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Modern Slavery Policy and Statement

Introduction

Under the Modern Slavery Act 2018 (Cth) (the Act), ‘modern slavery’ is defined as conduct which would constitute an offence under the human trafficking, slavery and slavery-like offence provisions under Divisions 270 and 271 of the Criminal Code Act 1995 (Cth), whether the conduct took place inside and outside of Australia. Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Coverage

This policy applies to all employees, contractors and suppliers of the Linfox Armaguard Group including Linfox Armaguard Pty Ltd (ACN 099 701 872), and its subsidiaries including , Point 2 Point Secure Pty Ltd (ACN 149 376 116), Integrated Technology Services Pty Ltd (ACN 079 514 917), Armaguard Technology Solutions Pty Ltd (ACN 601 253 187), ACM New Zealand Limited (NZCN 2194349), Integrated Technology Solutions Limited (NZCN 1299587) and Global Integrated Solutions Limited (NZCN 2227543) (together, Linfox Armaguard) or company.

Purpose

This policy sets out Linfox Armaguard’s commitment to:
• ensuring the company is compliant with Australian and international laws and regulations in the areas in which the company operates;
• demonstrating our commitment to addressing modern slavery in all its forms; and
• promoting awareness of concerns surrounding modern slavery to our employees and
suppliers.
Linfox Armaguard operates in Australia, New Zealand and Thailand and is dedicated to reducing the risk of modern slavery arising, directly or indirectly, out of its business activities and within its supply chain, both nationally and internationally. 

Our Approach

We have a zero-tolerance attitude and approach to modern slavery and are determined to promote awareness within our workforce and supply chain of the risks relating to modern slavery. We are committed to acting ethically and with integrity in all business dealings and relationships and to implementing and enforcing effective systems and controls to assess and manage modern slavery risks.
We expect that our employees and contractors will comply with this policy and uphold our values at all times and any breaches of our policy will be subject to investigation and potential disciplinary action.
We expect that our customers and suppliers match and reflect our dedication to preventing the existence of modern slavery within our supply chain and that they comply with all applicable legislation and regulations in relation to workplace rights and labour laws. Any breaches of our supplier agreements arising under this policy will be referred to General Counsel for investigation and potential breach action. 

Modern Slavery Statement

Linfox Armaguard is subject to the requirements of the Act as a reporting entity. Section 16 of the Act requires the company to submit an annual Modern Slavery Statement to identify and address the following mandatory criteria:
• The company’s structure, operations and supply chains;
• Modern slavery risks in the reporting company’s operations and supply chains (including those of subsidiary entities);
• Actions taken (including by subsidiary entities) to assess and address those modern slavery risks, including due diligence and remediation processes;
• How the company assesses the effectiveness of actions taken; and
• The process of consultation with subsidiary entities in preparing the modern slavery
statement.
Linfox Armaguard will report as part of the Linfox Group, which also includes Linfox Pty Limited (ABN 59 004 667 298) and its wholly-owned subsidiaries, including Linfox Australia Pty Ltd (ABN 47 004 718 647) and Linfox International Group Pty Ltd (ABN 79 058 015 544), and their respective subsidiaries (together, Linfox). The Chair of the Linfox Board will sign Modern Slavery Statements as the ‘responsible member’ for the purposes of the Act.

Communication, Awareness and Training

To ensure Linfox Armaguard employees and subcontractors are aware and educated of the nature and risks of modern slavery in the workplace, our modern slavery policy will be published and distributed to all Australian and New Zealand employees who will also be able to access copies of these documents via the intranet. 
Linfox Armaguard provides more specific training to those employees through whom the steps taken by the company in compliance with this policy are most likely to be taken. The aim of the training is to ensure a high level of understanding of the nature of modern slavery and the influence the company can bring to ensure that it does not occur within any part of its own business and in any of its supply chains.
Linfox Armaguard expects its suppliers and other business partners to provide similar training to their employees.

Breaches of this Policy

The breach of this policy by an employee, director or officer of the company may lead to disciplinary action being taken in accordance with the company’s disciplinary procedure. Serious breaches may be regarded as gross misconduct.
All employees, directors and officers of the company will be expected to cooperate fully in any investigation into suspected breaches of this policy or any related processes or procedures.
If an issue is identified with a supplier, we will work with them to prepare a corrective action plan and resolve all violations within an agreed upon time period. We reserve the right to terminate our relationship with individuals and organisations in our supply chain if they breach this policy.
If any part of this policy is unclear, clarification should be sought from the Linfox Armaguard General Counsel.

Reporting 

The Linfox Armaguard General Counsel will provide regular reporting to the Board on:
• any breaches of this policy; and
• modern slavery risk and what the company is doing to address those risks identified on the risk register.

Responsibilities

a. Policy Management
The Board of Directors has overall responsibility for this policy and in ensuring that the company complies with all its legal and ethical obligations.
Approval of the Policy is vested with the Board.

Reviews of the Policy are the responsibility of the Linfox Armaguard General Counsel and will be conducted annually. This is to ensure that the policy remains consistent with all relevant legislative requirements as well as the changing nature of the company.

b. Policy Implementation
The Chief Executive Officer (CEO) will have the primary day-to-day responsibility for the implementation of this policy, monitoring its use and ensuring that the appropriate processes and control systems are in place, and amended as appropriate, to ensure it can operate effectively.
Managers 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.

All employees are responsible for following the policy to the extent that it affects their day- to-day work and in respect of the reporting requirements. Employees are expected to raise concerns with their manager or Human Resources. Please also refer to our Whistleblower Protection Policy about any suspicion that modern slavery might be occurring in any part of the company's business or in any of the company’s supply chains at the earliest possible opportunity.

References - Legislation

  • Crimes Act 1914 (Cth)
  • Criminal Code Act 1995 (Cth)
  • Fair Work Act 2009 (Cth)
  • Migration Act 1958 (Cth)
  • Modern Slavery Act 2018 (Cth)
  • Modern Slavery Act 2018 (NSW)

References – Policies

  • Modern Slavery Policy
  • Workplace Behaviour Policy
  • Grievance Policy
  • Conflict of Interest Policy
  • Modern Slavery Statement FY2019-2020
  • Anti-Corruption and Bribery Policy
  • Whistleblower Protection Policy
  • Fraud and Corruption Control Policy
  • Code of Conduct (The Linfox Way)
  • Enterprise agreements, awards, collective agreements
  • Recruitment and selection policies and standards
  • Supplier and subcontractor management policies and systems

Contacts and Additional Information

If you would like further information in relation to this policy, please contact Liza Grage-Perry: liza.grage-perry@linfoxag.com

 

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