Modern Slavery Policy

The term modern slavery describes situations where coercion, threats or deception are used to exploit victims and undermine their freedom. It is used to describe the serious exploitation, coercion, threats, and deception used to exploit victims and undermine their freedoms. It can be difficult to identify the types of coercion and deception that are considered modern slavery.

Trafficking in persons

The recruitment, harboring and movement of a person for exploitation through modern slavery.

Slavery

Where the offender exercises powers of ownership over the victim, including the power to make a person an object of purchase and use their labour in an unrestricted way.

Servitude

Where the victim’s personal freedom is significantly restricted, and they are not free to stop working or leave their place of work.

Forced labour

The victim is either not free to stop working or not free to leave their place of work.

Forced marriage

Where coercion, threats or deception are used to make a victim marry or where the victim does not understand or is incapable of understanding the nature and effect of the marriage ceremony.

Debt bondage

The victim’s services are pledged as security for a debt and the debt is manifestly excessive or the victim’s services are not applied to liquidate the debt, or the length and nature of the services are not limited and defined.

The Worst forms of child labour

Describes situations where children are:

• exploited through slavery or similar practices, including for sexual exploitation;
• engaged in hazardous work which may harm their health, safety or morals;
• used to produce or traffic drugs.

The worst forms of child labour can occur in a variety of contexts and industries. This may include orphanage trafficking and slavery in residential care institutions, as well as child labour in factories and manufacturing sites, mining and agriculture.

Deceptive recruiting for labour or services

Describes situations where the victim is deceived about whether they will be exploited through a type of modern slavery.

There are a number of risk indicators which assist in evaluating whether there is a risk of modern slavery. This includes:

Sector and industry risks

There are some sectors and industries that can have high modern slavery risks because of their characteristics, products and process.

This includes indicators such as:

• the use of unskilled, temporary or seasonal labour;
• the use of short-term contracts or outsourcing;
• the use of child labour in hazardous conditions; and/or
• recruitment strategies that target specific individuals and groups from marginalized or disadvantaged communities.

Product and service risks

Some products and services can have a high modern slavery risk because of the way they are produced, provided or used.

This includes indicators such as:

• the cost requirements or timeframes might require supplier to engage in excessive labour working hours;
• the product or goods is made in a country where there is a high risk of reported labour exploitation; and/or
• the services are provided in a country where this is a high risk of reported labour exploitation.

Geographic risks

Some countries may have a higher risk of modern slavery, this can be a result of a number of factors including conflict and socio- economic factors.

This includes indicators such as:

• the country may not have ratified recognized international conventions that relate to modern slavery;
• the country is reported as having a high prevalence for modern slavery; and/or
• there are inadequate protections for workers, including no or low workplace standards.

Entity Risks

There are some entities which may have particular modern slavery risks because of factors including poor governance structures or a record of human rights violations.

This includes indicators such as:

• the entity has previously been reported as non-compliant with the human rights or labour standards;
• the entity has poorly managed procurement and sourcing processes; and/or
• the entity has complex supply chains and audit results conflict with other sources of information.

Modern slavery may not always be easy to identify, but there are a number of indicators, and a combination of these signs may indicate that a person is in a situation of modern slavery, and that further investigation may be required.

The types of indicators include where the suspected victim or victims are:

• living at  the  workplace,  or  another  place  owned/controlled  by  their employer;
• underpaid or not paid at all;
• required to work excessive hours;
• confined or isolated in the workplace or only leave at odd times;
• guarded at work or in their accommodation;
• isolated in remote locations that are difficult to access and/or restricted from contacting or interacting with people outside the workplace (for example, their phones are confiscated, or they are supervised when in public);
• managed by an intermediary or third party who ‘holds’ or ‘invests’ their money for them;
• subject to different or less favorable working conditions than other workers because of their country of origin, gender or other factors;
• unable to terminate their employment at any time;
• appear to be servicing a debt to an employer or a third party (such as a recruitment agent);
• appear to be subjected to, or threatened with, violence in connection with their employment;
• appear to have false travel or personal documents and/or are not allowed access to these documents because they are being held by an employer or third party;
• appear to have been deceived about the conditions of their employment;
• are not provided with contracts in a language and format that they can easily understand;
• are not informed of, or do not appear able to understand the terms and conditions of their employment;
• are not provided with any protective equipment, training or means to refuse to participate in dangerous work practices or refuse to handle known toxic materials or hazards; and/or
• do not have permission to work because they are from another country or appear to be working in breach of visa requirements.

It is important to Manuli Ryco group that its workers are aware of the risks of modern slavery and this policy. Workers must not engage in any activity that would constitute modern slavery or could result in modern slavery practices. Any worker who suspects or is aware of modern slavery occurring at Manuli Ryco group should report and raise those concerns to their manager.

Managers and HR are responsible for:

• ensuring they and their teams are aware of this Policy, especially the indicators of modern slavery;
• escalating to Director where they suspect, or an employee tells them they suspect, modern slavery is occurring within company, or its supply chain;
• understanding issues ‘on the ground’, including in parts of our supply;
• chain in the manager operates in;
• verifying what is happening in their operations and supply chains by accessing the views of workers and vulnerable groups;
• accessing expertise on key issues such as child protection, country or sector specific risks and context specific sensitivities;
• identifying actual, or potential, risks of harm as part of their ongoing due diligence processes and develop effective and context appropriate ways to address such risks;
• raising awareness about the risks of harm and potential pathways to remedy within the organisation, their suppliers or other business partners such as recruitment firms and supply chain workforce; and
• clearly communicating company’s expectations regarding modern slavery
• to suppliers and encourage honest two-way in their engagement.

Employees are responsible for:

• familiarizing themselves with this Policy, in particular the risk indicators of modern slavery; and
• following the internal reporting procedure if they are ever concerned modern slavery may be occurring, or there is a risk that it is occurring, within company’s supply chain.

If a worker of company is concerned that modern slavery is occurring within company or its supply chain, it is important that it is reported in accordance with the following procedure:

• Do not attempt to resolve the situation by yourself. Trying to deal with the situation without support from other areas, governments or trusted partners may lead to further harm to the victim or victims.
• Ensure your actions are always in the best interests of the suspected victim or victims. For example, immediately removing workers from an exploitative situation without appropriate support may lead to unintended negative consequences, including their deportation, re-exploitation, blacklisting by employers and/or violence from creditors.
• Consider if further action is required to verify if modern slavery is occurring. For example, if allegations of modern slavery are made through unsubstantiated media
• reporting you may need to check whether these reports are correct. You should ensure any actions you take do not alert the suspected offenders or result in any unintended consequences for the affected worker or workers.
• Escalate your concerns to you manager or HR.

If you have any questions or queries in relation to this policy, please contact your manager or your Human Resources department.