolerate any form of unacceptable treatment of Employees, including but not limited to the exploitation of children, physical punishment or abuse, or involuntary servitude.
One Key abides by all laws and regulations regarding pay practices and the classification of employment according to job level and status.
Where One Key is made aware of modern slavery practices in its own business or within its supply chain, One Key will investigate all claims and if valid, resolve the issue in line with the values expressed in this Policy.
One Key encourages all Employees and Contractors to monitor for signs that could indicate modern slavery.
6. One Key’s Supply Chain
Any breach of this Policy will be taken seriously and dealt with on a case by case basis.
A breach of this Policy by an Employee may lead to disciplinary action being taken in accordance with One Key’s disciplinary process. Serious breaches may be regarded as gross misconduct and may lead to the termination of employment in accordance with One Key’s disciplinary procedures.
A breach of this Policy by a Supplier or Client will also be dealt with on a case by case basis.
Depending on the behaviour, One Key may choose to adopt a zero-tolerance stance towards the Supplier or Client’s behaviour and look at methods of preventing further engagement with the Supplier or Client, or may decide not to work with the Supplier until they become compliant with this Policy.
One Key expects its Clients and Suppliers to have similar values to One Key in relation to modern slavery.
One Key is committed to introducing anti-slavery obligations in all Supplier contracts. As part of their contractual obligations, Suppliers will agree to undertake a process so One Key can gauge the Supplier’s ongoing commitment to eradicating modern slavery within its own business and those of its own suppliers.
One Key requires it’s Clients to take reasonable steps to ensure it has in place adequate procedures and policies to prevent and address involvement in modern slavery, including through its subcontractors (and to the extent practicable, its other suppliers and business partners) in line with the Act and recognised international standards including the UN Guiding Principles on Business and Human Rights.
7. Breach of this Policy
Any breach of this Policy will be taken seriously and dealt with on a case by case basis. A breach of this Policy by an Employee may lead to disciplinary action being taken in accordance with One Key’s disciplinary process. Serious breaches may be regarded as gross misconduct and may lead to the termination of employment in accordance with One Key’s disciplinary procedures. A breach of this Policy by a Supplier or Client will also be dealt with on a case by case basis. Depending on the behaviour, One Key may choose to adopt a zero-tolerance stance towards the Supplier or Client’s behaviour and look at methods of preventing further engagement with the Supplier or Client, or may decide not to work with the Supplier until they become compliant with this Policy