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Modern Slavery Policy

CHAMPIONING HUMAN RIGHTS, DIGNITY FOR ALL

VICNA’s Modern Slavery Policy

Purpose 

Modern Slavery is a crime and violation of human rights and is defined under the  Australian Modern Slavery Act 2018 (the Act) as including many forms. These include: 

  • Human trafficking. 
  • Slavery. 
  • Servitude. 
  • Forced marriage. 
  • Sexual exploitation. 
  • Criminal exploitation. 
  • Domestic servitude. 
  • Labor exploitation. 
  • Organ harvesting. 
  • Forced labor. 
  • Debt bondage. 
  • Deceptive recruiting for labor or services; and the 
  • Child labor 

Policy Program 

We operate several policies which reflect our commitment to act legally and properly in  all our organizational relationships and to implement and enforce effective systems and  controls. Our policies which contribute to minimizing the risk of modern slavery and  human trafficking in our organization and our supply chain include our: 

  • Recruitment policy 
  • Whistleblowing policy  
  • Safeguarding policy 
  • Confidentiality policy  
  • Joining for the organization 
  • Remuneration hours 
  • Personal leave 
  • Standards 
  • Capability 
  • Disciplinary

MODERN SLAVERY POLICY. Approved by the board of Job in Minutes Pty Ltd 

Revised April 2024 

Due April 2026 

  • Grievance 
  • Privacy 
  • Equal opportunities and anti-discrimination 
  • Workplace in general 
  • Bullying and harassment 
  • Drugs and alcohol 
  • Termination of employment 

We will continue to review our policies to ensure that they are effective and appropriate.  Subject to changes in legislation, this Policy will be reviewed and updated accordingly. 

1) The purpose of this Policy is to:  

  • Prevent, detect, and respond with mitigating controls to the risk of Modern Slavery  occurring within VICNA, its supply chain or in any other business relationships. 
  • Demonstrate VICNA’s commitment by doing business with those who fully comply with  the Act and oppose any form of modern slavery; and 
  • Ensure compliance with the Act (as may be amended from time to time). 

2) Scope 

This policy applies to all persons working for and with VICNA or on its behalf in any  capacity, including employees, directors, officers, volunteers, external consultants,  third-party representatives, and business partners. 

3) Policy Statement  

  • VICNA has a zero-tolerance approach to Modern Slavery. 
  • VICNA 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 within its own business  operations or supply chains.  
  • VICNA is also committed to ensuring there is transparency in its approach to tackling Modern Slavery throughout its business and supply chains, consistent with the VICNA’s disclosure obligations under the Act.  
  • The prevention, detection and reporting of Modern Slavery in any part of the VICNA’s  business and supply chains is the responsibility of all those working for it or under its  control. 

MODERN SLAVERY POLICY. Approved by the board of Job in Minutes Pty Ltd 

Revised April 2024 

Due April 2026 

  • Employees, including contractors, are encouraged to raise concerns with their  manager or Governance Director about any or potential Modern Slavery breaches in  any parts of VICNA’s supply chains or business, at the earliest possible stage. 
  • VICNA expects the same high standards from all its contractors, suppliers, and other  business partners. VICNA’s contracting processes will include specific prohibitions  against the use of forced, compulsory or trafficked labor, anyone held in slavery or  servitude, whether adults or children, and expect suppliers to hold their own  suppliers to the same high standards. 

4) Risk of Modern Slavery 

We are continuously reviewing our operations and policies to assess the risk to VICNA of  participating/engaging or enabling modern slavery and have determined that the risk is  very low. Indeed, because of the nature of our business notwithstanding this, we remain vigilant in monitoring the risks of modern slavery in our business and the operations. To  further mitigate this risk, we are including specific clauses on modern slavery in our  agreements which require all our internal staff, clients, and whomever related to the  business, to represent that each of their affiliates, agents, and subcontractors has not  been involved in any modern slavery and will comply with all anti-slavery and human  trafficking laws along with VICNA’s expectation of same. 

5) The Effectiveness of our Policies and Processes 

VICNA recognizes that monitoring and responding to modern slavery hazards is a  continuous requirement. As our company grows and evolves, we will continue to monitor  and enhance our anti-slavery and human rights programs, both on our own and in  collaboration with relevant organizations and individuals. 

We are confident that our rules and practices effectively prevent the risks of modern  slavery and human trafficking both internally and throughout our activities. Appropriate  reporting is critical for effective policies. We also hope to achieve this goal by maintaining  a strong no-retaliation policy, as outlined in our Whistleblower Policy. VICNA will not  retaliate against anybody for filing a complaint or participating in an inquiry in good faith,  including where such concerns relate to modern slavery within the operations, and we  will not tolerate retaliation from anyone. Following the above-mentioned due diligence  and remedial processes, VICNA examines its existing policies and procedures as they  relate to modern slavery on a regular basis in accordance with how we understand it.

MODERN SLAVERY POLICY. Approved by the board of Job in Minutes Pty Ltd 

Revised April 2024 

Due April 2026 

We strive to maintain the highest ethical standards at VICNA. We are committed to  having a workplace in which employees can report any ethical concerns that may be in  violation of our policies, free of any harassment, discrimination, or retaliation. 

6) How to Report Modern Slavery Concerns 

Colleagues who suspect incidents or signs of modern slavery in Australia and  Internationally should; 

  • Report their concerns to their immediate supervisor who will then in turn, as  required initiate formal investigations by contacting any/some or all the below  mentioned departments but not limited to: 
  • Contact local law enforcement: Local police departments in several countries  have specialist divisions that investigate human trafficking charges. • Reporting to national hotlines: Many countries have dedicated national hotlines  to receiving allegations of human trafficking. 
  • Contacting non-governmental organizations (NGOs): Non-governmental  organizations (NGOs) such as the International Organization for Migration (IOM)  and Amnesty International frequently have people trained to handle reports of  human trafficking. 
  • Contacting international organizations: The United Nations Office on Drugs and  Crime (UNODC) and the International Labor Organization (ILO) both have tools to  help in reporting human trafficking. 
  • Contact Anti-Slavery International at: https://www.antislavery.org/contact-us/ or  other specialist anti-slavery organizations. 
  • Search online for the relevant helpline in their country. If colleagues are abroad  and think a person may be being exploited or have been trafficked, they should  contact the embassy or consulate in the first instance for support. 

7) Monitoring, Review and Performance Information 

The monitoring and effectiveness of this policy will be managed by the Head of  Procurement which includes: 

  • Recording and monitoring any incidents or reports made to us which conflict  with our values. 
  • Treating all reports and incidents in line with our confidentiality policy. • Reviewing and strengthening our centralized procurement processes and  policy, considering a range of risks, including slavery and human trafficking.

MODERN SLAVERY POLICY. Approved by the board of Job in Minutes Pty Ltd 

Revised April 2024 

Due April 2026 

  • Ensuring relevant business personnel maintain their knowledge in Modern  Slavery by partaking in education and regular upskilling as required. 

8) Our Internal Training and Awareness Raising 

To ensure a high level of understanding of modern slavery, we annually review our  policies and business risk plans. We strive to promote awareness by undergoing latest  trainings and advetising our commitment to ending Modern Slavery practices through  various channels. VICNA’s commitment to the cessation of any types of modern slavery  policy is made readily available through the company management systems. The  training will be offered to internal staff when applicable to maintain current industry best  practice standard. We will raise awareness internally and externally by providing  education to staff through company meetings and other means of internal  communciation systems such as but not limited to; annoucements, memos, meetings,  newsletters and utilisiation of social media and other IT platforms. 

9) Continuous improvement 

VICNA will review our related policies and documents to ensure these demonstrate the  robustness of our approach to removing the risk of modern slavery from our operation. Any new individuals or organizations conducting business with VICNA will be made  aware of VICNAs stance on modern slavery practices.

MODERN SLAVERY POLICY. Approved by the board of Job in Minutes Pty Ltd 

Revised April 2024 

Due April 2026